Bird & Bird, a PIF Associate Member, has highlighted critical updates to the Digital Markets, Competition and Consumers Act 2024 (DMCC Act) that will impact how pet businesses manage subscriptions. With enforcement expected by April 2026, companies offering recurring services or products must prepare for stricter regulations regarding auto-renewals and consumer cancellation rights.
The DMCC Act introduces significant consequences for non-compliance, granting the Competition and Markets Authority (CMA) powers to issue direct fines. These penalties can reach up to 10 per cent of a business’s annual global turnover. This shift moves the UK toward a more rigorous legislative framework, in some cases exceeding current European Union consumer protection standards.
Under the new regime, pet businesses must provide “Key Pre-contract Information” clearly at the point of sale. This information, which includes payment frequency, minimum total liability, and a summary of cancellation rights, cannot be hidden behind hyperlinks. This ensures that consumers are fully aware of their ongoing financial obligations before entering into a commitment.
The legislation also mandates a specific schedule for reminder notices. Businesses will be required to notify consumers before a subscription renews or a payment becomes due. For annual subscriptions, reminders must be issued every six months. Furthermore, “cooling-off” rights will allow consumers a 14-day window to cancel after a trial period ends or a new yearly term begins.
A core aim of the Act is to eliminate “subscription traps” by ensuring that ending a contract is as straightforward as starting one. If a subscription is sold online, the business must provide an online cancellation mechanism that involves no unreasonable steps. Following a cancellation, written confirmation must be sent within 24 hours for online requests or three working days for other methods.
As the UK government finalises secondary legislation to operationalise these rules, pet businesses are encouraged to review their existing terms and conditions. Mapping out a new notification schedule and establishing a simple, transparent cancellation journey will be essential steps for maintaining compliance and avoiding the risk of substantial CMA intervention.
If your business is affected by these upcoming changes to subscription law, Pet Industry Federation members can access a free 30-minute consultation call with the industry experts at Bird & Bird to discuss their compliance strategy. To book your session, please contact the Bird & Bird team at pets.team@twobirds.com.
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Dan Everett