Dating App Subscriptions: The New Rules on Renewal and Cancellation in 2026
UK, US, EU and Australian rules on dating app sign-up, renewal and cancellation as of October 2026, with the Match and eharmony cases and a checklist.

As of 17 October 2026, dating apps that sell auto-renewing memberships face a tightening set of subscription rules in their three largest English-speaking markets. The UK's subscription contracts regime under the Digital Markets, Competition and Consumers Act 2024 is due in January 2027, Australia's ban on subscription traps follows on 1 July 2027, and in the United States the FTC is rebuilding a cancellation rule that a federal appeals court struck down in July 2025. Two dating operators have already been on the receiving end: Match Group agreed a $14 million FTC settlement in August 2025, and an Australian court found in August 2026 that eharmony misled users about automatic renewal.
Executive summary
Key findings
- The UK start date has moved forward to January 2027. The government said on 9 August 2026 that the DMCC Act subscription rules "will now come into force in January 2027", earlier than the spring 2027 date it had set in April (GOV.UK, 9 August 2026). The secondary legislation that sets the detail had not been published by mid-September (Brodies, 14 September 2026).
- The CMA can already fine for subscription conduct. Since 6 April 2025 (HSF Kramer) the CMA can decide infringements itself and impose penalties of up to £300,000 or 10% of turnover, whichever is higher (DMCC Act, s.182). It opened a subscription case against Microsoft on 27 July 2026 under existing law (CMA).
- The US federal cancellation rule is gone, but ROSCA is not. The Eighth Circuit vacated the FTC's amended Negative Option Rule on 8 July 2025. The FTC began a new rulemaking with an advance notice published on 13 March 2026 (Federal Register), and continues to bring cases under the Restore Online Shoppers' Confidence Act.
- Match Group's order covers 14 brands, not Tinder or Hinge. The proposed order in FTC v Match Group requires a "simple mechanism" to stop recurring charges on services including Match.com, OkCupid and Plenty of Fish. Tinder and Hinge do not appear in it (FTC proposed order).
- Australia has the first court ruling against a dating app's renewal model. The Federal Court found eharmony misled consumers in six ways, including automatic renewal into a 12-month term at prices the ACCC says could be up to five times the starting price (ACCC, 25 August 2026). eharmony intends to seek leave to appeal some findings; no penalty has been set.
- California already requires a "click to cancel" button beside save offers. Since 1 July 2025, California's amended automatic renewal law requires express consent to renewal terms, an annual reminder for annual plans and a continuously visible cancel link whenever a retention offer is shown online (Latham & Watkins, October 2024).
- The common standard is converging. Across all four jurisdictions, the test is the same in substance: show the renewal price, term and total cost before payment, remind before renewal, and let a user who joined online leave online without obstruction.
Why dating apps are exposed
Introductory prices that step up on renewal, long minimum terms sold at a monthly equivalent price, free tiers that require payment to message, and retention offers in the cancellation flow are common dating conversion tools. The eharmony judgment and the FTC's Match Group case both turned on them.
The scale of the wider problem is what is driving governments. The UK government estimates there are about 155 million active subscriptions in the UK, costing consumers around £26 billion a year, and that about £1.6 billion a year is spent on subscriptions people do not want (UK Parliament written statement HLWS1503, 13 April 2026). These figures cover all sectors; no regulator has published a dating-specific estimate.
Most large dating apps also sell through Apple's App Store and Google Play, where the platform handles billing and cancellation. The UK and Australian rules attach duties to the trader that supplies the subscription, and none of the sources reviewed for this report suggests an exemption where an app store processes the payment. How in-app billing will be treated in detail is not settled in the UK: the government's April 2026 consultation response does not address app stores (GOV.UK, 2 April 2026).
The UK subscription contracts regime
What the Act requires
The rules are in Part 4, Chapter 2 of the Digital Markets, Competition and Consumers Act 2024, sections 253 to 281. Most of the chapter is not yet in force. The core duties are:
- Pre-contract information. Section 256 requires the trader to give "key pre-contract information" listed in Schedule 23, all together and separately from the full terms and any other information (s.256). According to Ashurst, Schedule 23 lists 11 items, including that the contract continues until the consumer acts to end it, any minimum term, whether later payments may be higher, the minimum total amount payable and the steps needed to end the contract (Ashurst, 7 May 2026).
