Cooling-Off Periods & Refunds: How Much Customers Actually Get Back

FILDI Ltd is not a law firm. The DMCCA Subscription Hub reflects our understanding of publicly available government sources as of the date shown on each page, and parts of the underlying regulation are still being finalised.

Nothing in this section is a substitute for advice from a qualified legal professional about your specific circumstances.

___

This is the part of the regime with the most concrete, numbers-based detail so far, and it's worth understanding properly because the refund calculation genuinely differs depending on what you sell.

The two windows

There are two separate 14-day cooling-off periods. The initial one starts when a customer first enters a contract, and largely mirrors the existing right under the Consumer Contracts Regulations (CCRs). The renewal one is new: it opens after a free trial ends or after a contract of 12 months or more auto-renews, giving the customer another 14 days to cancel and get money back, even if they missed the moment the renewal actually happened.

Refunds for goods

For standard returnable goods, a customer who cancels and returns the item gets a full refund, including standard delivery costs. Where goods are sealed for health or hygiene reasons and get unsealed after delivery, or become inseparably mixed with other items, the trader can deduct the value of those specific items from the refund, since they genuinely can't be resold.

Perishable and bespoke goods work differently again. If the customer cancels before the goods are actually supplied, they get a full refund. If they cancel after supply, the trader can deduct the cost of those goods, including delivery, from the refund. The government originally proposed a "dispatch date" as the cut-off point, but dropped that concept after businesses pointed out it doesn't map cleanly onto how dispatch actually works operationally. The final approach uses "supply" instead, an existing concept in consumer law, which is a more forgiving standard to build processes around.

Refunds for services

If a service hasn't started yet when the customer cancels, they get a full refund. If it has started, or is ongoing (during a renewal cooling-off period, for instance), the refund is proportionate: calculated against the total contract price, based on how much of the service has actually been supplied.

This was genuinely contested during consultation. Businesses argued that a customer could use a service heavily for a few days, then cancel for close to a full refund, and pushed for stricter alternatives. The government considered this but kept the proportionate approach, mainly to stay consistent with how the CCRs already work for non-renewing contracts. If you already calculate proportionate refunds for standard cooling-off cancellations, this is the same underlying logic applied to renewal cancellations too.

Refunds for digital content

Digital content follows a slightly different path. The existing initial cooling-off waiver is kept: if a customer actively agrees to start supply immediately, they knowingly give up their initial 14-day cooling-off right, exactly as under the CCRs today. But the new renewal cooling-off right doesn't carry the same waiver. If a customer cancels during a renewal cooling-off period, they get a proportionate refund, calculated the same way as for services.

The government considered three options here, ranging from full proportionate refunds at both stages through to requiring fresh active consent at every renewal. It landed on this middle option specifically because it keeps the existing, familiar waiver for sign-up, while still giving customers a genuine remedy if they forget to cancel a renewal they didn't want.

The cost of getting notices wrong

If a trader fails to properly inform a customer about their cooling-off rights, the cooling-off period doesn't just stay at 14 days, it extends until 14 days after the trader actually corrects the failure, up to a maximum of 12 months. During that extended window, the customer can cancel without paying for goods, services or digital content already supplied. This is a direct, mechanical consequence of getting your notices wrong, not a discretionary penalty, which makes the reminder notices article in this hub directly relevant to your refund exposure here.

Refund timing

Once a refund is due, it has to be paid without undue delay and within 14 days, using the same payment method the customer originally used, unless they agree otherwise. This mirrors existing CCR timing, so it shouldn't require new infrastructure if your current refund process already meets that bar.

What to check now

• Map each product line against goods, services and digital content separately. The refund maths genuinely differs between them, and a mixed product may need its own logic once guidance on mixed contracts lands.

• Check whether your systems can calculate a proportionate refund, not just process a full refund or none at all. This is the calculation most businesses don't currently have built.

• Confirm your refund process actually hits the 14-day, same-method requirement end to end, not just in the policy document but in what the system does.

Want us to map your actual refund logic against these rules, product by product? [Book a DMCCA readiness review] and we'll work through it with you.

This article is general information, not legal advice, and reflects our understanding of publicly available sources as of the date below. Always verify against primary government sources before making a compliance decision.

Last reviewed: 24 August 2026