Subscription rules for consumer SaaS

Based on draft Regulations laid 19 October 2026.

Short answer. A SaaS product with consumer customers and a free trial needs a trial-ending reminder before the first charge, a renewal cooling-off notice when the trial converts, a six-monthly reminder on monthly plans and an easy online cancel.

B2B-only software is out of scope, but plenty of indie SaaS sells to individuals and freelancers who count as consumers. If any of your customers are consumers, the trial and renewal rules matter.

  • A 14-day trial is long enough for a 7-day reminder window. A 3-day trial is not.
  • The trial converting to paid starts a new cooling-off period with its own notice.
  • Self-serve cancellation inside the app satisfies the online route if it is easy to find.

Worked example: SaaS monthly plan

A 14-day free trial, then £29 a month, starting 15 January 2027.

DateNoticeWhat it covers
15 January 2027Full contract informationAt sign-up
15 January 2027Cooling-off noticeCooling-off ends 29 January 2027
22 January 2027Free trial ending reminderPayment of £29.00 on 29 January 2027
29 January 2027Renewal cooling-off noticePayment of £29.00 on 29 January 2027. Cooling-off ends 12 February 2027
22 July 2027Six-monthly reminderPayment of £29.00 on 29 July 2027
22 January 2028Six-monthly reminderPayment of £29.00 on 29 January 2028
22 July 2028Six-monthly reminderPayment of £29.00 on 29 July 2028

End-of-contract confirmation: Within 24 hours of an online cancellation.

Suggested checkout wording: We'll email you 3 to 7 days before your free trial ends, and before renewal at least every 6 months, 5 to 10 days before the payment. You can cancel online at any time.

Timings use our suggested defaults. The law doesn't fix the number of days; you choose a window and state it at checkout.

Questions

Does the trial need a card up front?

The reminder duty applies where the trial rolls into a paid plan, which in practice means a card is held. A trial that simply ends needs no reminder.

Renewful

Renewful sends the notices the draft UK subscription Regulations ask for, keeps a dated record, and publishes free tools and guides so small businesses can work out what applies to them.

Not legal advice. If unsure, check with an adviser.