If your members pay by card and their membership rolls over each year unless they stop it, the UK is about to treat that as a regulated subscription contract. The rules sit in Part 4, Chapter 2 of the Digital Markets, Competition and Consumers Act 2024, which has Royal Assent but is not yet in force [1][2]. On 19 October 2026 the government laid the draft Consumer Subscription Contracts (Cancellation and Information) Regulations 2026 before Parliament [3][4], with a start date of 1 January 2027 [1][5]. This is a UK rule for business-to-consumer contracts. It is not yet law: the draft regulations still need an approving vote in both Houses [1][3]. The date is firm enough to plan around, though, and the renewal journey on your website is where most of the work lands.
What was published, and what it is not
Two things arrived together: the draft regulations and 77 pages of draft guidance from the Department for Business, Innovation, Science and Trade [1][4]. Regulation 1 of the draft sets commencement at 1 January 2027 [5]. The rules apply only to subscription contracts entered into on or after that date; an existing membership does not fall into scope just because it renews in February [1][4]. If Parliament amends or delays the instrument, the duties below do not change, only the date [3].
Does an association membership count?
The Act defines a subscription contract as one between a trader and a consumer for goods, services or digital content, where the supply recurs or continues automatically, the consumer automatically incurs liability for each period, and the consumer has a right to bring it to an end [2]. An annual membership that auto-renews and charges a stored card ticks every box. Journal access and a members’ area are, on our reading, services and digital content in the Act’s terms [1][2].
Two filters matter more. The first is who pays. A consumer is an individual acting wholly or mainly outside their business; where an employer buys memberships for staff, that is business-to-business and out of scope [1][2]. The guidance does not say where a self-funded professional membership sits, and that is a question for your solicitor, not your web agency. Our working assumption: if an individual pays with their own card and auto-renew is on, build the journey as if the rules apply.
The second is the charity exclusion, which is narrower than most trustees will hope. Schedule 22 to the Act, as enacted, excludes utilities, financial services, telecoms, package travel and similar; it says nothing about charities or membership bodies [1][6]. Draft regulation 40 adds an exclusion for charity memberships, but only where the supply relates to the member viewing property the charity preserves or performances it produces, which the guidance describes as cultural and heritage memberships such as museums, galleries and theatres [1][4][5]. A journal and a conference discount are not that, so do not assume it rescues a charitable subject association.
International societies are not outside it. Traders based outside the UK who sell to UK consumers must comply, and section 275 of the Act applies the chapter to contracts with a close connection to the UK whatever law the contract chooses [1][7].
Five things your renewal journey will need
Key information on the join page itself
Before someone joins, you must give a short block of key information: that the contract continues unless they act, the payment frequency and amount, the minimum total they are committing to, how to end it, and when reminders will be sent [1][8]. If the fee is not monthly, you must also state the monthly equivalent [1][8]. Online, this cannot sit behind a link or a dropdown; the consumer must see it without taking any extra step [1][4][9]. The join button must make it plain that clicking it creates an obligation to pay [1].
Reminders, and two of them for annual renewals
Monthly memberships need a reminder roughly every six months [1][2]. Anything that renews onto a period of 12 months or more needs a reminder before renewal plus an additional, earlier one [1][9]. Each must be on a durable medium such as email, be recognisable as a reminder from the subject line, state the amount and date, and put that information ahead of any marketing in the same message [1][4]. A pop-up or push notification the member cannot retrieve later does not count [1][9]. You choose the sending window, state it in the key information, and then have to hit it [1][2].
A real way out, online
Members must be able to stop auto-renewal at any time, and if they joined online they must be able to leave online [1][2][5]. The government’s view is that offering only an email address does not meet that test; a clearly labelled button in the account area or a simple web form does [1][9]. A compulsory exit survey is unlikely to pass, and a retention offer must not prolong the process [1][9].
Confirmation within 24 hours
After a member stops auto-renewal you must send an end-of-contract notice stating when the membership ends: within 24 hours if they did it online, within three working days otherwise [1][2][4].
A 14-day cooling-off after each annual renewal
When a contract renews onto a term of 12 months or more, the member gets a fresh 14-day right to cancel, and you must tell them so in a separate cooling-off notice [1][2][9]. If they cancel, the refund is proportionate: the guidance’s own example is a £365 annual membership cancelled on day four, where the member owes £4 [1]. You may refund in full if calculating the proportion is more trouble than it is worth [1][9].
What this looks like on a WordPress membership platform
None of this is exotic engineering. After nine years running ISPAH’s digital operation, our experience is that the renewal journey is the least-visited, least-tested part of a membership site, and it drifts. The five duties map onto things a competent platform has: a fixed summary block on the join form, a scheduled email with the right fields merged in, a button on the account page, a transactional confirmation, and a refund rule in the payment integration. The work is in the wording and the dates, not the code.
