The UK's new subscription rules start January 2027 – what it means for Shopify merchants using Recharge

The government brought the date forward in August 2026, from spring 2027 to January, timed so the rules are in place before people start new subscriptions for the year – which leaves less time than most subscription businesses were planning for.

For Shopify merchants running subscriptions through Recharge, some of the groundwork is already in place – the rest still needs building before the deadline.

What's changing

The DMCCA introduces four obligations for any business selling rolling or auto-renewing subscriptions to UK consumers:

Pre-contract information. Before someone subscribes, key information – price, renewal terms, cancellation rights – has to be shown prominently at the point they're entering the contract rather than buried in a linked terms page, alongside a fuller set of information covering company details and cooling-off rights.

Reminder notices. Customers have to be notified before a free trial converts to paid, and before a subscription renews, with longer subscriptions requiring repeat reminders at set intervals – every six months on an annual plan, for example. Each one has to stand alone rather than being folded into a marketing email, and needs to be more prominent than anything else sent alongside it.

Two cooling-off periods. The existing 14-day cooling-off period after signup stays, and a new one is added: 14 days after a trial converts to paid, or after a 12-month-plus contract renews, during which a customer who cancels is owed a proportionate refund.

Easy exit. Cancelling has to be as straightforward as signing up, so if someone subscribed online, they must be able to cancel online without extra steps in the way.

The consequences of missing any of these aren't trivial, since the requirements are implied terms in the contract: breach one and the customer can cancel and claim damages, and failing to explain cooling-off rights extends the cooling-off window to 14 days after the breach is fixed, for up to 12 months. Separately, the CMA can fine up to 10% of global turnover or £300,000, whichever is greater, using enforcement powers it has already started using elsewhere in the DMCCA.

What Recharge already handles

Thankfully Recharge's features cover the mechanics of most of this, though nothing built specifically for DMCCA compliance appears to have been released, as far as we can tell.

• Customer portal. Subscribers can already pause, skip, swap, or cancel without contacting support, which is the foundation for "easy exit" – though it doesn't automatically satisfy the rule. Where a portal routes people through a retention flow or several confirmation screens before the cancel button actually works, that's the kind of obstacle the new rules are aimed at.
• Notification triggers. Recharge can already fire emails on upcoming charges, card declines and subscription renewals, which is the plumbing a compliant reminder notice runs on – though the content, timing and prominence the law specifies aren't pre-built, and would need configuring directly, or through Klaviyo.
• Native Shopify contracts. Because Recharge sits on Shopify's Subscriptions API, contracts and cancellations flow through the existing Shopify admin and fulfilment setup, which helps with recordkeeping.

What's still left to do

• Write the pre-contract disclosure. This is checkout and product details page copy – price, renewal terms, cancellation rights – shown prominently before purchase. Recharge doesn't generate this, so it's a content task for the subscription product pages.
• Build the renewal cooling-off logic. The second 14-day window, and the proportionate refund that goes with it, is a new right. We haven't seen a Shopify subscription app that's automates the process or calculations yet, so this will potentially involve manual processing in the short term.
• Audit the cancellation journey. Walking through it as a customer usually surfaces anything that delays or complicates hitting "cancel" – win-back offers, multi-step confirmations – and those need re-sequencing so they don't count as an unreasonable step.
• Update the terms and consent records. Reference the new cooling-off rights and keep evidence of what customers agreed to and when.

Timing

Secondary legislation and detailed guidance haven't been published yet, so several of the specifics above – exact reminder intervals, what "straightforward" cancellation means in practice – are still being finalised. This is worth treating as directional, with a check for updated guidance before building anything permanent, particularly around the cooling-off refund logic.

Given the accelerated date, the sensible order is auditing the checkout and cancellation flow now, treating the pre-contract information work as a content task to solve early, and holding the cooling-off period build until Recharge – or the guidance – gives something firmer to build against.

If it would help to have someone go through your own checkout, renewal notices and cancellation flow against these requirements, that's the kind of audit we run for Shopify merchants on Recharge – get in touch and we can talk through where things stand.