Your cancel button could now get you a 10% global revenue fine

As of 6 April 2025, the UK’s Competition and Markets Authority (CMA) will have the power to directly fine companies that fail to comply with the Digital Markets, Competition and Consumers Act 2024 (DMCCA). Penalties can reach up to 10% of global annual turnover or £300,000, whichever is higher. For subscription-based businesses, the stakes around UX design, accessibility, and cancellation flows have never been higher. In this series, we’ll break down the new compliance areas that could impact your business — and how to stay ahead of them. Part 1: Subscription traps We’ve all seen it — unclear settings, phone calls, hidden links. What was once just bad UX is now a potential legal risk. Section 260 of the DCCMA — Arrangements for consumers to exercise right to end contract (1) A trader must make arrangements to enable a consumer to exercise a right to bring a subscription contract to an end— (a) in a way which is straightforward, and (b) without having to take any steps which are not reasonably necessary for bringing the contract to an end. (4) In relation to a subscription contract entered into online, arrangements under subsection (1) must— (a) enable a consumer to bring the contract to an end online, and (b) ensure that instructions for doing so are displayed online in a place or places that a consumer seeking to end the contract is likely to find them. We have identified 5 UX dark patterns that could potentially put your business at risk from the above legislation. Hidden cancellation options Forced contact (e.g. phone or email) Guilt-tripping or manipulative language Excessive confirmation steps Penalties or artificial delays Let’s break them down: Hidden cancellation options

Apr 21, 2025 - 10:36

Your cancel button could now get you a 10% global revenue fine

As of 6 April 2025, the UK’s Competition and Markets Authority (CMA) will have the power to directly fine companies that fail to comply with the Digital Markets, Competition and Consumers Act 2024 (DMCCA).

Penalties can reach up to 10% of global annual turnover or £300,000, whichever is higher. For subscription-based businesses, the stakes around UX design, accessibility, and cancellation flows have never been higher.

In this series, we’ll break down the new compliance areas that could impact your business — and how to stay ahead of them.

Part 1: Subscription traps

We’ve all seen it — unclear settings, phone calls, hidden links. What was once just bad UX is now a potential legal risk.

Section 260 of the DCCMA — Arrangements for consumers to exercise right to end contract

(1) A trader must make arrangements to enable a consumer to exercise a right to bring a subscription contract to an end—

    (a) in a way which is straightforward, and

    (b) without having to take any steps which are not reasonably necessary for bringing the contract to an end.
(4) In relation to a subscription contract entered into online, arrangements under subsection (1) must—

    (a) enable a consumer to bring the contract to an end online, and

    (b) ensure that instructions for doing so are displayed online in a place or places that a consumer seeking to end the contract is likely to find them.

We have identified 5 UX dark patterns that could potentially put your business at risk from the above legislation.

Hidden cancellation options
Forced contact (e.g. phone or email)
Guilt-tripping or manipulative language
Excessive confirmation steps
Penalties or artificial delays

Let’s break them down:

Hidden cancellation options

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