Reminder Notices: What, When and How They Need to Be Delivered

Aug 25

3 min read

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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There are three notices that matter under the new regime, at three different points in a subscription's life. The reminder notice, sent before a trial ends or a long contract auto-renews. The cooling-off notice, telling a customer about their cancellation rights. And the end-of-contract notice, confirming a cancellation has actually gone through. The government's April 2026 response added real detail to how all three have to work, which makes this one of the more concrete parts of the regime right now.

They have to be on a durable medium

All three notices have to be given in writing, on what the Act calls a durable medium. That means something a customer can keep and refer back to: a letter, an email, an SMS or a WhatsApp message. An in-app banner that vanishes after a few seconds isn't good enough, because there's nothing left for the customer to check back against later.

Their purpose has to be obvious

Each notice has to make its purpose "immediately apparent" to the customer. A reminder notice that reads like a generic marketing email, with the actual renewal warning buried three paragraphs down, doesn't meet that bar even if the information is technically present somewhere in the text.

The prominence rule, and what didn't make it in

This is worth reading carefully, because it changed shape during consultation. The government originally proposed that the required information in reminder notices and end-of-contract notices should be the first thing a customer sees. After hearing from stakeholders, that specific proposal was dropped. What replaced it: the prescribed information simply has to be more prominent than anything else shown in the same notice.

In practice, that's a meaningfully different bar. It doesn't have to lead the message, but it does have to stand out more than anything else competing for attention in it, a retention offer, a feedback prompt, a product announcement squeezed into the same email. If the renewal warning is one small line beneath a bigger, bolder pitch for something else, that's the kind of pattern this rule is aimed at.

Cooling-off notices carry extra detail

On top of the general durable medium and prominence requirements, a cooling-off notice specifically has to include the cost to the customer of returning goods, where a renewal cooling-off right applies and returnable goods are involved. If your product includes a physical component, this is a detail your notice template needs to account for, not just the fact that a cooling-off right exists.

What's still open

The exact timing, how many days before a trial ends or a contract renews a reminder notice has to go out, and how many reminders are required, hasn't been finalised in public detail yet. That level of specificity is expected through secondary legislation and guidance rather than being settled already. Build your notice templates and content around what's confirmed here, but treat the exact scheduling as provisional until that detail lands.

What to check now

Check your current renewal and cancellation emails against the durable medium test. If any of them are only delivered as in-app notifications with no email or SMS equivalent, that's a gap.
Look at where the key information actually sits in your templates. If a reminder is visually dominated by anything else, a retention offer, a cross-sell, a design flourish, that's worth revisiting even before the exact rules are finalised.
If you supply physical goods, check your cooling-off notice template includes real return-cost information, not just a general statement that a cooling-off right exists.

Want your current notice templates checked against these requirements? [Book a DMCCA readiness review] and we'll go through them 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