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Compliance checklist

UK Subscription Compliance Checklist (DMCCA 2027)

Every duty a UK subscription business must meet under the Digital Markets, Competition and Consumers Act 2024 — organised as a practical checklist. Written for Shopify merchants; applies whichever billing platform you use.

Note: This checklist is informational and does not constitute legal advice. Secondary legislation and CMA guidance may refine the final requirements before enforcement begins.

1. Pre-contract information

Before a customer signs up, the key terms of the subscription must be clear and prominent — not buried in linked terms.

  • ☐ The recurring price, billing frequency, and any price after a trial period are shown before checkout
  • ☐ The fact that the contract auto-renews is stated where the customer commits to buy
  • ☐ The minimum commitment and how to exit are stated up front
  • ☐ Your Terms, Subscription Policy, and Refund Policy pages describe the same terms consistently

2. Renewal reminder notices

The core new duty: customers must be reminded before a renewal payment is taken, with enough time to cancel.

  • ☐ A reminder notice is sent before each renewal charge (for each plan frequency you offer)
  • ☐ The reminder states the renewal date, the amount, and that the contract continues unless cancelled
  • ☐ The reminder explains how to cancel, with a working route
  • ☐ Sending is automated — manual sending does not survive growth or staff changes
  • ☐ Each send is logged with a timestamp you can retrieve later

Reminders are also the highest-value item on this list today: a logged reminder sent before billing is direct evidence of informed consent in a subscription chargeback dispute.

3. Easy cancellation

Cancelling must be as straightforward as signing up — the DMCCA targets cancellation friction directly.

  • ☐ Customers can cancel online without phoning or emailing support
  • ☐ The cancellation route is findable from the customer account in a small number of steps
  • ☐ Your policy states when cancellation takes effect relative to the billing cycle
  • ☐ No dark patterns: no forced retention flows the customer cannot skip

4. Cooling-off rights

The DMCCA extends cooling-off protections to subscription renewals, not just initial signups.

  • ☐ Your refund policy covers the initial 14-day cooling-off period
  • ☐ You have a process for cooling-off cancellations after a renewal, where they apply
  • ☐ Refunds issued under cooling-off are logged with dates

5. Records and evidence

Compliance you cannot prove is compliance you do not have — to the CMA or to a card issuer.

  • ☐ Every reminder sent is logged: recipient, timestamp, content
  • ☐ You can show what your policy pages said on any past date (dated exports or archives)
  • ☐ Cancellations are logged with request date and effective date
  • ☐ Records are exportable — you can hand a dated packet to a dispute reviewer or regulator

Does your subscription platform matter?

The duties above sit with the trader — you — regardless of which app bills your subscribers. The practical setup differs slightly by platform:

For the policy-page requirements in detail, see the UK subscription policy checklist. For the wider legal picture, see the complete DMCCA 2027 guide.

Frequently asked questions

What is the DMCCA and when does subscription enforcement start?

The Digital Markets, Competition and Consumers Act 2024 is UK legislation introducing a dedicated regime for subscription contracts: clear pre-contract information, reminder notices before renewal payments, straightforward cancellation, and cooling-off rights. The subscription provisions are expected to be enforced from Spring 2027, with the CMA able to fine businesses directly up to 10% of global turnover.

Do I need to send renewal reminder emails under the DMCCA?

Yes. The DMCCA requires reminder notices before a subscription renews and takes payment, so customers can cancel before being charged. The reminder must state that the contract will renew, the payment amount and date, and how to cancel. Sending them early also builds the evidence trail that wins chargeback disputes today.

Does the DMCCA apply to Shopify stores selling subscriptions?

Yes. If your store sells subscriptions to UK consumers — through Shopify Subscriptions, Recharge, Appstle, Loop, or any other billing platform — the DMCCA subscription regime applies. The duties sit with the trader (you), not with the app you use.

What records should I keep to prove compliance?

A dated record of every reminder sent (recipient, timestamp, content), what your policy pages said at any given date, cancellation requests and when they took effect, and cooling-off refunds. Dated, exportable records are also exactly what card issuers ask for in subscription chargeback disputes.

Is there a tool that checks my store against this checklist automatically?

Subnotice scans your published Privacy, Terms, Subscription, and Refund policies against DMCCA-derived checks, gives a 0–100 readiness score with fix notes, sends pre-renewal reminders timed to each plan, and exports a dated audit trail. The policy scan is free.

Check your store against this list in 30 seconds

Subnotice scans your published policies against DMCCA-derived checks and shows your 0–100 readiness score with fix notes. Free — no card required.

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