Originally expected in Autumn 2026, the new regime has been delayed to Spring 2027, but that is not an invitation to put preparation on the back burner. The new rules introduce significant changes across four core areas: pre-contract information obligations, mandatory reminder notices, straightforward cancellation processes (including online cancellation where contracts are entered into online), and extended cooling-off rights on renewal, including a right to cancel and receive a proportionate refund for digital content subscriptions after a free trial or 12-month auto-renewal.
Jen and Alex also cover the government's consultation response, which confirmed the position on digital content refund rights, a finding that many businesses had lobbied against amid concerns about "binge and cancel" behaviour. The government has confirmed it will issue practical guidance on presenting pre-contract information, although no date has been set.
With no transition period and the CMA empowered to enforce the new regime with fines of up to 10% of annual global turnover, the message is clear: don't delay, start now.