CMA fines for subscription businesses
The draft guidance says the CMA can investigate suspected breaches of the subscription rules itself and impose financial penalties of up to £300,000 or 10% of global turnover, whichever is higher. It says court-based enforcement is also open to public enforcers, and a separate criminal offence carries a fine.
The government has announced the rules will come into force in January 2027; the exact date will be set in regulations. Parts of this guide rest on draft regulations or draft guidance, which are subject to Parliament's approval and may change.
Last checked against official sources: . This page is general information, not legal advice.
What the official sources say
The CMA can enforce directly
The draft guidance says infringements of the subscription rules can lead to action by a public enforcer under Part 3 of the DMCCA where there is harm to the collective interest of consumers. One route is direct enforcement by the CMA.
Infringements of the subscription rules by a trader can result in action being taken by a public enforcer under Part 3 of the DMCCA where there is harm to the collective interest of consumers.
Source: DBT guidance on the subscription contracts rules - full text (draft, subject to Parliament)
What direct enforcement involves
The draft guidance says the CMA can investigate suspected infringements and take enforcement action itself. The subscription rules are listed for CMA direct enforcement.
Under the direct enforcement route, the CMA may investigate suspected infringements and take enforcement action itself.
Source: DBT guidance on the subscription contracts rules - full text (draft, subject to Parliament)
The penalty figures
The draft guidance gives the ceiling for CMA financial penalties as £300,000 or 10% of global turnover, whichever is higher. It lists this among the steps the CMA may take.
Impose financial penalties where appropriate (up to £300,000 or 10% of global turnover, whichever is higher).
Source: DBT guidance on the subscription contracts rules - full text (draft, subject to Parliament)
A separate criminal offence
The draft guidance says it is a criminal offence for a trader to fail to give information about initial cooling-off rights when entering an off-premises subscription contract, such as on a consumer's doorstep. A person convicted may be liable to a fine.
When entering into an off-premises subscription contract with a consumer (for example, on a consumer’s doorstep), it is a criminal offence85 for a trader to fail to provide the consumer with information about their initial cooling-off rights as required by the DMCCA.
Source: DBT guidance on the subscription contracts rules - full text (draft, subject to Parliament)
Common questions
What is the maximum financial penalty the CMA can impose?
The draft guidance gives up to £300,000 or 10% of global turnover, whichever is higher.
Is there a criminal offence under the subscription rules?
The draft guidance describes an offence of failing to give initial cooling-off information when entering an off-premises subscription contract. A person convicted may be liable to a fine.
Check where you stand
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Related guides
General information, not legal advice. Every quotation above is copied from the official text named beneath it; follow the link to read it in full.