New UK legislation is changing the rules around subscription contracts — including gym memberships. Here’s what’s coming, what it means in practice, and what you should be thinking about ahead of its enforcement.
If you haven’t heard of the Digital Markets, Competition and Consumers Act 2024 (DMCC Act) yet, you’re not alone. Between managing members, covering the desk, and keeping everything running day-to-day, tracking government legislation doesn’t always make the priority list.
But this one is worth understanding. With enforcement of the subscription contract provisions now targeted for Spring 2027, there’s still time to prepare — but it’s worth starting that process now rather than later.
This article is intended to inform, not advise. ClubWise is a software company, not a legal firm, and nothing here should be taken as legal guidance. For questions specific to your business and compliance obligations, we’d always encourage you to seek independent legal advice. What we can do is give you a clear picture of what’s on the horizon.
What is the DMCC act?
The Digital Markets, Competition and Consumers Act received Royal Assent in May 2024 and represents the most significant overhaul of UK consumer law in over a decade. Several provisions — including drip pricing prohibitions and new CMA enforcement powers — came into force in April 2025.
The part that directly affects gym and leisure operators — the subscription contracts regime — is expected to come into force Spring 2027, following a government consultation that concluded in April 2026. Secondary legislation is still being drafted, with guidance for businesses expected before implementation.
The Act was prompted, in part, by government estimates that so-called “subscription traps” — auto-renewals, opaque cancellation processes, and dark-pattern tactics — cost UK consumers over £1.6 billion per year. The Competition and Markets Authority (CMA) has already shown it is serious, issuing its first financial penalty for consumer law breaches in April 2026.
Corporate wellness is one of the most underused revenue streams for independent Australian gyms. At EOFY, the incentive to act is particularly strong. Businesses with remaining health and wellness budget need to spend it before June 30 to claim the deduction in the current financial year. A corporate bulk membership package positioned as a pre-EOFY tax move removes the common objection of cost timing.
The potential fines are substantial: up to 10% of global annual turnover for companies, and up to £300,000 for individuals. This is an active enforcement environment, not a future risk.
What does it actually require?
Here are the five areas most likely to affect your gym or leisure business:
1. Pre-contract information — clear, prominent, before they sign
Before a member enters into a contract, you must ensure that key information is made clearly available and prominent — not buried or hard to find. This includes:
- The payment amount and frequency
- Auto-renewal terms
- The cancellation process
- Cooling-off rights
What this means in practice: Members need to know where to find this information and to have had a genuine opportunity to read it before they commit. The requirement is not that every line of your terms and conditions must be displayed on screen — it is that the existence and location of key terms is made prominent, and that members are not surprised by auto-renewal or cancellation conditions after the fact. Reviewing how your membership terms are presented at the point of joining is a sensible place to start.
A note from ClubWise: Our online joining and membership agreement templates are designed to surface key terms at the point of sign-up. The ClubWise team is happy to talk through how your current setup presents this information and where adjustments might be worth considering.
2. Renewal reminder notices — proactive, prominent, on time
You must proactively remind members of upcoming renewals:
- Monthly rolling subscriptions: A reminder at least every 6 months
- Annual (12-month) subscriptions: Two reminders near the end of the term
- The renewal reminder must be the most prominent content in any communication in which it appears — it cannot be buried in a general newsletter or footer note
With members on different contract cycles and lengths, this requires a process that is both consistent and auditable. If a member disputes a renewal charge and claims they were never reminded, you will need to be able to demonstrate that the notice was sent.
What this means in practice: Manually tracking renewal windows across a large membership base is genuinely difficult to sustain reliably. Whether through your CRM, your gym management software, or another system, what matters is that the process is consistent, the content meets the requirements, and you have a record.
A note from ClubWise: ClubWise’s Active CRM can be configured to automatically send renewal reminders triggered by membership anniversary dates — including the required auto-renewal terms and cancellation rights — and logs every communication for your records. The ClubWise team can help you explore what an automated reminder workflow might look like for your membership setup.
3. Cancellation rights — easy to start, by the right means
The Act introduces clear requirements around when and how members can cancel:
- A 14-day cooling-off period from the start of a contract
- The right to cancel after a free trial and at renewal
- Members must be able to initiate their cancellation through the same means by which they joined — so if a member joined online, they must be able to begin the cancellation process online. If they joined in person, an in-person or written process remains appropriate.
The key principle is that cancellation should be straightforward. The Act’s language is clear: it should be as easy to exit a subscription as it is to enter one.
What this means in practice: The requirement is specifically about how a member initiates their cancellation — it must be accessible through the channel they used to join. It is worth reviewing your current cancellation journey in light of this. It is also worth understanding the distinction between a dark pattern — deliberate design intended to obstruct or frustrate cancellation — and a feedback step, such as an exit survey or a brief conversation. The Act prohibits the former; a thoughtful process that asks why someone is leaving, without blocking or delaying the cancellation itself, remains acceptable.
A note from ClubWise: ClubWise’s FitSense member app supports self-service membership management, including online cancellation workflows, for members who joined digitally. The ClubWise team can walk you through the options available within your current setup
4. Marketing practices — no false urgency or dark patterns
The Act explicitly prohibits:
- False urgency — implying an offer is time-limited when it isn’t (such as a “today only” promotion that resets every 24 hours)
- Dark patterns — interface or process design deliberately intended to discourage cancellation or mislead members into renewing
What this means in practice: It is worth reviewing your marketing materials, join pages, and any automated member communications. If you use countdown timers or time-limited messaging, you should be confident these reflect genuinely time-limited offers.
5. CMA enforcement — this has teeth
The CMA now has direct enforcement powers under the DMCC Act, including the ability to:
- Fine companies up to 10% of global annual turnover
- Fine individuals up to £300,000
- Award compensation directly to consumers
The CMA issued its first penalty under these new powers in April 2026. Enforcement is already underway for other consumer law provisions and the subscription contract regime will follow in Spring 2027.
Things worth considering for your business
The following isn’t a compliance checklist — it’s a prompt for internal reflection. Every business is different, and whether your practices meet the requirements of the Act is something only you (and your legal advisers) can assess:
- How are your key membership terms presented at the point of joining? Is it clear to a new member where to find information about auto-renewal, cancellation rights, and cooling-off periods before they sign up?
- Do your membership agreements explicitly reference the 14-day cooling-off period? If not, this might be worth reviewing.
- What does your renewal reminder process currently look like? Is it consistent, documented, and does it produce a record you could refer back to?
- Can a member who joined online initiate their cancellation online? Is that process straightforward, or does it require them to take additional steps not available through the channel they used to join?
- Have you looked at your marketing materials and join pages recently with an eye on whether any messaging could be characterised as false urgency or a dark pattern?
- Are your staff aware of members’ cancellation and cooling-off rights, and are they equipped to handle those conversations correctly?
A note from ClubWise
We’re sharing this because we work alongside gym and leisure operators every day and we think it’s important you’re aware of what’s coming. This article is intended to inform, not to prescribe — the decisions about how your business approaches compliance are yours to make, ideally with the support of qualified legal advice.
The DMCC Act’s subscription contract provisions are still subject to finalised secondary legislation and guidance. We’ll continue to follow developments and share updates as that picture becomes clearer.
Where our tools — including Active CRM, Online Joining, membership agreement templates, and the FitSense app — can support the operational side of what’s required, the ClubWise team is happy to talk that through with you.