- Reminder notices. Section 258 requires a reminder before renewal payments. For a contract with no introductory period, a reminder is due for the renewal payment linked to each six-month period. For a contract with a free or discounted introductory period, a reminder is also due before the first renewal payment (s.258). Timing and content are set by section 259 and regulations.
- Ending the contract. Section 260 requires arrangements that let a consumer end the contract "in a way which is straightforward" without steps "not reasonably necessary". A contract entered into online must be capable of being ended online, and instructions must be shown where a consumer is likely to look for them (s.260).
- Cooling-off. Sections 264 and 265 create an initial cooling-off period and a renewal cooling-off period. The government confirmed the renewal period will be 14 days after a free trial ends or a contract of 12 months or more auto-renews (GOV.UK, 2 April 2026).
What the April 2026 consultation response decided
The Department for Business and Trade published its response to the implementation consultation on 2 April 2026. Points that bear directly on dating apps:
- Digital content refunds. The existing waiver of the initial 14-day cooling-off right for digital content is kept. On a renewal cooling-off cancellation, the consumer receives a proportionate refund (GOV.UK). For a dating app, that means a user whose trial converts or whose annual plan renews can cancel within 14 days and receive back the unused portion.
- Retention offers. Traders may make offers or ask for feedback during cancellation, but these must not "frustrate or unreasonably elongate the process". Detail will come in guidance.
- Online exit. Consumers who sign up online must be able to exit online. Reed Smith reads the response as meaning email alone is not sufficient and cancelling a Direct Debit does not count (Reed Smith, 9 April 2026).
- Notices. Reminder and cooling-off notices must be in writing on a durable medium, and their purpose must be immediately apparent.
- Consequences. If a trader fails to tell consumers about cooling-off rights, the cooling-off period runs until 14 days after the breach is corrected, up to 12 months. A list of specified breaches, such as a missed reminder, will trigger refunds (HLWS1503).
The commencement date
The date has moved twice. Osborne Clarke records that the regime was first expected in autumn 2026, then delayed to spring 2027 (Osborne Clarke, September 2026). The April 2026 response said the government anticipated commencement "in spring 2027" and would legislate "when parliamentary time allows". On 9 August 2026 the Prime Minister's Office announced: "New rules will now come into force in January 2027" (GOV.UK).
Two points remain open. First, the implementing regulations had not been published as of mid-September; Brodies expects them to be made under the negative procedure, with a draft around 30 days before the enforcement date (Brodies). Second, transitional treatment of existing subscribers is not final. Farrer & Co states the regime applies only to contracts entered into after commencement (Farrer & Co, 7 October 2026); Latham & Watkins says it is "expected to apply primarily" to contracts from January 2027, with the position on renewals of earlier contracts depending on final transitional provisions (Latham & Watkins, 14 September 2026). Operators should not assume existing subscribers are out of scope.
CMA enforcement before and after January 2027
Direct enforcement powers
The UK's new consumer protection regime came into force on 6 April 2025 (HSF Kramer, 7 April 2025). The CMA no longer needs a court to find a breach. Under section 182 of the Act, a final infringement notice can impose a penalty "not exceeding £300,000 or, if higher, 10% of the total value of the turnover" of the business (s.182), which Latham & Watkins describes as up to 10% of global annual turnover.
The subscription regime will be enforceable through the same powers once it commences. Until then, subscription practices are judged under the Act's general prohibitions on misleading actions, misleading omissions and aggressive practices, explained in the CMA's unfair commercial practices guidance (CMA207), published on 4 April 2025 and updated on 18 November 2025.
Online choice architecture and drip pricing
The CMA's thinking on design is set out in two papers from its Behavioural Hub published on 5 April 2022, a discussion paper and an evidence review covering 21 online choice architecture practices and their links to "dark patterns" (CMA, 5 April 2022).
Drip pricing, where mandatory charges are left out of the headline price, was the focus of the CMA's first enforcement drive under the new powers. On 21 November 2025 it issued final price transparency guidance, said it had reviewed more than 400 businesses in 19 sectors, sent advisory letters to 100 and opened eight investigations (SCL, 21 November 2025). On 15 April 2026 it fined Automobile Association Developments Limited £4.2 million, after a 40% settlement reduction, over booking fees presented outside the headline price (CMA case page). Osborne Clarke reported in September 2026 that the CMA had opened three further drip pricing investigations, into Trainline, a package holiday business and RED Driving School (Osborne Clarke).
