The CMA has opened 20 consumer cases, and the new subscription rules start in January

The CMA has stated that since April 2026 it has opened six new direct consumer enforcement cases, against Ryanair, Euro Car Parks, Microsoft, Virgin Atlantic, Trainline and Red Driving School. That takes the total to 20, and the CMA has settled seven.

The CMA reports over £11.8m in fines and over £2.3m in redress. It says the pricing cases against Gold’s Gym, Wayfair and Buy It Direct produced penalties of over £6m. Open matters include Adobe and the Microsoft 365 and Copilot investigation, which was opened in July.

The numbers matter because they show a regulator using direct fining powers at pace, not a regime still in its education phase.

The CMA’s post says the new subscription-contract rules start in January. It does not state the year, and the commencement date and year have not been confirmed against the legislation. If the rules start in January 2027, businesses have about two months.

The CMA also states that it will support compliance first, but that conduct in the run-up may still count in enforcement, and that it will weigh genuine efforts to comply. The sensible reading is that there is no safe harbour before the start date.

Businesses should therefore check the commencement date and year in the legislation itself before setting their project timetable.

The CMA’s post says businesses must show the total price throughout the purchase journey, use genuine discounts and not pre-tick extras.

For a subscription business, that reaches the pricing page, the checkout, the order confirmation and the renewal notice. A price that changes between screens, a discount that is not genuine or an add-on that is selected by default is the pattern the CMA has been fining.

These are product and design points as much as contract points, but they end up in the contract. The terms say what the customer agreed to, and the sign-up flow is evidence of whether they actually agreed.

The CMA’s post says AI providers and deployers stay accountable to consumers. That sits alongside the Microsoft 365 and Copilot probe, which concerns whether customers received clear choices when AI features were added to existing plans.

The practical point for SaaS businesses is that adding an AI feature to a paid plan, and raising the price or changing the plan to match, is a consumer-law event. The customer journey has to explain what changed, what it costs and what the alternatives are.

The CMA’s cases are open or settled, so none of this is a finding. It is the direction of travel, stated by the regulator.

The CMA’s blog post is a statement of enforcement activity and intentions. It does not itself create new obligations, and the exact commencement date and year of the subscription rules should be checked against the Digital Markets, Competition and Consumers Act 2024 and its commencement regulations.

The figures for fines and redress are the CMA’s own, as reported in the post. The cases listed are at different stages, and a case being open is not a finding of breach.

Treat the post as an early warning that changes the cost of delay, not as a compliance checklist.

The following is drafting and design advice, not a statement of what the new rules require. It should be checked against the legislation once the commencement details are confirmed.

• Total price terms, stating the price payable including mandatory fees, and matching the pricing page, checkout and renewal notice to it.
• Renewal and cancellation, setting out how a subscription renews, how it can be cancelled and when reminder notices are sent, in terms the customer can find and follow.
• Price and plan changes, including changes tied to bundled AI features, with advance notice and a clear option to decline or leave.
• No pre-ticked extras, so optional add-ons require a positive choice, and the contract says which items are optional.
• Vendor warranties, where a platform, reseller or marketing vendor handles sign-up or advertising, warranting that its flows and copy comply, with an indemnity for regulatory penalties and redress.