Britain now regulates the subscription, not just the content

The figure or the record

The UK's Digital Markets, Competition and Consumers Act 2024 received royal assent on 24 May 2024, adding a subscription-contracts regime, Part 4, Chapter 2, sections 253 to 281, on top of the older Consumer Rights Act 2015, which already gives a consumer rights over digital content itself. The two Acts answer different questions: the 2015 Act asks whether the digital content bought is faulty; the 2024 Act asks whether the subscription that keeps charging for it is easy to leave.

What the documents establish

Under the Consumer Rights Act 2015, section 2(9) defines digital content broadly as data which are produced and supplied in digital form, and sections 43 to 45 give a consumer the right to repair or replacement, then a price reduction, then a refund, if that content does not conform to the contract. The 2024 Act adds obligations that attach to the contract rather than the content: section 264 gives a consumer the right to cancel during an initial cooling-off period and a renewal cooling-off period, each defined at 14 days; section 256 requires key pre-contract information as a standalone document before the consumer signs up, covering price, identity and cancellation steps; and section 258 requires a reminder notice before a subscription renews.

Scope and caveats

Whether a purchased balance of in-app coins is itself digital content under the 2015 Act's broad definition, separate from the episodes it later buys, is not something either Act states in so many words; the safer reading is that the episodes and video content the coins unlock are the digital content the 2015 Act protects, while the coins are closer to a unit of account for a later supply. The 2024 Act's subscription regime governs the contract for a recurring coin subscription specifically, its cooling-off and reminder duties concern the renewal relationship, not the individual episode purchase. This account did not confirm the exact date on which Part 4, Chapter 2 was brought into force by commencement regulations, which in UK practice is often later than royal assent, so a business should not assume the subscription regime binds from royal assent alone.

What to watch

Editorially, the detail worth tracking is the commencement date for the subscription-contract provisions specifically, since royal assent and the operative date for these duties are not the same thing under this Act, and a checkout built only to the 2015 Act's digital-content rules would still miss the 2024 Act's cooling-off and reminder duties once they take effect.

• Has a commencement regulation been made bringing Part 4, Chapter 2 of the 2024 Act into force, and on what date?
• Does the app's UK checkout provide the section 256 key pre-contract information as its own document, separate from general terms?
• Does the app treat a purchased coin balance as refundable digital content, or only the episodes it is later spent on?

Two different UK statutes now bear on a coin-based app: one asks whether what you watched worked, the other asks whether leaving the subscription that paid for it is as easy as joining it, and a compliance answer built for one does not automatically answer the other.