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BVRLA members offering consumer vehicle subscriptions or automatically renewing services are being encouraged to review their contracts ahead of new consumer protection requirements expected to take effect on 1 January 2027.
The draft Consumer Subscription Contracts (Cancellation and Information) Regulations 2026 have been laid before Parliament, alongside supporting guidance. Subject to Parliamentary approval, the legislation will introduce new requirements for businesses offering qualifying consumer subscription contracts.
Firms with contracts falling within scope will need to:
- Provide clear information before customers enter into contracts, including payment, renewal and cancellation terms.
- Issue reminder notices at specified points, including before introductory offers end and certain renewal payments.
- Make it straightforward for customers to cancel subscriptions, including online cancellation where customers originally signed up online.
- Comply with applicable cooling-off rights and refund requirements, both when contracts begin and following certain renewals.
The requirements will not automatically apply to all rental, leasing or finance agreements, with certain contracts, including financial services, excluded. Members should therefore assess their individual products and contractual arrangements to establish whether the new rules apply.
Where products are within scope, businesses may need to update customer information, renewal communications, cancellation procedures and refund arrangements ahead of implementation.
Members can review the draft regulations, draft guidance and explanatory memorandum for further information.
Members with questions or practical concerns can contact James Vickery at [email protected].