Then there are existing members. The rules do not reach contracts made before 1 January, so you are not legally required to send notices to them [1][9]. The guidance nonetheless calls consistent protection for all consumers best practice, and running two renewal journeys side by side is its own kind of pain [1][9]. Our view: pick one journey, the compliant one, and give it to everyone.
An afternoon of work before Christmas
Inventory first. One sheet: every membership category, whether it auto-renews, who typically pays, whether you are a charity and what the membership actually supplies. Then open the join page as a new member and check that the key information is visible without clicking. Draft the two reminder emails and the cooling-off notice now, and agree the sending window you will commit to. Check the account page for a button that stops renewal in one step. Ask your platform or payment provider how a proportionate refund is handled, because the answer is often a manual process.
On enforcement: the Competition and Markets Authority can act directly, with penalties of up to £300,000 or 10 per cent of global turnover, whichever is higher [1][4]. On 14 October the CMA said its early focus would be on helping businesses get this right, while warning that businesses should not assume enforcement is being delayed and that conduct in the early months may still be considered [10][11]. For an association with a volunteer web lead, that is a fair deal: show genuine effort, and be there by the first renewal cycle of 2027.
If you looked at your cookie banner after the February rules changed and found it wanting, the renewal journey is probably in the same state. The difference is that this time you have eight weeks’ notice.
References
- Department for Business, Innovation, Science and Trade. Draft Guidance: Part 4, Chapter 2 of the Digital Markets, Competition and Consumers Act 2024 and Draft Consumer Subscription Contracts (Cancellation and Information) Regulations 2026. GOV.UK, October 2026. https://assets.publishing.service.gov.uk/media/6acf97da2de3184ccf8b814e/subscription-contracts-rules-guidance.pdf. Accessed 02 November 2026.
- UK Parliament. Digital Markets, Competition and Consumers Act 2024, Part 4, Chapter 2 (as enacted). legislation.gov.uk, 2024. https://www.legislation.gov.uk/ukpga/2024/13/part/4/chapter/2/enacted. Accessed 02 November 2026.
- UK Parliament. Consumer Subscription Contracts (Cancellation and Information) Regulations 2026 (procedure browser work package). api.parliament.uk, 19 October 2026. https://api.parliament.uk/procedure-browser/work-packages/zCTwHUN0. Accessed 02 November 2026.
- CMS. UK subscription contracts: the Government publishes the missing detail. cms.law, 23 October 2026. https://cms.law/en/gbr/legal-updates/uk-subscription-contracts-the-government-publishes-the-missing-detail. Accessed 02 November 2026.
- UK Government. The Consumer Subscription Contracts (Cancellation and Information) Regulations 2026 (draft statutory instrument). legislation.gov.uk, 2026. https://www.legislation.gov.uk/ukdsi/2026/9780348287912/contents. Accessed 02 November 2026.
- UK Parliament. Digital Markets, Competition and Consumers Act 2024, Schedule 22 (as enacted). legislation.gov.uk, 2024. https://www.legislation.gov.uk/ukpga/2024/13/schedule/22/enacted. Accessed 02 November 2026.
- UK Parliament. Digital Markets, Competition and Consumers Act 2024, section 275 (as enacted). legislation.gov.uk, 2024. https://www.legislation.gov.uk/ukpga/2024/13/section/275/enacted. Accessed 02 November 2026.
- UK Parliament. Digital Markets, Competition and Consumers Act 2024, Schedule 23. legislation.gov.uk, 2024. https://www.legislation.gov.uk/ukpga/2024/13/schedule/23. Accessed 02 November 2026.
- Lewis Silkin. Unsubscribe from confusion: what the UK Government’s guidance on the new subscription rules means for business. lewissilkin.com, 30 October 2026. https://www.lewissilkin.com/insights/2026/10/30/unsubscribe-from-confusion-what-the-uk-governments-guidance-on-the-new-subscrip-102o6yg. Accessed 02 November 2026.
- Cochrane, E. Direct consumer enforcement: 18 months on. Competition and Markets Authority blog, 14 October 2026. https://competitionandmarkets.blog.gov.uk/2026/10/14/direct-consumer-enforcement-18-months-on/. Accessed 02 November 2026.
- Gowling WLG. The countdown is on: new DMCCA subscription rules landing in January 2027. gowlingwlg.com, 21 October 2026. https://www.gowlingwlg.com/en/insights-resources/articles/2026/the-countdown-is-on-new-dmcca-subscription-rules-landing-in-january-2027. Accessed 02 November 2026.
