The subscription rules are changing.
From Spring 2027, new rules under the Digital Markets, Competition and Consumers Act (DMCCA) will change how UK organisations sell, renew and cancel subscription contracts.
Regulation continues to shape the way leisure operators engage with their members. As your technology partner, we monitor legislative developments that may affect the sector and explain what they mean in practical terms for our customers.
If you sell memberships, recurring class passes or any other auto renewing payment arrangement, these changes are likely to affect you.
For leisure operators, that means reviewing everything from online joining journeys to renewal reminders and cancellation processes to ensure they meet the new legal standards, backed by direct enforcement powers for the Competition and Markets Authority (CMA).
Why this matters for leisure
Gym and leisure centre memberships have been a focus of consumer complaint for years. The CMA and its predecessor (the OFT) have previously taken action against operators over unfair contract terms, difficult cancellation processes, and misleading practices.
The DMCCA formalises what regulators have been pushing for informally: clear terms, fair treatment, and straightforward exits.
This is not about punishing operators. It is about raising the standard across the board so that members trust the process, and operators who already do the right thing are not undercut by those who don't.
What the new legislation requires
Based on the government's consultation response (published April 2026), the confirmed requirements include:
Pre-contract information Before a consumer commits to a subscription, traders must provide clear information about what they are signing up for, including the cost, billing frequency, renewal terms, and how to cancel.
Reminder notices Operators must send information notices at key points in the subscription lifecycle:
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Before a free trial converts to a paid subscription
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Before an auto-renewal, particularly for contracts of 12 months or longer
- At the end of a contract period
Easy exit Consumers must be able to cancel their subscription in a straightforward way, without unnecessary hurdles. If a member signs up online, they must be able to cancel online. Operators may present retention offers or request feedback, but cannot force the consumer to engage with these in order to complete their exit.
Cooling-off periods Consumers have a 14-day cooling-off period after signing up, and a further 14-day cooling-off period on renewal. If a consumer cancels during the renewal cooling-off period, the operator may retain a proportionate amount of the payment rather than issuing a full refund.
Refunds Where a refund is due, it must be processed without undue delay and within 14 days, to the same payment method used by the consumer.
What this means in practice
For a typical leisure operator managing memberships through Gladstone, the key areas affected are:
Joining and sign-up flows Your online joining journey will need to present the required pre-contract information clearly before the member commits. This is not just terms and conditions buried in a link. It must be accessible and prominent.
Renewal communications Your system will need to send reminder notices ahead of renewal dates, with specific prescribed content. This means your communications tooling needs to trigger based on contract dates and membership type, not just manual campaigns.
Cancellation processes If members join through your app or website, they need to be able to cancel through the same channel. Phone-only or in-person-only cancellation routes will not meet the "easy exit" requirement for members who signed up digitally.
Payment and refund handling Your payment processes will need to support proportionate refund calculations during cooling-off periods, processed within the 14-day window.
What you should do now
The regime does not take effect until Spring 2027, and some operational detail is still subject to secondary legislation and CMA guidance. But waiting until the rules land to assess your readiness is a risk.
Audit your current joining journey. Is the pre-contract information clear, prominent, and accurate? Could a member reasonably understand their commitment before signing up?
Review your cancellation process. Can members who joined online cancel online? Are there any steps in the process that could be described as "unnecessary hurdles"?
Check your renewal communications. Are you sending reminders before auto-renewal? Do those messages contain enough information for the member to make an informed choice?
Review whether your technology platform supports automated renewal reminders, digital self service, configurable communications and compliant cancellation journeys.
How Gladstone is preparing
Helping customers adapt to regulatory change is part of how we develop our platform. Our teams are monitoring the legislation, assessing product impacts and reviewing customer journeys against the emerging requirements. As and when the secondary legislation is confirmed and CMA guidance is published, we will update our products to support operators in meeting their obligations.
Our platform already supports:
- Configurable communications triggered by membership events
- Online self-service for members, including account management
- Flexible payment handling and refund workflows
- Automated renewal and expiry notifications
As further guidance is published, we'll continue to evolve the platform and keep customers informed through our normal product update channels.
Helping customers navigate regulatory change is part of how we develop and evolve the Gladstone platform. To learn more about our approach to security, compliance and regulatory readiness, visit our Security and Compliance page.
Further Reading
This article reflects the legislation and government guidance available at the time of publication. As secondary legislation and CMA guidance continue to develop, implementation details may change.
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