The Microsoft case
The CMA is already testing subscription conduct under existing law. On 27 July 2026 it opened an investigation into whether Microsoft Ireland Operations Limited gave customers clear information about Microsoft 365 Personal and Family plan options when the plans changed, including the addition of Copilot, and whether pre-renewal communications were misleading (CMA case page). The CMA says it should not be assumed that Microsoft has broken the law. Its next update is due by the end of 2026.
United States: after Click-to-Cancel
The vacated rule and the new rulemaking
The FTC issued its amended Negative Option Rule, known as Click-to-Cancel, on 16 October 2024. On 8 July 2025, days before its main compliance date of 14 July, the US Court of Appeals for the Eighth Circuit vacated it in Custom Communications, Inc. v. FTC, 142 F.4th 1060, holding that the FTC had not carried out the preliminary regulatory analysis required by section 22 of the FTC Act (Federal Register; Latham & Watkins). The court said it did "not endorse the use of unfair and deceptive practices in negative option marketing" but that the procedural defects were fatal (Fenwick, 10 July 2025).
The FTC restarted on 11 March 2026 with an advance notice of proposed rulemaking (FTC, 11 March 2026), published in the Federal Register on 13 March with comments due by 13 April 2026. It asks whether to keep the 1973 rule, adopt parts of the vacated rule or take narrower steps, and requests data on how long enrolment and cancellation take and on the use of "save" offers (Covington, March 2026). Jones Day counted about 100 comments and described a new rule as "likely on the horizon" (Jones Day, May 2026). An advance notice is only the first stage of rulemaking.
What still binds: ROSCA
The Restore Online Shoppers' Confidence Act requires sellers of online negative option plans to disclose all material terms clearly before taking billing information, obtain express informed consent and provide a simple way to stop recurring charges (Gibson Dunn, March 2026). The FTC has kept using it. Its cases since the vacatur include a settlement with Chegg on 15 September 2025 providing $7.5 million in consumer redress, and an amended complaint against Uber filed on 15 December 2025 with 21 states and the District of Columbia, alleging that cancelling Uber One could take as many as 23 screens and 32 actions (Goodwin, February 2026). The Uber allegations are unproven.
FTC v Match Group
The case most relevant to dating began on 25 September 2019, when the FTC sued Match Group in the Northern District of Texas (FTC case page). Alongside allegations about advertisements built on messages from suspected fraudulent accounts, the complaint alleged a cancellation process that required users to find the cancellation tab, enter their password, pass a retention offer and click through two pages of survey questions (FTC complaint, 2019). It quoted a 2015 internal Match presentation describing the process as "hard to find, tedious, and confusing", and alleged a breach of section 4 of ROSCA.
On 12 August 2025 the FTC announced that Match Group had agreed to pay $14 million and stop the practices (FTC, 12 August 2025). The proposed order (FTC):
- bars Match from failing to provide simple mechanisms for consumers to stop recurring charges on any covered service with a negative option feature (Section III);
- requires clear disclosure of the conditions of any "six-month guarantee" (Section II);
- bars retaliation against consumers who file billing disputes, while allowing suspension of service while a dispute is pending (Section IV);
- imposes a $14,000,000 monetary judgment (Section V) and 10 years of recordkeeping.
Match neither admitted nor denied the allegations. The order defines covered services as those operated under 14 trade names, including Match.com, OkCupid, Plenty of Fish, OurTime, BLK, Chispa, The League, HER and Archer, and continues to apply if those platforms change names. Tinder and Hinge are not named. The FTC's case page listed the case as pending and showed the order as proposed when DII checked in October 2026; DII could not confirm from the FTC site the date the court entered it.
State automatic renewal laws
State law is now where the most prescriptive US requirements sit. California's AB 2863, signed on 24 September 2024, applies to contracts entered into, amended or extended on or after 1 July 2025 (Latham & Watkins). It requires:
- express affirmative consent specifically to the automatic renewal terms, with proof kept for three years (or one year after termination, if longer);
- an annual reminder for annual-term plans, stating the product, the frequency of charges and how to cancel;
- where a retention offer is shown online, a prominent, continuously visible "click to cancel" link or button shown at the same time, and cancellation "without obstruction or delay" once used;
- notice of a price change at least seven and no more than 30 days before it takes effect, with cancellation instructions.
