Most UK telehealth subscriptions, GLP-1 top-ups, HRT refills, hair loss repeats, run on recurring billing, which is exactly the contract type the Digital Markets, Competition and Consumers Act 2024 was written to police. Its subscription contract rules land squarely on pre-contract disclosure, renewal reminders, and how hard it is to leave. For brands that built their checkout around retention rather than exit, that is a compliance gap worth closing before the CMA closes it for them.
What the DMCCA actually changed for subscription traders
The Digital Markets, Competition and Consumers Act 2024 (DMCCA) did two separate things that matter here. It gave the Competition and Markets Authority a direct enforcement power over consumer protection law, so it can investigate and fine a trader itself rather than going through the courts first. And it wrote a standalone subscription contracts regime into the Act, aimed specifically at contracts that renew automatically or roll over into a paid period after a trial.
The subscription provisions are among the later parts of the Act to take effect, phased in through secondary legislation and CMA guidance rather than switched on all at once. By 2026 the practical position for any UK-facing subscription business, telehealth brands included, is that the regime is live or close enough to it that building for it now is the only sensible approach. Waiting for a specific commencement date to be confirmed somewhere is not a compliance strategy.
Who the new regime actually catches
The rules are written around the billing mechanic, not the medicine. If a patient's card is charged again without them actively placing a new order, whether that is a monthly GLP-1 injection, a repeat HRT prescription, or a rolling hair loss subscription, it is a subscription contract for these purposes. A private prescription that a patient has to manually reorder each time sits outside the regime in the same way, which is one more reason the choice between a subscription and one-off pricing model is now a compliance decision as well as a commercial one.
Free or discounted trials that convert into a paid subscription are caught too, and arguably carry more risk, because the moment of conversion is exactly where patients complain loudest about being charged without warning. Any brand running an introductory price, a free consultation that unlocks paid repeats, or a first-month-free hook on a weight management or skincare subscription needs to map that conversion point specifically, not just the ongoing renewal cycle.
The pre-contract information duty
Before someone subscribes, the regime expects them to be told clearly, and before they hand over payment details, what they are agreeing to: the price, how often it will be charged, how long the initial commitment runs, and how the contract renews. Burying that in a terms-and-conditions link at the bottom of a checkout page is exactly the kind of practice the rules are designed to stop.
For a telehealth checkout this usually means restating the subscription terms on the payment screen itself, not only inside the clinical consent flow. Patients are focused on the prescribing decision at that point, not the billing mechanics, so the information has to sit where they are actually looking, in plain language, rather than folded into a block of legal text they are unlikely to read.
If your checkout charges a card again without the patient placing a fresh order, treat it as a DMCCA subscription contract now rather than waiting for a specific commencement date to be confirmed. Pre-contract disclosure, a renewal reminder, and an exit no harder than sign-up are the three things to fix first.
Reminder notices before renewal, and before a trial converts
The regime requires a reminder notice ahead of key moments: before a contract renews into a new term, and before a trial or discounted period ends and converts to the full price. The notice has to reach the patient through a channel they will actually see, typically email or SMS, and has to say plainly what is about to happen and what it will cost.
This sits alongside, rather than replaces, the payment and refund operations most telehealth brands already run. A chargeback defence pack built on prescription records, consultation transcripts, and dispatch confirmation, covered in our guide to UK telehealth payments and refunds, still matters once a dispute lands. The reminder notice is what is meant to stop the dispute arising in the first place.
The 'easy exit' duty: cancellation can't be harder than sign-up
The headline provision is the exit duty, often shorthanded as click to cancel. A patient has to be able to end the subscription using a method no more difficult than the one they used to start it. If sign-up took two taps in an app, cancellation cannot require a phone call, a retention conversation, or an email that only gets answered three days later.
In practice, an easy-exit cancellation flow for a telehealth subscription needs:
- A self-serve cancel option inside the patient's account, not just a 'contact us to cancel' instruction
- No mandatory retention call or chat gating the cancellation itself
- Immediate written confirmation that the cancellation has been actioned, and when it takes effect
- Clarity on whether any part-used period is refunded or simply not charged again
- A timestamped record of the cancellation request and confirmation, kept on both sides
An easy exit is not a retention risk. It is what separates a subscription patients chose to keep from one they simply never got around to cancelling.
Enforcement: the CMA's direct powers, and where ASA and CAP still apply
The DMCCA's biggest practical change is procedural. The CMA can now investigate a suspected breach of consumer protection law and decide the case itself, including imposing a fine, instead of having to persuade a court first. That shortens the distance between a patient complaint and a finding against a brand, and it raises the cost of treating subscription compliance as a problem to fix only once someone complains.
None of this replaces the ASA and CAP rules that already govern how a subscription price is advertised, covered in our guide to marketing compliance for UK telehealth. A landing page promoting 'from £X a month' without making the recurring nature and cancellation terms clear was already a problem under the CAP Code. It is now a problem under two regimes at once, enforced by two different bodies with overlapping interest in the same checkout page.
How PExpo supports compliant renewal and cancellation flows
PExpo's billing layer separates the subscription mechanics, renewal timing, trial conversion, cancellation state, from the clinical and dispensing workflow underneath it. That separation is what lets a white-label brand update reminder notice timing or its cancellation flow to stay current with a rule change, without re-engineering how prescriptions get clinically approved and dispensed.
For brands deciding between subscription and one-off pricing in the first place, our brands page sets out how PExpo's billing and dispensing layer supports white-label launches either way. Our pricing page shows how that support is tiered, so updating a renewal or cancellation flow does not mean renegotiating the whole commercial relationship.
The DMCCA subscription regime is not a reason to abandon recurring billing; repeat prescriptions are too operationally sound to give up over a compliance update. It is a reason to audit the checkout and account area now: pre-contract disclosure, a reminder notice before every renewal and trial conversion, and a cancel button that works as hard as the sign-up flow did. Pair that with the advertising clarity in our guide to ASA and CAP rules for pharma adverts, and most of the regime is already covered by changes most mature telehealth operators should be making anyway. Done well, an easy exit does not even hurt patient retention; it just means the patients who stay are staying for the right reasons, not because cancelling was too hard to bother with.
Frequently asked questions
Does the DMCCA subscription contracts regime apply to UK telehealth and online pharmacy brands?
Yes, if a patient is charged on a recurring basis without placing a fresh order each time, which covers most GLP-1, HRT, and hair loss subscription models. A prescription a patient has to actively reorder each time is treated differently. Legal advice specific to your checkout flow is still worth getting, since the rules turn on exactly how the billing mechanic works.
What does 'click to cancel' actually require from a telehealth checkout?
It requires a cancellation method that is no harder to use than the sign-up method was, in practice a self-serve option in the patient's account rather than a mandatory phone call or retention conversation. Confirmation of the cancellation, and clarity on any refund or final charge, should follow straight away.
Who enforces the DMCCA subscription rules, and what happens if a brand doesn't comply?
The Competition and Markets Authority enforces it. The Act gives the CMA power to investigate and decide breaches itself rather than going through the courts first, with civil fines as the sanction. That makes non-compliance a direct commercial risk, and responsibility sits with whoever owns the checkout and billing flow, not with the prescribing side of the business.
