Short answer. Under the Digital Markets, Competition and Consumers Act 2024 the CMA can fine a business up to £300,000 or, if higher, 10% of its turnover, without going to court (section 182(6)). The subscription contract duties in Part 4, Chapter 2 are on the list of enactments it can enforce directly (Schedule 16). Those duties are due to start from 1 January 2027, subject to Parliament.
The headline numbers
| Figure | What it means | Source |
|---|---|---|
| £300,000 or 10% of turnover, whichever is higher | The maximum penalty in a final infringement notice. No court order is needed first. | Section 182(6) |
| 6 April 2025 | When the CMA's direct consumer enforcement powers came into force. | Commencement note on section 181 |
| Chapters 1, 2 and 3 of Part 4 | Listed as directly enforceable. Chapter 2 is the subscription contracts chapter. | Schedule 16 |
What the CMA has done so far
In its first year of direct enforcement, from April 2025 to April 2026, the CMA reports that it:
- opened investigations into 14 businesses and settled with 2,
- imposed fines totalling £4.7 million and ordered £760,000 in consumer refunds,
- sent 157 advisory and warning letters and 46 information notices.
Its fines included £4.2 million against the AA, which admitted liability for drip pricing. In an open letter published on 2 November 2026 the CMA said it has now enforced the drip pricing rules against 4 businesses, with fines of more than £5.1 million and more than £1.35 million in refunds.
Those cases are about drip pricing, fake reviews and online choice architecture, and the CMA is also investigating Adobe over early cancellation fees. The point is that the CMA is using the power, and its blog tells businesses to prepare for the subscription rules: "businesses must get ready to comply".
What customers can do if you get it wrong
Separate from any fine, section 263 gives a consumer the right to cancel a subscription contract if the trader breaches an implied term, including the duties to give key pre-contract information, send reminder notices, specify a reasonable reminder period or provide a straightforward way to end the contract. No penalty or charge may be imposed for cancelling, and the consumer may be entitled to a refund as set out in regulations.
What this does not tell you
A maximum is not a forecast. Fines depend on the case, and the refund rules are set in regulations that are still in draft. The subscription chapter is marked prospective in the legislation until it comes into force.
This page is general information, not legal advice.
Questions
How much can the CMA fine under the DMCC Act?
A final infringement notice can impose a fixed penalty of up to £300,000 or, if higher, 10% of the total value of the respondent's turnover (section 182(6)).
Can the CMA fine over subscription contract breaches?
Chapters 1, 2 and 3 of Part 4 of the Act, which include the subscription contract duties, are listed in Schedule 16 as enactments the CMA can enforce directly.
Have subscription fines been issued yet?
Not yet. The subscription duties are not in force. The CMA's fines so far, such as £4.2 million for the AA over drip pricing, are for other breaches.
Is failing to give cooling-off information a crime?
For off-premises subscription contracts, failing to give the required cooling-off information is an offence under section 268, enforced by local weights and measures authorities.
Sources
- DMCC Act 2024, section 182 (final infringement notice and penalty)
- DMCC Act 2024, Schedule 16 (direct enforcement enactments)
- DMCC Act 2024, section 263 (right to cancel for breach of implied term)
- CMA blog: Direct consumer enforcement, one year on (17 April 2026)
- CMA open letter to online retailers (published 2 November 2026)
Not legal advice. If unsure, check with an adviser.