In April 2024, I warned that millions of UK consumers were being trapped into ongoing subscription payments they didn’t fully understand or could not easily cancel. The Government has since introduced new laws to tackle subscription traps and fake reviews, but many businesses are still relying on confusion to take consumers’ money.
What is a subscription trap?
As I explained in my April 2024 blog, subscription traps typically involve:
- Free or low-cost trials that roll into paid subscriptions
- Auto-renewals without clear reminders
- Businesses automatically opting consumers in to auto-renewals
- One-off subscription purchases auto renewed
- Cancellation processes designed to make it difficult to cancel
Citizens Advice research in March 2024 revealed that:
- Around 10 million people had unwanted active subscriptions
- The average cost was £14 per month per person
- 40% auto-renewed without warning
- 39% forgot to cancel after a free trial
- 25% were caught out by a one-off purchase turning into a subscription
What has changed since April 2024?
When I wrote my original article, the Digital Markets, Competition and Consumers Act 2024 (DMCC Act) was approaching Royal Assent. That legislation is now law.
The Digital Markets, Competition and Consumers Act 2024 strengthens consumer protection by giving regulators stronger enforcement powers. The Competition and Markets Authority (CMA) can impose fines of up to 10% of global turnover.
Some provisions are already in force, while others – particularly detailed subscription rules – rely on secondary legislation. Further clarity is expected in Autumn 2026.
Companies will be required to give:
- Detailed and clear information upfront
- Issue a reminder before a free-trial or introductory offer ends
- Send reminder notifications before auto-renewals
- Ensure cancellation processes are straightforward
However, this does not mean consumers are powerless in the meantime.
Subscriptions and the Consumer Rights Act 2015
Subscriptions and apps are classed as digital content contracts under Section 34 – Section 36 of the Consumer Rights Act 2015. This includes parking apps.
I contributed to the Daily Telegraph article about Pret a Manger with Gary Rycroft, a resident legal expert on Rip Off Britain, about your consumer rights.
How do I cancel an unwanted subscription?
If you want to cancel a subscription you don’t want or didn’t knowingly agree to:
1. Cancel direct with the business
Always cancel in writing and ask for confirmation. Keep copies of emails or letters for your records.
If they claim you agreed to it and are tied in, ask them to point you to:
- Where the subscription terms were clearly explained
- Where cancellation restrictions were made transparent
Section 62 of the Consumer Rights Act 2015 has a requirement for contract terms and notices to be fair. An unfair term of a consumer contract is not binding on the consumer.
Section 68 of the Consumer Rights Act 2015 has a requirement for transparency. Firms cannot rely on Key Terms buried in the small print.
2. Cooling-off rights
Subscription contracts should include a 14-day cooling-off period under The Consumer Contracts Regulations 2013:
- When you first sign up
- When a free trial converts into a paid subscription
- When a subscription renews into a new contract
Under the Consumer Contracts Regulations 2013, traders must provide clear information about cancellation rights before a contract is formed. If they fail to do so, the consumer’s cancellation period does not expire after 14 days. Instead, it is extended by up to 12 months.
3. Challenging unfair or misleading terms
You can cancel a contract if it was misrepresented and key terms were not made prominent and are unfair. If they refuse to do so, escalate it as a formal complaint and quote the relevant consumer laws.
Why The Digital Markets, Competition and Consumers Act 2024 (DMCC Act) matters for subscription traps
This regulation is particularly important for subscription traps, where businesses often:
- Bury cancellation rights in small print
- Fail to explain them clearly at sign-up
- Omit key information
- Making cancellation deliberately difficult
- Rely on consumers not knowing they can cancel
Where cancellation rights were not properly explained, consumers may still be legally entitled to cancel months later and claim a refund.
Is it illegal to make subscriptions difficult to cancel?
UK consumer law requires contract terms to be fair and transparent. Businesses cannot:
- Rely on key terms of a contract and how to cancel hidden in the small print
- Make cancellation significantly harder than sign-up
If a term is found to be unfair under the Consumer Rights Act 2015, it is not binding on the consumer.
How to cancel unwanted subscriptions?
Practical steps that work:
- Audit bank, card and mobile phone bills and statements for the past 12 months
- Watch for vague or unfamiliar payment descriptions
- Set reminders for free trials a few days before they expire
- Keep written confirmation of cancellations
- Opt for Direct Debit and avoid card payments where possible (Continuous Payment Authority)
Subscriptions to apps can even be charged via mobile phone bills, which many people overlook.
How the law protects you
Even before the Digital Markets, Competition and Consumers (DMCC) Act 2024, subscription traps were often unlawful under:
- The Consumer Rights Act 2015 (unfair and non-transparent terms)
- The Consumer Contracts Regulations 2013 (cooling-off rights and information duties)
- The Consumer Protection from Unfair Trading Regulations 2008 (misleading actions and omissions)
The Digital Markets, Competition and Consumer Act 2024 (DMCC Act), which has replaced and updated the Consumer Protection from Unfair Trading Regulations 2008, also protects consumers from unfair trading practices and and has a fairness test.
For a practice to be unfair under these rules, they must harm, or be likely to harm, the economic interests of the average consumer.
Getting your money back
You may be entitled to a refund if:
- You cancelled within a cooling-off period
- You were misled into signing up
- Charges were taken without proper authorisation
- The service was not as described
- The subscription terms were unfair or hidden in the small print
If the business refuses to refund you, contact your bank or card provider.
You can report firms for breaches to the Competition and Markets Authority (CMA), who can impose fines of up to 10% of global turnover.
Finally
In April 2024, I wrote that subscription traps were long overdue for proper enforcement. That remains true.
The law has moved on, consumer awareness has grown but too many businesses are still relying on confusion, inertia and obstruction to deny consumers fair treatment.
If you don’t want a subscription, you do not have to keep paying for it.