DMCCA 2027: The Complete UK Subscription Compliance Guide for Shopify Merchants
The Digital Markets, Competition and Consumers Act 2024 introduces the biggest change to UK subscription law in a decade. CMA enforcement begins Spring 2027 — here is everything Shopify merchants need to know and do before then.
What is the DMCCA 2024?
The Digital Markets, Competition and Consumers Act 2024 (DMCCA) received Royal Assent in May 2024. It is a wide-ranging piece of legislation covering three distinct areas:
- Digital markets regulation — new powers for the CMA to regulate large tech platforms.
- Competition law reform — updated merger control and investigation powers.
- Consumer protection — Part 2 replaces and extends several existing consumer rights laws, including new rules for subscription contracts.
For Shopify merchants, the relevant section is Chapter 2 of Part 2: the subscription contract provisions. These rules apply to any trader who sells a subscription to a consumer in the UK.
The legislation is available in full at legislation.gov.uk. The CMA has also published detailed guidance for traders.
Does DMCCA Apply to My Shopify Store?
The DMCCA subscription rules apply if all three of the following are true:
- You are a trader (a business or sole trader acting in the course of a business).
- You sell subscriptions to consumers — individuals acting outside their trade or profession. This rules out pure B2B subscriptions.
- Those subscriptions are consumer subscription contracts — recurring contracts where consumers pay periodically for goods, services, or digital content.
- Subscription boxes (coffee, food, beauty, supplements)
- Recurring memberships (gym, wellness, content)
- Subscribe-and-save product subscriptions
- Software as a Service sold direct to consumers
- Any "Subscribe" option on a Shopify product page
Out of scope: B2B subscriptions (selling to other businesses), one-off purchases, and free subscriptions. Your own App subscription fee to DMCCA Guard is also not covered — that is a B2B SaaS agreement. See our FAQ for the full explanation.
5 DMCCA Requirements You Must Meet by Spring 2027
1. Pre-renewal reminder notices
This is the most operationally significant requirement for most merchants. Under DMCCA, traders must send consumers reminder notices before their subscription renews. The CMA's guidance specifies that reminders should be sent:
- 14 days before the renewal date
- 7 days before the renewal date
- 1 day before the renewal date
Each reminder must include the renewal date, the amount that will be charged, and — critically — a clear way for the consumer to cancel before renewal occurs.
For merchants using Shopify Subscriptions (native): Shopify controls the billing cycle and renewal date. You will need to configure renewal reminders through Shopify Email, Klaviyo, or a specialist compliance tool. The raw billing date is not always exposed to third-party apps.
For merchants using Recharge, Appstle, Loop, or Bold: These platforms expose renewal dates via their APIs. A compliance tool can read these dates and automate the 14/7/1-day reminder sequence.
2. Easy cancellation
DMCCA introduces what commentators are calling the "easy exit" requirement. Cancellation must be as easy as signing up. Specifically:
- You must not require consumers to call a phone number to cancel.
- The cancellation route must be simple, clear, and not hidden behind multiple screens.
- A cancel button in the consumer's account area or a prominently linked cancellation page is the expected standard.
Shopify's built-in subscription management (via Shopify Account) already provides a cancel flow. If you use a third-party subscription app, verify that the customer-facing cancellation journey meets the above standard.
3. Pre-contractual information
Before a consumer enters a subscription, you must provide clear, prominent information about:
- The subscription price and how it will be charged (e.g. £X per month)
- How the subscription renews (automatically, on what schedule)
- How to cancel and what happens to the subscription on cancellation
- Any initial fixed-term period before the subscription rolls into an ongoing contract
- Cooling-off rights (see below)
This information should appear clearly on your product page, at checkout, and in your Subscription Policy page — not buried in Terms and Conditions.
4. Annual renewal reminder for long-running subscriptions
For subscriptions that have been running for 12 months or more (particularly annual or rolling monthly subscriptions), DMCCA requires a more prominent annual reminder. This notice must:
- State the total amount charged in the past 12 months
- Confirm the upcoming renewal date and price
- Prominently explain how to cancel
This requirement is designed to prevent "subscription fatigue" — consumers who signed up and forgot, and are now paying annually without realising.
5. Cooling-off period
Where a consumer enters a subscription contract, they have a right to cancel within a cooling-off period (typically 14 days) without penalty. The specific rules depend on whether goods, services, or digital content are involved, and whether delivery has begun.
Your Subscription Policy and Terms pages must clearly explain the cooling-off rights available to your customers.
