Pre-Contract Information: What You Have to Tell Customers Before They Subscribe

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.

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Of the four pillars of the new regime, this is the one already most fully specified. Unlike reminder notices or cooling-off notices, most of the pre-contract information requirements sit directly in the DMCCA itself rather than waiting on secondary legislation, so this is closer to settled than some of the other pieces in this hub.

What has to be disclosed, and when

Before a customer commits to a subscription, they need to be given clear information covering the essentials: what they're paying, how long the commitment runs, how the contract renews, and how to cancel it. The underlying principle is straightforward, this information needs to be genuinely available before the point of purchase, not buried in a terms and conditions document a customer would only find after signing up.

This sits on top of, rather than replacing, general information requirements that already apply under wider consumer law and, where relevant, the Consumer Contracts Regulations (CCRs). If you already comply with CCR-level disclosure, you have a solid base to work from rather than starting fresh.

Where the government made a call

During consultation, the government asked whether there were specific operational problems with the pre-contract information requirements as drafted. Businesses generally preferred fewer additional rules layered on top of what's already in the Act, and the government didn't hear a strong case for adding much beyond what's already specified. Some points raised will be reflected in guidance rather than in the legislation itself, but the core obligation isn't expected to change materially from what's already set out in the Act.

That's a different pattern to reminder notices, cooling-off notices and end-of-contract notices, where the April 2026 response introduced genuinely new requirements (the durable medium requirement, the "purpose immediately apparent" standard, and specific prominence rules). Those are covered in the reminder notices article in this hub. Pre-contract information is comparatively stable ground.

What's still open

Guidance is expected to add some operational clarity around pre-contract information, but this is fill-in-the-gaps detail rather than a new set of obligations. The bigger unknown for most businesses isn't what has to be disclosed, it's making sure their existing sign-up flow actually surfaces it clearly, rather than assuming a line in the footer terms counts.

What to check now

• Audit your actual sign-up flow, not just your terms document. Price, duration, renewal terms and cancellation method should be visible and legible before a customer commits, not just present somewhere in the small print.

• Check how "how to cancel" is actually communicated. A generic link to a support page usually isn't specific enough. Customers should come away from the sign-up flow with a real sense of what cancelling will involve.

• Don't treat this as done because you're CCR-compliant. It's a solid base, but confirm the DMCCA's own requirements are separately covered, not assumed.

Want a second pair of eyes on whether your sign-up flow actually surfaces this clearly? Book a DMCCA readiness review and we'll walk 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