A lot of SaaS teams still treat subscription compliance as future-admin.
That is understandable, but not especially wise.
The UK’s incoming subscription contracts regime under the Digital Markets, Competition and Consumers Act 2024 is expected to land in spring 2027, with the government already setting out how the new rules are meant to work in practice. The Competition and Markets Authority has also spent the last year showing that consumer enforcement is no longer theoretical background noise. It is active, funded and increasingly specific about what businesses should fix.
For self-serve software companies, that matters because the relevant problems are not hidden in legal small print. They live in product decisions: pricing pages, free trials, annual renewals, cancellation paths, reminder emails and the general temptation to make leaving harder than joining.
In other words, this is product work.
Why this matters before the law fully arrives
The obvious response is to say, “Fine, but spring 2027 is not tomorrow.”
True. But that is exactly why it is worth dealing with now.
The awkward version of compliance is the one that starts late, when teams realise their billing logic, email triggers, contract wording and account settings all need changing at once. The calmer version starts earlier, while there is still time to fix the experience properly instead of stapling warning text onto a messy flow.
The government’s consultation response is fairly clear about the direction of travel. Consumers should get clear information before signing up, proper reminders before they drift into unwanted payments, straightforward exit routes, and cooling-off rights in more situations than many subscription businesses would prefer.
That is not just a legal theme. It is a design brief.
The practical shift for product-led SaaS
If you run a self-serve SaaS product, there are a few habits worth questioning now.
1. Pricing needs to be genuinely clear
The CMA has been loud about price transparency and unlawful drip pricing. That matters beyond retail checkouts.
For SaaS, the equivalent problems often look like this:
- headline monthly prices that quietly become annual commitments later
- trial messaging that understates when billing begins
- tax, onboarding or mandatory add-ons appearing late in the flow
- plan comparison tables that make the real renewal terms harder to spot than they should be
If a customer cannot tell, without effort, what they will pay, when they will pay it, and what happens next, that is a risk.
It is also usually a trust problem before it becomes an enforcement problem.
2. Trial-to-paid journeys need more discipline
The government’s response highlighted how many unwanted subscriptions begin by rolling over from free or discounted trials.
That should make product teams slightly uncomfortable, because trial design is often treated as a conversion game first and a clarity problem second.
A sensible flow should answer a few basic questions cleanly:
- when does the trial end
- what amount will be charged
- what plan will it convert into
- how does the user cancel before billing starts
- what reminder messages will they receive before that happens
If those answers are technically present but tucked away in awkward UI, overlong copy or low-contrast footnotes, do not kid yourself that the experience is fine.
It probably is not.
3. Cancellation has to stop being treated like a retention hack
This is the bit many teams will dislike most.
The direction of policy is obvious: if someone signed up online, they should be able to leave online, and the exit route should be straightforward.
That is a direct collision with the old playbook of hiding cancellation behind support tickets, multi-step settings hunts, friction-heavy surveys or defensive “book a demo before you leave” gates.
Good retention comes from product value, not from making the fire exit harder to find.
4. Annual renewals and reminders need operational plumbing
One of the easiest mistakes here is to think the work is mostly front-end copy.
It is not.
A lot of the hard part sits underneath the interface:
- billing systems need the right renewal states
- reminder emails need to trigger at the right time
- account data needs to know whether a contract falls into the relevant renewal rules
- support teams need a clear refund and cancellation position
- audit trails need to show what the user saw and when
This is where product, engineering, ops and customer support need to behave like they are on the same company, which sounds basic but is not always observed in the wild.
The useful way to think about cooling-off rights
The government has set out two 14-day cooling-off periods in the new regime: an initial one when the contract is entered into, and a renewal cooling-off period after a trial or a 12-month-plus contract auto-renews.
That matters because many teams still think of renewal as a back-office event. From the customer’s point of view, it is not. It is another point where money leaves their account and where trust is either reinforced or quietly damaged.
Even where the legal detail ends up varying by contract type, the product lesson is simple enough: renewal cannot remain an invisible system event that customers are expected to keep track of by memory.
If your subscription model depends on users forgetting, it is probably not a very sturdy model.
What a sensible SaaS response looks like now
You do not need to stop shipping features and launch a grand subscription-law taskforce.
You do need to review the journeys that matter.
A useful short list would be:
Audit the complete self-serve path
Go through discovery, pricing, trial signup, checkout, confirmation emails, renewal reminders, billing history and cancellation.
Not the ideal flow in Figma. The real one.
Check where meaning is carried by implication
A worrying amount of SaaS UX relies on people inferring the important bits.
If the billing date, renewal basis, cancellation route or refund position is implied rather than stated plainly, fix that.
Remove decorative friction from cancellation
If a user has to click through several screens, justify themselves, or switch channels just to stop paying, you are creating future pain for yourself.
Align commercial copy with system behaviour
The nicest pricing page in the world is useless if the reminder emails, Stripe logic, terms copy and support responses all say slightly different things.
Keep evidence of what you changed
As the CMA’s direct enforcement regime matures, being able to show that you reviewed flows and tightened them deliberately is better than vague claims about caring deeply about transparency.
Why this is distinct from our recent compliance posts
This is not another broad security or accessibility piece in different clothes.
The interesting part here is the overlap between consumer law and product mechanics.
Security guidance tends to focus on how software is built and run. Accessibility guidance focuses on whether people can actually use it. Subscription rules force teams to look at whether the commercial experience itself is fair, legible and operationally honest.
That makes this a useful topic for product-led businesses, especially those relying on self-serve growth.
What we think is worth doing next
At BPS Designs, we think the smart move is to treat the incoming subscription regime as a prompt to clean up the product now, not as a last-minute legal nuisance for later.
If your SaaS has free trials, annual plans, automatic renewals or self-serve cancellation, this is a good time to inspect what the customer actually experiences from first click to final exit.
The teams that do that work early will not just be in a better position for spring 2027. They will usually end up with clearer pricing, fewer avoidable complaints, better support conversations and more credible customer trust in the meantime.
Which, conveniently enough, is what a decent software business should want anyway.