How to navigate subscription regulations from around the world

However, it’s not just customer satisfaction you need to worry about. Legal regulations worldwide are starting to catch up to this relatively new way of doing business. Depending on where your business operates, making it difficult (or nearly impossible) to cancel a subscription could land you on the wrong side of the law. Here’s what you need to know about subscription commerce regulations from around the world and how you can stay compliant with them.

Subscription-regulations around the wrld

It’s incredibly exciting when your business starts to reach new countries, but it also makes running your business a little more complicated. Let’s look at some countries that are starting to implement regulations about subscription commerce.

United States of America

The US is a more complex patchwork because regulation is both federal and state-level. Below are the key developments you need to know.

Federal level – Federal Trade Commission (FTC) / negative option rule
In October 2024 the FTC announced a final “click-to-cancel” rule which would require businesses to make it at least as easy for consumers to cancel a subscription as it was to sign up. The rule was due to take effect 180 days after Federal Register publication.

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However in July 2025 the U.S. Court of Appeals (8th Circuit) blocked the rule on procedural grounds (the court found the FTC did not conduct a required cost-benefit analysis). Reuters+2The Register+2
This means that while the rule as written is not currently enforceable, the FTC continues to focus on so-called “dark patterns” (design features that make cancelling difficult) and has brought enforcement actions on that basis. And enforcement isn't lax: Amazon recently agreed with the FTC to settle the suit for $2.5 billions.

So, the key take-aways for U.S. federal compliance:

• Don’t rely on the “click-to-cancel” rule being live. But do expect the FTC to continue enforcement under its general unfair and deceptive practices authority.
• Avoid dark-patterns that make cancellation difficult or obscure.
• Disclose clearly and conspicuously all material terms of subscriptions, obtain express informed consent before charging consumers, provide easy cancellation. These were the core principles of the FTC’s negative option guidance.

California – The state leading the charge
The state of California has taken a strong stance and introduced significant amendments to its Automatic Renewal Law (ARL). Key contractual and operational requirements apply now or will soon.

• The ARL already required clear and conspicuous disclosure of automatic renewal offers and affirmative consent.
• The recent amendments (under Assembly Bill 2863) become effective 1 July 2025 and expand the scope of the law:
  • Free-to-pay conversion offers (free trial converting to paid subscription) are now explicitly covered.
  • Businesses must obtain express affirmative consent to renewal or continuous service terms and maintain records of consent for at least three years or one year post-termination.
  • Cancellation must be through the same medium as the enrolment (e.g. online enrolment means online cancellation). If online, cancellation must be “at will” and cannot have steps that obstruct or delay termination.
  • Annual reminder: for automatic renewals or continuous service offers, a business must send an annual reminder stating the product/service, frequency and amount of charges and how to cancel.
  • Notice of fee changes: if there is a fee increase it must be notified at least 7 days and no more than 30 days before the change takes effect, with cancellation instructions.

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United Kingdom

In the UK, subscription-commerce regulations focus on clarity, transparency and the ability to exit contracts easily. The Digital Markets, Competition and Consumers Act 2024 (DMCCA) gives a legislative basis to a new subscription-contracts regime.

Key upcoming changes:

• Pre-contract information: businesses must provide clear, prominent details about renewal, contract term, cancellation methods and when a free trial or introductory offer ends.
• Reminder notices: businesses will have to send reminders to consumers before a contract auto-renews, or when a free trial converts into a paid subscription.
• Easy exit: The consumer must be able to exit a subscription contract in a straightforward, cost-effective and timely way – if the contract was entered online then cancellation must also be available online.
• Additional cooling-off rights: The new rules extend the existing 14-day cooling-off period so that for renewals (such as annual contracts) there is a further 14-day right to cancel from the renewal date.
• Enforcement: The Competition and Markets Authority (CMA) has enhanced direct enforcement powers under the Act.

Implementation timing:
The regime was expected in Spring 2026, but has recently been delayed. Businesses should act now because the lead-time is short and the requirements may apply to any UK-consumer contract with auto-renewal or free trial conversion to paid.

What to do now:

• Identify all subscription contracts offered to UK consumers (goods, services or digital content) that auto-renew or convert from a free or low cost trial.
• Review your sign-up flows, renewal communications and cancellation processes to ensure reminders, clear information and easy exit.
• Update your terms and conditions, website copy and consumer communications to include clear renewal and cancellation info.

Germany / European Union (brief)

In Germany, as part of the wider EU consumer-protection rules, businesses already need to make cancelling contracts easy. For example, the German „Fair Consumer Contracts Act“ requires that online subscriptions must include a cancellation button accessible without login. (As a useful reference point, although not specific here, ban-on difficult exit flows.)

Limio helps keep you compliant

With so many regulations to keep an eye on, it can be challenging to launch a subscription service. Partnering with Limio can help make the process much easier. We have the expertise you need to launch purchasing, renewals and smart cancelling experiences that complies with all regulations. This means you can focus on what really matters.

Contact us today to get started on your subscription commerce journey.

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