Subscription reforms under the DMCCA: What sport organisations need to know

Written by Daniel Tedd, Solicitor in our Corporate/Commercial team.

The Digital Markets, Competition and Consumers Act 2024 (DMCCA) introduces wide-ranging consumer law reforms designed to tackle “subscription traps”, situations where individuals are locked into recurring payments without clear consent or adequate information.

For the UK sport sector, this new legislation is highly relevant. Many clubs, governing bodies, and service providers offer membership packages, season tickets, facility access, or digital streaming on a subscription basis. The DMCCA will change how these arrangements are marketed, renewed, and cancelled.

These reforms will apply not only to commercial providers such as gyms or broadcasters, but also to public bodies, sport associations, and incorporated clubs operating under the Companies Act 2006 where membership subscriptions or services are provided to consumers. Governing bodies will need to consider the impact on their member clubs and associations, and ensure that their rules, membership terms, and renewal processes are compliant.

How the DMCCA defines a subscription contract

Under the DMCCA, a subscription contract is an agreement between a trader and a consumer for the supply of goods, services or digital content on a recurring basis.

In the sport sector, this may include:

• Annual or monthly membership fees for clubs, governing bodies, or associations
• Season tickets or matchday passes with automatic renewal
• Gym or leisure centre memberships linked to sport participation
• Paid access to training programmes, coaching platforms, or online courses
• Sports streaming services for competitions or events
• Subscription boxes for sports equipment, nutrition, or merchandise

The key determining factors are:

1. Automatic renewal or ongoing supply – the service continues unless actively cancelled.
2. Automatic liability for payment – charges are taken at set intervals without new consent each time.
3. Right to cancel before next payment – the consumer can end the agreement before the next charge is due.

Even where the organisation is non-profit or member-led, if it provides services to consumers on a recurring, paid basis, the DMCCA may apply.

Why the DMCCA matters to sport organisations

Sport organisations often operate on trust-based, long-term relationships with members or supporters. However, the DMCCA imposes formal, statutory requirements on how subscription arrangements are communicated and managed.

For example:

• Clubs offering “auto-renewal” on memberships must give advance renewal reminders.
• Governing bodies charging affiliation fees to individual members must ensure that pre-contract information is provided clearly and separately from other rules or policies.
• Digital content providers (e.g., live-streaming services for matches) must allow for straightforward cancellation in the same way the subscription was taken out.

Key pre-contract information requirements

Before a consumer agrees to a subscription, sport organisations must provide key pre-contract information, including:

• Details of any automatic renewal provisions
• Charges after any trial or promotional period
• Payment amounts and frequency
• How the consumer can cancel the subscription

This information must be:

• Prominent and separate from other documents such as constitutions or codes of conduct
• Given close in time to sign-up or renewal
• In writing (unless agreed orally via remote communication)
• Easily accessible without extra steps

For example, a national governing body offering a discounted first-year membership to athletes must make clear what the ongoing annual fee will be and how to opt out of renewal.

Renewal reminders in the sport sector

The DMCCA requires that consumers receive clear reminders before a renewal payment is taken:

• Monthly rolling contracts – reminder at least every six months
• Annual contracts – two reminders before renewal

For sport, this could mean:

• A football club emailing season ticket holders twice before the auto-renewal date
• A governing body notifying members of upcoming affiliation fee renewals in line with its chosen timing schedule (which must be set out in advance)

Cooling-off rights

Consumers will have the right to cancel without penalty during:

• Initial cooling-off period – 14 days from sign-up (or from receiving goods in the case of a merchandise subscription)
• Renewal cooling-off period – 14 days from certain “relevant renewals”, including:
  • First renewal after a free or discounted trial
  • Renewal where the next payment is 12 months or more away
  • Renewal where no further payments are due but the contract continues for at least 12 months

Organisations must have procedures in place to process cancellations promptly and refund overpayments where applicable.

Straightforward cancellation

If a sport subscription was taken out online, cancellation must be possible online, with instructions clearly displayed in a place the member is likely to find them.

For example:

• A tennis club with an online member portal must allow members to cancel via that portal, without requiring an in-person visit.
• A sports streaming platform must offer an online cancellation form rather than requiring a call to customer service.

Once cancelled, the organisation must send an end-of-contract notice confirming the termination and any refund due.

Implications for public bodies and incorporated sport associations

Where sport organisations are incorporated under the Companies Act 2006, their members are afforded statutory rights that sit alongside contractual rights. The DMCCA requirements will interact with these in areas such as:

• Membership renewals
• Notice provisions in articles of association
• Members’ rights to resign and recover overpaid fees

Public bodies or quasi-public sport authorities with paying members will need to review their governance documents, terms, and renewal procedures to ensure alignment with the DMCCA.

Role of governing bodies

Governing bodies play a central role in ensuring sector compliance. Recommended actions include:

1. Review membership categories – Determine which types of members fall within the DMCCA’s scope.
2. Assess club-level obligations – Consider whether the legislation applies to member clubs and, if so, how.
3. Issue clear guidance – Publish a position statement for members, similar to Welsh Athletics’ proactive communication on compliance matters.
4. Educate and support – Provide template renewal notices, cancellation processes, and pre-contract information documents to clubs.
5. Facilitate communication – Encourage clubs to share DMCCA information with their own members to ensure sector-wide understanding.

Penalties for non-compliance

The CMA will have direct enforcement powers, including the ability to issue fines of up to 10% of worldwide turnover or £300,000, whichever is higher.

While many sport organisations may not reach turnover levels that trigger the maximum, the reputational risk of non-compliance, particularly for governing bodies and major clubs, is substantial.

Preparing for spring 2026

Although the subscription provisions are expected to come into force in spring 2026, sport organisations should act now to:

• Audit membership and subscription terms
• Update sign-up and renewal processes
• Train staff and volunteers on the new requirements
• Coordinate with payment processors and ticketing platforms to ensure compliance
• Engage with members and stakeholders early to build trust through transparent practices

Our dedicated cross disciplinary team of sports lawyers advise across the entire sector, from national governing bodies to grassroots clubs. We can help you review your subscription models, membership rules, and governance documents to ensure compliance with the DMCCA, while respecting your obligations under the Companies Act 2006. Contact our Commercial team to arrange a tailored compliance review.