CMA Enforcement and Penalties
The Competition and Markets Authority (CMA) becomes the primary enforcement body for DMCCA consumer provisions. The CMA's new enforcement toolkit is significantly more powerful than its predecessors:
Beyond financial penalties, the CMA can:
- Issue enforcement orders requiring you to stop non-compliant practices
- Require you to implement a consumer redress scheme (refunds to affected subscribers)
- Make non-compliant subscription terms unenforceable — meaning consumers could cancel and retain money already paid
- Refer breaches to Trading Standards for additional enforcement
Timeline: The subscription provisions are expected to come into force under a commencement order in Spring 2027. However, the CMA has signalled it will be monitoring the market in 2026, and may take informal action or publish compliance warnings before formal enforcement begins.
DMCCA Readiness Checklist for Shopify Merchants
Use this checklist to assess your current position. Each item maps to a specific DMCCA obligation.
Policy pages
- You have a dedicated Subscription Policy page explaining renewal terms, cancellation rights, and cooling-off period
- Your Terms & Conditions include a subscription section with renewal intervals, pricing, and cancellation terms
- Your Refund Policy covers subscription cancellations and pro-rata refunds
- Policy pages are linked from your footer, checkout, and product pages
Pre-contractual information
- Your subscription product page shows the recurring price and billing interval clearly (not just "Subscribe & Save")
- Checkout confirms the recurring charge before payment is completed
- Confirmation email includes renewal date, price, and cancellation instructions
Pre-renewal reminders
- You have a system to send reminder emails at 14 days before renewal
- You have a system to send reminder emails at 7 days before renewal
- You have a system to send reminder emails at 1 day before renewal
- Each reminder includes the renewal amount, date, and a cancellation link
- You have an annual summary notice for long-running subscriptions (>12 months)
Cancellation flow
- Customers can cancel their subscription without calling you or emailing support
- The cancellation flow requires no more than a few clicks
- After cancellation, the customer receives confirmation and knows when their access ends
Audit trail
- You can demonstrate (to the CMA, if asked) that reminders were sent and when
- You have records of subscriber opt-ins and policy versions at the time of sign-up
Get your automated readiness score — DMCCA Guard scans your Shopify store and scores each of these points in under 5 minutes.
Run free scan →Frequently Asked Questions
What is the DMCCA 2024?
The Digital Markets, Competition and Consumers Act 2024 is a UK law that modernises consumer protection and competition enforcement. Chapter 2 of Part 2 introduces new subscription contract rules covering pre-renewal reminders, easy cancellation, and transparent terms. The CMA enforces these provisions from Spring 2027.
When does DMCCA come into force for subscriptions?
Spring 2027, subject to a Government commencement order. The CMA has indicated it will be watching the market in 2026. Merchants should prepare now — updating policies, building reminder workflows, and reviewing cancellation flows takes time.
Do I need to send pre-renewal reminder emails?
Yes. DMCCA requires traders to send reminder notices before subscriptions renew. CMA guidance recommends 14, 7, and 1 day before renewal. Each reminder must state the renewal date, price, and how to cancel.
What cancellation requirements does DMCCA introduce?
Cancellation must be as easy as signing up. Consumers must not need to call a phone number or navigate complex menus. A clear in-account cancel button is the expected standard. This is sometimes called the "easy exit" requirement.
Does DMCCA apply if I use Shopify Subscriptions (native)?
Yes. DMCCA applies to your obligations as a merchant regardless of which subscription platform you use. However, Shopify Subscriptions (native) does not expose renewal dates to third-party apps via API, which complicates automated reminder flows. You will need to configure reminders via Shopify Email or a specialist tool that can work around this limitation.
What are the penalties for non-compliance?
The CMA can fine up to 10% of global annual turnover. It can also issue enforcement orders, require consumer redress schemes, and make non-compliant terms unenforceable. Non-compliant merchants may face chargebacks and disputes from subscribers who learn they had cancellation rights not made available to them.
Does my B2B subscription fall under DMCCA?
No. DMCCA Chapter 2 covers consumer subscriptions — contracts with individuals acting outside their trade or profession. Subscriptions sold to businesses (B2B) are not in scope. See our FAQ page for more detail on B2B vs B2C scope.
I use Recharge / Appstle / Loop — does DMCCA apply?
Yes. DMCCA applies based on your relationship with your customers (trader to consumer), not on the technology you use. The advantage of Recharge and most third-party subscription apps is that they expose renewal dates via API, which makes automated reminder compliance more straightforward than Shopify Subscriptions native.