The Act applies where a business has a place of business in the UK, carries on business in the UK, or directs its commercial practices to consumers in the UK by any means. A software company in the United States, a Shopify store in Pakistan or an app developer in Germany that sells subscriptions to UK customers is caught.
In practice the risk for a small overseas business is less about regulator fines and more about customers exercising their new cancellation and refund rights, card chargebacks where the business cannot show it sent reminders, and app-store or payment-platform policies that require compliance with local law.
If you run such a business, use the readiness checklist to see what needs to change in your checkout, reminder emails, cancel flow and refund handling.