Subscription cancellation law: clear renewal, easy exit

The rule

Two EU instruments meet on subscriptions. The Consumer Rights Directive says what a trader must tell a consumer before the contract. The Unfair Commercial Practices Directive (UCPD) asks whether the way the offer is presented, or the way leaving is made, misleads or pressures an average consumer. Neither has a chapter called “subscriptions”. Both reach them.

The point-of-order duty is the one that applies most directly to a renewing subscription. The renewal terms and the price per billing period have to be next to the button, not only in a terms page.

Enforcement has used the UCPD against the exit as well as the entrance. In July 2022 the Commission announced that Amazon had committed to bring its Prime cancellation into line with EU consumer rules, after a coordinated action by the Commission and national authorities that began in April 2021. The Commission said the change was necessary to comply with the UCPD in particular, and it described the problem as hurdles such as complicated navigation menus, skewed wording, confusing choices and repeated nudging.

Penalties are national. Article 24 of the Consumer Rights Directive and Article 13 of the UCPD leave the rules to Member States, which must make them “effective, proportionate and dissuasive”. For widespread infringements handled under the CPC Regulation (EU) 2017/2394, Member States must allow a maximum fine of at least 4% of the trader’s annual turnover in the Member States concerned (UCPD Art. 13(3); CRD Art. 24(3)). The Italian authority applied articles 20, 21, 22, 24, 25, 26(f) and 65-bis of the Italian Consumer Code in its Virgin Active decision.

A newer rule sits beside these. Directive (EU) 2023/2673 inserts Article 11a into the Consumer Rights Directive. From 19 June 2026, for distance contracts concluded through an online interface, the trader must offer a withdrawal function labelled “withdraw from contract here”, continuously available during the withdrawal period and prominently displayed, followed by a confirmation function. That is the 14-day withdrawal right. It is separate from ending a running subscription.

The Commission has also announced a Digital Fairness Act. The European Parliament’s legislative tracker lists it as announced, not adopted, expected in the fourth quarter of 2026, and aimed at difficulties with cancelling and renewing digital subscriptions.

What PeekWell checks and how

EU-13 asks two questions of a site that appears to sell subscriptions. Are the renewal terms stated where a visitor can read them before buying? Is a cancellation route described or linked? The scan answers from the public pages, not from what the company says in a contract.

The check applies only when the scan has seen signs that the site sells subscriptions. A language model reads the terms of service and checkout copy and pulls out the sentences about renewal and cancelling. Code then checks for a link to a cancellation route.

The method is the same one PeekWell uses for the United States rule on US-09; only the law it is compared with differs.

The scan has limits, and the report says so. It sees public pages and nothing behind a sign-in. It does not start a checkout, enter payment details, create an account or try to cancel, so it cannot see the label on the final order button or how many steps a cancel flow takes. It reads wording; it does not decide what the wording legally amounts to. A Passed means the expected behaviour was observed on the pages scanned. It does not say the site complies.

Why it matters for a company

These are matters authorities can read from the outside. The Italian authority’s decision on Virgin Active Italia in June 2025 ended in a fine of EUR 3 million. It found inadequate information about subscription terms, automatic renewal, cancellation and early termination, and no advance notice of renewal or of the cancellation deadline. The authority found that customers were not put in a position to decide consciously whether to subscribe or cancel.

The Amazon action ended without a fine, but with commitments applied to every EU website and device, and monitoring by the authorities. The Commission’s release includes screenshots of the new cancellation steps, which shows what it looked at: the screens a consumer sees.

For a company the consequences are practical. A missing statement before the order can leave the consumer not bound by the contract under Article 8(2). Article 8(2) asks for the terms directly before the order, so a terms page alone may not be enough. And money taken under unclear terms is a refund exercise, which is a cost on top of any penalty.

Smaller companies and larger companies

The rules have no size threshold. A sole trader and a listed group are measured against the same pre-contract information and the same test of what an average consumer would understand. Size shows up in the penalty and in how the problem arises.

In a small company the subscription is often a plan inside a hosted shop or a payment tool. The renewal sentence sits in a default template, or in terms copied from another site, and the cancel route is an email address nobody has tested. The Dutch authority fined a sole proprietor EUR 25,000 in 2022 for misleading telemarketing of puzzle subscriptions with unclear and incorrect cancellation information, and noted the business’s size when it set the amount.

In a larger company there are more screens and more owners. Marketing runs trials, product owns the account area, support owns the cancel flow, and a redesign can move the cancel link three levels down. The Amazon action is a case of exactly that: the problem was in the path, not in a missing page. A large company can also face several national authorities acting together, as the Amazon case shows.

How to fix it

1. Walk the path as a customer. Open the site in a private window, read the pricing page, start the signup up to the last step without paying, then try to find how to cancel. Write down every place the renewal terms are or are not stated.
2. Put the terms next to the button. Directly above the order button, state in plain words the price per billing period, whether it renews automatically, the length of any minimum period, and how to end it. Label the button with words that say it creates an obligation to pay.
3. Say how trials convert. If a free or discounted trial turns into a paid plan, say when and at what price, on the same screen as the trial offer.
4. Make the cancel route findable. Put a plain link, such as “Cancel subscription”, in the account area, the footer or the help page, and in the terms. If people sign up online, let them cancel online without a phone call or a chat.
5. Remove friction from the exit. Keep the path short. Drop distracting warnings, unclear button labels and repeated prompts at the moment someone cancels, and send a confirmation.
6. Add the withdrawal function where it applies. For consumer contracts concluded online, add the “withdraw from contract here” function and the “confirm withdrawal” step that Article 11a describes.
7. Re-scan. Run a scan again. The finding should clear once the renewal sentence and a reachable cancellation route are on the public pages.

Whether a given wording satisfies a particular authority is a question for your legal adviser, and Peeky reports only what it sees.