SubClear

Is your subscription flow ready for the UK 2027 rules?

If you sell subscriptions to consumers in the UK, the new rules apply to you wherever your business is based. Answer twenty questions to get a readiness score and a prioritised fix list.

Pre-contract information

Before the customer commits, do you show the recurring price, how often it is charged, and the minimum total they will pay?

Before the customer commits, do you show the recurring price, how often it is charged, and the minimum total they will pay?

Key pre-contract information must be given before the customer enters the contract, separately from the small print.

If there is a free or discounted trial, do you state clearly the date it ends and the price that then applies?

If there is a free or discounted trial, do you state clearly the date it ends and the price that then applies?

Trial-to-paid conversion is the single most complained-about subscription trap.

Do you tell customers, before they commit, how and when you will send renewal and trial reminders?

Do you tell customers, before they commit, how and when you will send renewal and trial reminders?

The timing of reminders is yours to choose but must be stated up front, and then kept.

Do you explain, before they commit, how to cancel and that there is a 14-day cooling-off period?

Do you explain, before they commit, how to cancel and that there is a 14-day cooling-off period?

Undisclosed cooling-off rights can extend the cooling-off period by up to 12 months.

Is the key information readable without expanding, scrolling inside a box, or clicking through?

Is the key information readable without expanding, scrolling inside a box, or clicking through?

The information must be given without the customer taking extra steps to read it.

Reminders

Do you send a reminder before a free or discounted trial turns into a paid subscription?

Do you send a reminder before a free or discounted trial turns into a paid subscription?

A reminder before the end of a concessionary period is required.

Do you send reminders before a contract of 12 months or longer auto-renews?

Do you send reminders before a contract of 12 months or longer auto-renews?

Long contracts need advance warning before they roll over.

For rolling monthly or weekly plans, do you remind customers at least every six months that they are still paying?

For rolling monthly or weekly plans, do you remind customers at least every six months that they are still paying?

Rolling contracts carry a periodic reminder duty tied to six-month periods.

Are reminders sent on their own (email or similar), with their purpose obvious, not buried in a newsletter?

Are reminders sent on their own (email or similar), with their purpose obvious, not buried in a newsletter?

Reminders must be in a durable medium and their purpose immediately apparent.

Cancellation

If a customer signed up online, can they cancel fully online, without calling or emailing support?

If a customer signed up online, can they cancel fully online, without calling or emailing support?

Online sign-up means online cancellation must be available.

Is cancellation free of steps that are not reasonably necessary (no mandatory surveys, repeated 'are you sure', or hidden links)?

Is cancellation free of steps that are not reasonably necessary (no mandatory surveys, repeated 'are you sure', or hidden links)?

The process must be straightforward.

If you show a retention offer, can the customer decline it with one click and continue?

If you show a retention offer, can the customer decline it with one click and continue?

Offers are allowed, but must not frustrate or prolong cancellation.

Do you confirm the cancellation in writing, stating the end date and any final charge?

Do you confirm the cancellation in writing, stating the end date and any final charge?

Customers need evidence, and it reduces disputes and chargebacks.

Can customers cancel by other reasonable means (for example, email) and do you act on those?

Can customers cancel by other reasonable means (for example, email) and do you act on those?

Customers cannot be forced into one narrow route.

Cooling-off and refunds

Do you give a 14-day cooling-off period when a trial converts to paid, with a refund if the customer cancels in it?

Do you give a 14-day cooling-off period when a trial converts to paid, with a refund if the customer cancels in it?

This is a new, non-waivable right for subscriptions taken out from 2027.

Do you give a 14-day cooling-off period after each renewal of a contract of 12 months or more?

Do you give a 14-day cooling-off period after each renewal of a contract of 12 months or more?

Each long renewal restarts a cooling-off window.

Do you refund within 14 days of cancellation, to the original payment method?

Do you refund within 14 days of cancellation, to the original payment method?

The government rejected longer refund windows.

For digital content, do you get express consent to immediate supply and explain the effect on the initial cooling-off period?

For digital content, do you get express consent to immediate supply and explain the effect on the initial cooling-off period?

The existing digital-content waiver continues for the initial period only.

Records and people

Do you keep a record of what information each customer saw at sign-up and every reminder you sent?

Do you keep a record of what information each customer saw at sign-up and every reminder you sent?

Breaches of information and reminder duties give customers cancellation and refund rights, so you need evidence.

Have support staff been told the new rights, and do you have a date to review the final guidance when it is published?

Have support staff been told the new rights, and do you have a date to review the final guidance when it is published?

The draft guidance will be finalised after Parliament approves the regulations.

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