“Don’t poke sleeping dragons” is an expression often used in subscription marketing. In other words, if a subscriber is dormant, it’s probably not a great idea to remind them of their subscription.
No longer. UK subscription businesses will soon be required to remind subscribers and trialists about their subscription and what they are paying for. They will also introduce new requirements around cancellation and the information provided to customers.
The changes, slated for January 2027, reinforce what we’ve always known to be true: retaining subscribers depends on engaging them and demonstrating enough value for them to stay.
So, what do the new rules mean in practice, and how should publishers prepare?
We sat down with Marie Goddard (MG), Group Director of Customer Experience & Lifecycle at the FT. Marie and her team have been preparing for the new DMCCA rules for over eighteen months, adapting their approach and working closely with the FT’s legal team to interpret new guidance.
What the new rules mean
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Source: FT, Reader Revenue Group
The new rules affect publishers in five key areas:
- Clarity at point of acquisition - publishers now need key contract information clearly visible at the point of purchase. This can no longer be nested in the T&Cs.
- No stealth trial rollovers - when a trial converts into a paid subscription, customers must be reminded before the trial ends, giving them sufficient time to cancel before payment is taken.
- More reminders in-life - subscribers must be sent additional reminders about their subscription. The timing and frequency of these depends on the length of the subscription.
- Direct cancellation option - Cancellation must be available online if the subscription was purchased online, and must be “straightforward and free of unnecessary steps.”
MG: “It’s unclear how many steps are ‘reasonably necessary.’ Our interpretation at the FT is to reduce the journey to just one win-back offer and an optional question about motivation for cancelling”.
- Cooling-off period & refunds - additional cancellation and refund rights will apply in certain circumstances, including following some subscription renewals.
MG: “Imagine what this means for a media company like Disney. Someone could binge watch several shows, and then cancel.”
For global brands operating in multiple jurisdictions, our interpretation is that being compliant in the UK means brands are a long way towards compliance with other laws, given they have similar intent. For global publishers, this creates a broader question about how far subscription journeys should be standardised across markets.
Publishers will have to also consider subscriptions sold through third-party platforms, such as Apple’s App store and Google Play.
What could the effect be?
The commercial implications could be significant. Noncompliance with the DMCAA can be exposed to fines of £300,000 or, if higher, 10% of annual global turnover.
The effect on churn is harder to predict. We will only begin to see the actual impact when subscriber cohorts become due for renewal. Early FT testing suggests that churn could increase.
MG: “As we start seeing the data, we will have a greater understanding of impact, and can test and learn. Cancellation rates will go up, but it’s not necessarily that more people will cancel than would have otherwise. Instead, they may do so earlier in their lifecycle, and this would have a net revenue effect. Consumers will probably be inundated with reminder emails in January. We could see a spike of cancellations that could then normalise.”
Print may behave differently. Marie notes that subscribers to the FT’s print/digital bundle receive a tangible daily reminder of their subscription. The greater concern is around less engaged digital subscribers.
There may also be a longer-term benefit to making cancellation easier. Marie recalls that the FT was very early to implement easier cancellation online, and we learned that this made it more likely for customers to return in the future. In fact, when we implemented online cancellation, we saw a better save rate of 6% (doubled compared with the previous 3%).
How publishers can prepare
At the FT, focus has been not only on compliance but also on churn mitigation.
MG: “Improving our ability to save customers at the point of cancellation has been a big focus for the FT teams; if we can only show them one win-back offer, it needs to be exactly right. We've invested in data science and the save experience to predict what that offer should be and build the right customer experience at this point in the journey. Early performance has proven to boost both our save rate and customer lifetime value.”
MG: “Our approach has been to protect customer needs and a favourable user experience while responsibly pursuing our commercial goals. We have an opportunity here to set the gold standard and win more trust. The new rules mean we’ll be giving our readers more control and transparency."
Marie recommends focusing on the following questions:
- Why do customers cancel?
MG: “People don’t cancel because they get a reminder email, that is just the catalyst. You need to understand why they have cancelled in order to prevent churn.”
Use the period before implementation to build a clearer picture of cancellation reasons, which cohorts are most vulnerable and test different interventions.
- How can we re-engage disengaged cohorts?
Engagement is the other side of the retention equation. Develop a more proactive engagement strategy to prevent readers from becoming ‘at risk.’
Historically, the FT’s onboarding journey has been the starting point for this effort.
MG: “We’ve been thinking about our goals before the six-month reminder email. How engaged do we want a subscriber to be by that point and how can we push them up to that level?”
- Who needs to be involved?
This is not just a question for marketing teams. Achieving compliance will require input from legal, commercial, product, technology, data, finance and customer service. With the Reader Revenue Group driving the FT’s response, the work requires a full company effort to mitigate implications for churn, lifetime value, acquisition costs and proposition strength.
MG: “We have worked really hard with our legal team to understand the FT’s interpretation of the rules and embed that in our strategy.”
For many publishers, preparing for the changes will therefore require a combined regulatory, commercial and operational assessment: understanding what needs to change and how to strengthen propositions and engagement strategy.
This article is for general information only, reflects our understanding as of September 2026 and does not constitute legal advice.
Special thanks to Emma Bentaleb, FT Legal.
FT Strategies can assist publishers in preparing for changing subscription requirements by assessing the potential impact on subscriber retention, identifying customers most at risk of churn, and testing new customer journeys and engagement tactics.
Through our Subscription Growth & Retention and Funnel Analytics services, we help organisations strengthen engagement, optimise the subscription lifecycle, and build more resilient reader revenue strategies. Please contact us to explore how we can support your organisation.
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