Ukie responds to new subscription’s contracts regime

Submitted – 10th February 2025

Ukie welcomes the opportunity to respond to the Government’s consultation on new subscription contract rules and supports measures that enhance consumer rights, provided they remain practical for businesses to implement. As subscription models for games continue to grow in popularity, offering consumers exceptional value and access to premium content, it is crucial that regulations strike a fair balance. Ukie supports clear, timely information for consumers, including at the point of renewal, and believes that established waivers on refunds for digital content, once accessed, should be upheld to protect traders from misuse. The trade body expresses concern that proposed rules, such as introducing a 14-day cooling-off period at renewal with proportionate refunds, risk encouraging content ‘bingeing’ followed by cancellations, ultimately undermining business models and reducing consumer choice.

Ukie urges the Government to avoid a one-size-fits-all approach and instead adopt Option 3, which maintains current digital content refund waivers and ensures consistency for consumers. It suggests practical improvements, such as enabling consent through in-app notifications and recognising subscription reminders as opportunities for informed tacit consent. Ukie also calls for a clearer definition of digital services to prevent confusion and mitigate risks for businesses offering hybrid models that include content libraries, multiplayer access, and cloud services. These adjustments would safeguard innovation, protect long-term value for players, and ensure the continued success of the UK’s thriving games subscription economy.