Back in 2017, a UK consumer bought two pairs of leggings online, assuming it was a one-off purchase. Seven years later, while updating credit cards, they discovered something unexpected: monthly payments of nearly £60 had been leaving their account for years, totalling almost £5,000.
The charges came from a “VIP” membership they hadn’t realised they’d signed up for – a subscription that billed them every month for store credit they never used. Securing a refund wasn’t straightforward; it involved formal letters, recorded delivery, and repeated emails before most of the money was returned. And they’re not alone; other customers have reported similar experiences, some losing thousands.
This case, highlighted by the BBC, underscores a growing issue in consumer law: subscription traps.
What is a subscription trap?
A subscription trap is when a customer is locked into an ongoing paid subscription without fully understanding what they’ve agreed to. Common tactics include:
- Unclear sign-up terms such as free trials or one-off purchases that silently convert to paid auto-renewal.
- Pre-ticked boxes or hidden opt-ins during checkout.
- Opaque pricing or renewal frequency buried in small print.
- Friction-filled cancellation processes such as requiring phone calls, restricted hours, or multiple steps.
- Failure to send reminders before renewal or cooling-off periods.
The UK Government calls these practices “easy to sign up but hard to cancel”. The cost of this is an estimated £1.6 billion a year in unwanted subscriptions.
Why UK businesses should pay attention
The government is cracking down on subscription traps. Under the Digital Markets, Competition and Consumers Act (DMCCA) 2024, the CMA now has direct enforcement powers (from April 2025) and can impose fines of up to 10% of global turnover.
From spring 2026, companies offering subscriptions must:
- Provide clear, prominent key pre-contract disclosures about auto-renewal, fees, cancellation, and when renewal reminders will be sent.
- Send reminder notices before renewal and end-of-contract notices.
- Offer 14-day cooling-off rights post-renewal.
- Ensure simple, accessible cancellation routes (online or in-app).
The rules apply to paid subscriptions for goods, services and digital content, including trials. They also reach non-UK traders targeting UK consumers. Exclusions include insurance and financial services.
For a broader look at the DMCCA and other consumer law reforms, read our earlier insight: April 2025: The Consumer Law Shake-Up.
Preparing for Compliance
Businesses should review subscription models now to ensure sign-up flows are transparent, renewal reminders are implemented, cancellation processes are simplified, consent records are audited, terms and privacy notices are updated, and training is offered to teams to meet DMCCA standards.
If you want to review your subscription practices or ensure compliance with the DMCCA and wider consumer law, contact our Commercial team today at [email protected].
