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DBT consultation on the implementation of the new subscription contracts regime.
On 20 November 2024, the Department for Business and Trade published a consultation on the implementation of the new subscription contracts regime. The Digital Markets, Competition and Consumers Act (DMCCA) sets out a legislative regulatory framework to strengthen protections for consumers when they enter a subscription contract. This consultation is seeking views to inform the implementation of the regime.
The consultation includes:
- Overview of the Digital Markets, Competition and Consumers Act and consultation proposals
- Cooling-off cancellation rights - returns and refunds
- Cancellation remedies for breach of duties
- Repayment of refunds
- Contractual terms for exiting a contract
- Arrangements for exiting a contract
- Information notices
- Pre-contract information
More information and the consultation can be accessed here. It will be open for 12 weeks and close on 10 February 2025.
Cosmetic retailers offering subscription-based services, such as monthly beauty boxes or refill programs for skincare products, would potentially be affected by this legislation. Key proposals include providing clear and prominent information about subscriptions, obtaining explicit consumer agreement for auto-renewals, and sending reminders before contract renewals.
CTPA do not intend to respond to the consultation, but we encourage companies that believe they might be in scope to participate.
