The new subscription law for apps and software, in plain English
Free trials that turn into payments, three months at an introductory price, annual plans discounted against monthly, and content that starts the moment someone signs up. From 1 January 2027 a new UK law has a rule for each of these. You will have to email users before a trial or offer ends, give them 14 days to change their mind, and let anyone who subscribed on the web cancel on the web in one step. We plug into Stripe and do it for you.
Your typical plans and what the law asks for each
| Plan | What the law asks for |
|---|---|
| Monthly, 7 day free trial | An email before the trial ends saying the first payment is coming. A 14 day change of mind period at sign-up and another when the trial ends, each with its own email. Then a payment reminder at least once every six months. |
| Monthly, first 3 months at £4.99 then £12.99 | An email before the first payment at £12.99 and a change of mind period when the full price starts. The full price must be on the sign-up page next to the offer. |
| Annual plan, 2 months free compared to monthly | A reminder before every annual renewal and a 14 day change of mind period, with its email, each time it renews. The annual total is the commitment to show at sign-up. |
| Monthly with immediate access to content | A change of mind period at sign-up. The user may agree to start straight away and accept that they lose the refund for content they have used, but that agreement must be recorded with a timestamp. |
What we do for your app
We connect to Stripe and read your plans and subscribers. It emails users before a trial or introductory price ends and before each payment the law requires, in your branding. It gives them a cancel page on the web that takes one step, no support ticket or chat bot. And it keeps a record of every email, click, refund and consent, so if the regulator asks you have the answer.
It also writes the sign-up wording the law requires for each plan, with the full price shown next to the offer, ready to paste into your pricing page or Stripe Checkout.
Trials and introductory prices
Before the first payment at the full price, the user needs an email that says the price is about to apply, how much, when, and how to cancel. We send one before a free trial turns into any charge and another before the first full price charge after an introductory price, which is the safest way to do it. When the full price starts, a 14 day change of mind period opens and an email is due at its start. See trials and introductory offers.
Users who start using content straight away
A user who starts streaming or downloading inside the 14 days can give up the right to a refund for the content they used, but only if they clearly agree and accept that they lose the right. A pre-ticked box is not agreement. A line buried in the terms is not either.
We record the agreement with a timestamp against the subscription and take it into account in the refund sum only when both parts are there. Without them, a change of mind cancellation is refunded in full even if the content was used.
App store subscriptions
Where Apple or Google takes the payment for an in-app purchase, their platform runs the renewal. The duties under the law sit with whoever makes the contract with the customer, so check with your adviser who that is for each sales channel. We connect to Stripe for web sign-ups today. App store billing is not a connection we offer.
Cancel in the app, not by email
Users who subscribed on the web must be able to cancel on the web in one clear step. A support ticket, a chat bot or an email to cancellations@ does not count. One offer to stay, for example a cheaper tier, is allowed. You confirm the cancellation in writing within 24 hours. See one click cancel.
Worked example: Fitness app, £12.99 a month, first 3 months at £4.99, signed up 1 March 2027
Change of mind email on 1 March, period to 15 March. Payments of £4.99 on 1 March, 1 April and 1 May. The first £12.99 payment is 1 June: an email from 25 May (7 days notice promised) and no later than 29 May, saying £12.99, the date, cancel by 1 June to avoid it, and how.
A second change of mind period opens 1 June with its email, to 15 June. The next reminder attaches to the 1 October payment, the first in the six month period from 1 September, sent from 24 September.
Questions
- Is a free trial with no card covered by the law?
- If the trial turns into a paid subscription unless the user cancels, yes, from the day they start it. If it simply expires with no charge, it is not.
- Can we start the subscription straight away without losing the change of mind refund?
- For content, only if the user clearly agrees and accepts that they lose the refund for content they have used. For software access, the refund is worked out on time used instead.
- Do we need a reminder every month?
- No. Monthly plans need a payment reminder at least once every six months, plus the extra emails before a trial or introductory price ends.
- Is the Stripe customer portal a one click cancel?
- Not on its own. It is behind a login, it is not linked from the emails, and it does not send the cancellation confirmation. We give you a cancel page reached by a secure link from every email and your account page.
- What about users who signed up through the App Store?
- The platform takes the payment for those purchases. Confirm with your adviser where the duties fall for each channel. We cover web sign-ups through Stripe.
This page explains the law in plain English. It is not legal advice. The detailed rules are still being finalised by the government.