The Department for Business and Trade (DBT) has confirmed that the new subscription contracts regime under the Digital Markets, Competition and Consumers Act 2024 will come into force in January 2027, bringing implementation forward from the previously expected Spring 2027 timetable.
The underlying requirements have not changed. The new regime will introduce rules covering areas such as pre-contract information, reminders, cancellation and ending subscription contracts. Further detail is available in the Government’s response to the consultation published earlier this year.
For vehicle rental businesses, the position is less straightforward. Rental subscriptions do not fit neatly into the categories considered through the consultation, which focused primarily on subscriptions for services, goods and digital content. Members offering subscription-style products should therefore be aware of the new January start date and consider whether their arrangements could fall within scope.
The BVRLA will continue to engage with DBT as implementation guidance is developed and will share further information with members as soon as it becomes available.
Digital Markets, Competition and Consumers Act 2024
Also see the BVRLA’s ‘Digital Markets, Competition and Consumers Act 2024 – Unfair Commercial Practices’ factsheet.