Nothing has changed yet. The subscription measures the Prime Minister’s Office announced on 9 August have been written up almost entirely in compliance briefings addressed to businesses, not to the people being charged, and those briefings are countdowns. We set out the four duties when the CMA’s drip-pricing cases went up. What matters here is what they would do to the billing flows a dating app actually uses.
What already binds, and what does not
Today a renewal screen is not lawless. The DMCC Act’s unfair commercial practices provisions apply to commercial practices from 6 April 2025 onwards, and the CMA’s guidance covers misleading actions and misleading omissions, plus the information already owed before a distance contract under the Consumer Contracts Regulations 2013. What does not exist is a duty to remind you ahead of a renewal, or a fourteen-day window to undo one after it has gone through. Those are what January adds.
The government says commencement is January 2027, though the detail is not settled: TLT’s 24 August briefing notes the secondary legislation and guidance are still unpublished. The release’s figures — around 155 million active UK subscriptions, an estimated £1.6 billion a year on unwanted ones — are national, not dating numbers.
The three flows it meets
No dating app is named anywhere in the release, and nobody should read the category into it. The trial that flips to paid without a second tap is the obvious one; the twelve-month tier sold at a per-month price is the second. Both draw both rights: the release has the fourteen-day window running after a long contract renews as well as after a trial, and on TLT’s reading a reminder falls due at least once every six months, with further notices owed on trials and on renewals of twelve months or longer — a dated warning in front of someone who has forgotten which of the two numbers they agreed to.
The third flow appears to fall outside. A boost bundle bought outright is not a subscription contract, and the regime reaches only those. The other half of the same announcement — fake “was” prices, invented discounts, misleading RRPs — is where a one-off purchase would be caught, and that half is only a consultation, promised for the autumn and, as of this writing, not opened. Where a paywall leans on consumables, January will touch the smaller half of the bill.
Why a reminder is worth more in Hull than in Hackney
Nobody publishes the data, so take this as inference rather than finding: the subscriber carried through a silent renewal is probably the one who stopped opening the app because the pool ran dry in a fortnight. That describes a thin market, not a careless customer, and a reminder is worth most where the product is worth least.
One reminder that needs no commencement date: these billing flows sit behind apps for over-18s, and January does not change that.