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How the UK Subscription Rules Affect WooCommerce Stores

Futuristic WooCommerce Pay by Bank checkout showing a customer-approved bank payment journey
If you sell subscriptions through WooCommerce, the UK’s new subscription-contract regime will affect how you present subscription terms, communicate with customers and handle cancellation. The Digital Markets, Competition and Consumers Act 2024 establishes the framework, while further legislation and guidance are needed to put the regime fully into operation.

Current status: The new subscription-contract regime is not yet operative. The Government has announced a planned timetable for implementation, while secondary legislation and guidance are still required.

Key Takeaways

  • The UK has enacted a new subscription-contract framework, but the new regime is not yet operative.
  • WooCommerce merchants should review subscription information, pricing, trial terms and customer communications before the regime takes effect.
  • Qualifying subscriptions will have requirements around reminders, straightforward cancellation and online exit where applicable.
  • Cooling-off and refund rights depend on the circumstances; they do not create a new 14-day cancellation period after every monthly renewal.
  • Using cards, Pay by Bank or another payment method does not by itself determine whether a merchant’s contract falls within the subscription regime.
  • WalliD can support customer-approved Pay by Bank renewals, but using Pay by Bank does not by itself make a WooCommerce subscription journey legally compliant.
This article is about how the UK’s new subscription-contract regime may affect WooCommerce stores, including requirements for subscription terms, customer reminders, cancellation, online exit routes, cooling-off rights and refunds. It also explains how Pay by Bank fits into subscription renewal journeys and why using a particular payment method does not remove a merchant’s wider consumer-law responsibilities.

What Do WooCommerce Merchants Need to Prepare For?

The new regime introduces requirements covering the customer journey before and during a qualifying subscription.
Area What to review
Before signup Subscription terms, pricing and relevant trial or introductory-price information.
Reminders Required customer notices at the relevant stages of the subscription.
Cancellation A straightforward process for customers to end a qualifying subscription.
Online exit An online cancellation route where the subscription was entered into online.
Cooling-off Relevant initial and renewal cooling-off rights, depending on the circumstances.
Refunds How refunds are handled when applicable cancellation rights are exercised.

Before the customer subscribes

Make key subscription terms clear before the customer enters the contract, including the nature of the subscription, price and relevant trial or introductory-price conditions.

During the subscription

Review how your store handles required reminders and other customer communications. These requirements apply at specified stages and circumstances rather than before every individual payment.

Cancellation and online exit

Customers must have a straightforward way to end a qualifying subscription. Where the subscription was entered into online, the framework provides for an online route to end it.

What Should You Check in Your WooCommerce Store?

Before the new regime takes effect, review:
  • subscription terms shown before checkout;
  • pricing and trial disclosures;
  • required reminder communications;
  • the cancellation journey;
  • online cancellation where required;
  • cooling-off handling;
  • refund processes.
Your subscription terms, customer communications, cancellation process and payment workflow should work together.
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Does the Payment Method Change the Subscription Rules?

Not by itself.
Whether you accept cards, Pay by Bank or another payment method does not determine whether the underlying contract is a subscription contract. The relevant question is how the contract is structured and whether it falls within the applicable rules.
Changing the payment method therefore does not remove the merchant’s responsibility to review the wider subscription journey.

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What Is Still Being Finalised?

The Act establishes the framework, but important operational details require secondary legislation and guidance.
Merchants should therefore distinguish between requirements already established by legislation and details that remain dependent on the implementing framework.
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Where Does Pay by Bank Fit?

Pay by Bank can form part of a customer-approved subscription renewal journey.
With WalliD, the customer can review the renewal and authorise the payment through their bank. Each new WalliD renewal payment requires fresh customer authorisation. It should not be presented as an automatic recurring bank debit.
Using Pay by Bank does not by itself make a subscription journey compliant with UK consumer law. Merchants remain responsible for reviewing and implementing the requirements that apply to their subscription contracts.

Add Pay by Bank to Your WooCommerce Store

WalliD adds Pay by Bank to WooCommerce, allowing customers to review and authorise payments through their bank.

Talk to Our Payments Team

See how Pay by Bank can fit into your WooCommerce payment journey.

Frequently Asked Questions

What are the new UK subscription rules?

The new subscription-contract regime introduces requirements for qualifying subscriptions, including pre-contract information, reminder notices, straightforward cancellation, online exit arrangements and specific cooling-off rights. The framework is established in the Digital Markets, Competition and Consumers Act 2024, while some implementation details depend on further regulations and guidance.

Do the subscription rules apply to WooCommerce stores?

They can. The regime applies according to the nature of the underlying consumer contract, not because a merchant uses WooCommerce. A WooCommerce store offering a qualifying subscription should therefore review its subscription terms, customer communications, cancellation process and other parts of the customer journey.

What information should a WooCommerce store provide before signup?

Merchants should make key subscription terms clear before the customer enters the contract, including relevant pricing, ongoing payment obligations and trial or introductory-price conditions. The enacted framework requires key and full pre-contract information for qualifying subscription contracts, with the information provided clearly and in an accessible form.

Do merchants have to remind customers before every renewal?

No. Reminder requirements apply at specified points and to relevant renewal payments rather than automatically before every individual payment. Merchants should therefore review which reminder notices apply to their subscription model and ensure the required information and timing are supported by their customer-communication process.

Does an online subscription need an online cancellation route?

Yes, where the qualifying subscription was entered into online, the framework provides for the consumer to be able to exercise their right to cancel online. The cancellation mechanism must also be easy to find and access rather than being hidden behind unnecessary steps.

Do customers get a 14-day cooling-off period after every monthly renewal?

No. The framework distinguishes between an initial cooling-off period and a renewal cooling-off period that applies in defined circumstances, including certain trial-to-paid transitions and relevant longer-term renewals. It should not be treated as a new 14-day cancellation period after every ordinary monthly renewal.

Are customers always entitled to a full refund when they cancel?

No. Refund treatment depends on the circumstances and what has already been supplied. The Government's implementation proposals distinguish between full and proportionate refunds, so merchants should not build a universal full-refund assumption into their WooCommerce subscription process.

Does using Pay by Bank remove a subscription from the UK rules?

No. The payment method does not by itself determine whether a contract falls within the subscription regime. Merchants using Pay by Bank should assess the underlying subscription contract and customer journey in the same way as merchants using cards or other payment methods.

Are the new subscription requirements already fully in force?

No. The statutory framework has been enacted, but the new subscription-contract regime is not yet fully operative. Further regulations and implementation guidance are required for important operational details, so merchants should distinguish between the requirements established by the Act and details still being finalised.

Expert Note:
Written by a WalliD content specialist focused on ecommerce payments, Open Banking and WooCommerce payment journeys in the UK. This article explains the current subscription-contract framework from a merchant perspective and focuses on what WooCommerce businesses should review across subscription information, customer communications, cancellation and payment flows.

2026-09-11 18:28 Subscriptions