The Subscription Rules Are Right. They Are Still Going to Hurt.

From the Editor.

On October 19, the UK government laid the regulations for its new subscription regime before Parliament and published 77 pages of draft guidance to go with them. Starting January 1, 2027, every new consumer subscription sold in the UK has to follow a new rulebook: clear key terms before purchase, written reminders before renewals, a 14-day cooling-off period at the start and again at key renewals, and an exit "as easy as signing up." The CMA can fine up to 10 percent of global turnover. There is no statutory grace period. The regulations still need Parliament's approval, so the date could move, but nobody should plan on that.

Dating is a subscription business, so this lands squarely on us. Our trade body, the ODDA, called it the most significant consumer-law change for the sector in years. I agree.

I also agree with the rules. That is the part some operators will not want to hear. The second part is the one regulators do not want to hear: this is going to be painful for a lot of people who did nothing wrong.

Both things are true. Here is why.

Subscription design is where a lot of the fraud lived

Look at the cases. In 2019 the FTC sued Match Group, alleging it sent "someone is interested in you" emails to non-paying users even when the accounts behind those messages had already been flagged as likely fraudulent. The FTC said the scheme pushed hundreds of thousands of people into paid subscriptions. It also alleged Match made cancellation hard and cut off people who won billing disputes. Match settled in August 2025 for $14 million, admitted no liability, and said the practices had ended years earlier.

That is the biggest company in the category. Below it is a long tail of sites most of you know about: "free" funnels that turn into recurring charges, engagement from profiles that are not real people, and renewals designed to be forgotten. Last week I wrote that the scammer is your most engaged user. The subscription version of that problem is the customer who only renews because they forgot they were paying. Neither one is a real business. Both look fine on a dashboard.

The UK government's own impact numbers show the scale. It estimates about 9.7 million unwanted subscriptions are active in the UK, roughly 3.6 million of them from trials that rolled over, and that consumers spend £1.6 billion a year on subscriptions they do not want. Every pound of that is sitting in somebody's revenue line.

A subscription that only survives because the user cannot find the exit was never a customer.

So yes. Rules that force the renewal into the open, make cancelling easy and stop "free" from meaning "free until we bill you" will cut off a lot of bad behavior. A subscription that only survives because the user cannot find the exit was never a customer. It was a liability waiting for a regulator.

The pain is real, and it will not land evenly

The rules are aimed at the worst actors. The cost lands on everyone who sells a subscription. A few places it will hurt dating in particular:

Every reminder is a prompt to cancel. Monthly subscribers must get a written reminder roughly every six months. Trial and discount users must be reminded before the price goes up. Annual plans need an extra, earlier reminder before each renewal. Honest operators have always had some renewals from people who meant to stay and some from people who forgot. Starting in January, you will learn which is which. Expect renewal rates to drop, even at companies that never did anything wrong.

Dating front-loads its value. A new subscriber often gets the most out of a dating product in the first week. They reveal their likes, use the boost, start the conversations. The cooling-off rules let a consumer cancel within 14 days and pay only for what they used. The ODDA has already asked how that math works for a product used heavily in its first days, and whether a dating subscription counts as a service or as digital content, which changes the refund rules. The government has not answered yet. Until it does, every operator has to guess.

Long plans get fragile. Discounted six- and twelve-month plans carry a lot of dating's cash flow. Under the new rules, renewing onto a 12-month term or out of a discount opens a fresh 14-day cooling-off window. If you miss a required notice, the cooling-off period can stay open for up to 12 months. One broken email template can turn a year of revenue into a refundable balance.

App store billing does not move the duty. The guidance says the obligations sit with the trader the consumer contracts with, and that a pop-up or in-app message that disappears does not count as a written notice. The guidance does not deal with app store billing directly. My read is that most dating subscriptions sold through Apple and Google will still need reminders, notices and an exit route that the operator controls, through a store flow that it does not control. Check that with your lawyers before January, not after.

Save flows lose their teeth. Retention offers cannot prolong the exit, and you cannot require feedback before someone leaves. If your churn plan depends on a three-screen cancellation maze, that plan ends on January 1.

The smaller you are, the more it costs. Match has a legal team in every market. A ten-person app has a founder reading a 77-page PDF at midnight. The UK is only the first. The European Commission is expected to propose its Digital Fairness Act in mid-November, and subscription cancellation is one of the areas it has flagged. The FTC reopened its negative option rulemaking in March after a court threw out its click-to-cancel rule, and many US states already have automatic renewal laws of their own. Building one compliant subscription stack is manageable. Building five slightly different ones is a real tax on small companies, and it will push some of them toward selling or shutting down.

There is also a timing problem. The rules apply only to contracts signed on or after January 1. Existing subscribers are not covered, though the guidance says consistent treatment is best practice. Most operators will end up running two subscription systems side by side for a while, and that is exactly where mistakes happen.

Pay now or pay later

I have been on the revenue side of subscription businesses for most of my career. Here is how I would think about it.

The revenue these rules take away was never as good as it looked. Some of it came from people who were going to complain, charge back, leave a one-star review and tell their friends that dating apps rip you off. That story hurts every operator in the category, the same way a scam on one app hurts trust in all of them. Nobody can see that cost on a dashboard either.

That does not make the transition cheap. Some honest companies are going to post a few bad quarters while this shakes out, and some small ones will not make it to the other side. Regulators should hear that clearly. The ODDA is right to push for straight answers on refunds and digital content before January, not after the first enforcement case.

But operators who spend the next two months complaining instead of building will lose twice. Once to the rules, and again to the competitor who used the change to tell users, "We are the one that's easy to leave," and meant it.

What to do before January 1

These rules exist because some of this industry treated renewal as a trick. The honest operators are going to help pay for that. The best response is to make sure that, in a year, being easy to leave is part of why users trust you.

Sources: UK government subscription contracts guidance and draft regulations (October 19, 2026); government response to consultation (April 2026); ODDA statement (October 21, 2026); FTC v. Match Group complaint (2019) and settlement (August 2025); FTC negative option ANPRM (March 2026); European Parliament Research Service on the Digital Fairness Act (October 2026).