Subscription Contracts: a LIVE online course presented by Keith Markham

Subscription Contracts

Unfair commercial practices and enforcement update

Consumers regularly enter subscription contracts, but their rights and traders’ obligations remain unclear.

The Digital Markets, Competition and Consumers Act 2024 introduces subscription-specific rules expected to take effect in January 2027. Lawyers and clients must understand and implement them soon; serious non-compliance could incur fines of up to 10% of global turnover.

This webinar summarises the key provisions and steps required for compliance and provides an update in terms of current enforcement action concerning unfair commercial practices where multi-million pound fines have already been levied on traders.

Topics for discussion will include:

Subscription Contracts

Definition of ‘subscription contracts’

• Contracts that are automatically recurring
• Contracts with an increase in the original rate for payment
• Excluded contracts

Pre-contract information to be provided

• Key pre-contract information
• Full pre-contract information
• Key content and timing requirements

Cooling off rights

• Initial and renewal cooling off periods
• Cooling off notices
• Key content and timing requirements

Provision of reminder notices

• Key content
• Timing requirements

Enforcement Update – action taken by the CMA in respect of:

• Drip pricing
• Fake reviews
• Other breaches of the rules on unfair commercial practices
• Unfair terms in consumer contracts