By Lauren Stein
With reduction of government funding to the arts being an perennial issue, museums and other institutions rely on subscriptions for building up operating budgets. In the United Kingdom, Digital Markets, Competition and Consumers Act 2024 (DMCC) became law on May 24, 2024, introducing reforms to consumer protection and competition law.[1] Officially described as an “Act to provide for the regulation of competition in digital markets . . . to make provision relation to the protection of consumer rights and to confer further such rights; and for connected purposes,” the DMCC represents one of the most significant overhauls of UK consumer law in recent years.[2] It updates and replaces the Consumer Protection from Unfair Trading Regulations 2008 law and imposes increased transparency requirements and enhanced rights for consumers, particularly in relation to subscription contracts.[3]
On April 6, 2025, the unfair commercial practice provisions of the DMCC were enacted, strengthening the consumer enforcement regime administered by the United Kingdom Competition and Markets Authority (CMA).[4] A key area of reform lies in Part IV, Consumer Rights and Disputes, Chapter Two, which concerns subscription contracts. Specifically, chapter two imposes duties on traders in relation to subscription contracts, provides rights for consumers if those duties are breached, and provides rights for consumers to cancel subscription contracts during cooling-off periods.[5]
Under the DMCC, a subscription contract is defined as a “contract between a trader and consumer for the supply of goods, services or digital content by the business to the consumer in exchange for payment by the consumer.”[6] Notably, these contracts renew automatically for a fixed or indefinite period of time, and the consumer becomes automatically liable for each renewal.[7] Additionally, the subscription contract sets out the rate for the supply of goods, services, or digital content for a specified period, after which the consumer remains liable for continued payments.[8] Importantly, the DMCC affirms the consumer's right to terminate such a contract.[9]
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