New York has amended its own automatic renewal law to add consent, cancellation and disclosure requirements, according to Latham & Watkins; DII could not access the statutory text to confirm the amendment's details or commencement date during this research. New York Attorney General Letitia James publicly backed the federal rule on the day it was vacated, saying New Yorkers "should never have to jump through hoops just to cancel an unwanted subscription" (New York Attorney General, 8 July 2025). Fenwick notes a Massachusetts rule effective 2 September 2025 modelled on the FTC's junk fees and click-to-cancel rules. The 21 states that joined the FTC's amended Uber complaint show that state attorneys general are prepared to act jointly on cancellation design.
European Union
The EU has no subscription-specific regime yet, but one new rule already applies to dating apps. Directive (EU) 2023/2673 inserted Article 11a into the Consumer Rights Directive, requiring a "withdraw from contract here" function, or equivalent wording, for distance contracts concluded through an online interface. The function must be continuously available during the withdrawal period, followed by a "confirm withdrawal" step and an acknowledgement on a durable medium. Member states had to transpose it by 19 December 2025 and apply it from 19 June 2026, and recital 37 confirms it is not limited to financial services (EUR-Lex).
The Digital Fairness Act is the European Commission's planned response to dark patterns, subscription traps and related practices. Ashurst reported in May 2026 that the Commission had recently closed its public consultation, and that the proposal aims, among other things, to prohibit subscription and cancellation "traps" (Ashurst). DII could not access the Commission's initiative page during this research and has not confirmed whether a legislative proposal had been adopted by 17 October 2026. Any proposal would still need agreement by the Parliament and Council.
Australia: the eharmony judgment and a new ban
The ACCC sued eharmony, which it described as part of ParshipMeet Group, on 7 September 2023, alleging conduct dating back to at least November 2019, including charging monthly payers $3 more than advertised (ACCC, 7 September 2023). On 25 August 2026 the Federal Court found eharmony had engaged in misleading conduct in six areas (ACCC, 25 August 2026):
- offering "free" dating when users could not communicate without paying;
- automatic renewal of memberships;
- advertising one-month memberships when the shortest term available was six months;
- telling consumers they could cancel early when they could not;
- advertising monthly prices without disclosing a mandatory additional monthly fee;
- failing to show a single minimum total price alongside the monthly figure.
According to the ACCC, members chose 6, 12 or 24-month plans that renewed automatically for a 12-month lock-in, at renewal prices that could be up to five times the initial price. The court found changes made from July 2024 cured the monthly payment misrepresentation. ACCC Commissioner Luke Woodward said the regulator "is concerned about subscription traps in digital services".
On formal declarations made in ACCC v eHarmony, Inc (No 2) [2026] FCA 1445, eharmony said it intended to seek leave to appeal "some, but not all" of the liability findings. The case returns for case management no earlier than 28 days after the declarations, and the court said the penalty stage was "likely to be multifaceted and not necessarily quick or straightforward" (Australasian Lawyer, 5 October 2026). DII's coverage of the declarations is here.
For a sense of penalty levels, the Federal Court ordered JustAnswer to pay A$10 million on 8 July 2026 after its chat widget offered to sign consumers up "for only AU$2 (fully refundable)" when they were in fact joining a subscription of A$45 to A$75 a month (ACCC, 8 July 2026).
Australia will then have specific rules. The Competition and Consumer Amendment (Unfair Trading Practices) Bill 2026 passed Parliament on 2 July 2026 and takes effect on 1 July 2027 (Assistant Minister Andrew Leigh, 2 July 2026). DLA Piper summarises the subscription provisions: suppliers must say an offer is a subscription and explain payments, term, renewal, notice periods and how to cancel, close to where the consumer agrees; cancellation methods must be easy to find and limited to reasonably necessary steps; at least one method must be online where sign-up is online; and practices that unreasonably hinder cancellation are unlawful (DLA Piper, 20 July 2026).
What the public record shows about dating operators
DII set out to compare how Tinder, Hinge, Bumble, Grindr, OkCupid and Feeld describe sign-up, renewal and cancellation on their own help-centre and terms pages. Those pages could not be retrieved during this research session, and DII does not report their content from memory or from third-party summaries. That comparison will be added in an update to this report. The table below sets out instead what regulator and court documents establish about named dating operators as of October 2026.
| Operator / brands | Regulator and status | Subscription conduct at issue | Outcome so far |
|---|---|---|---|
| Match Group: Match.com, OkCupid, Plenty of Fish and 11 other named brands | US FTC; complaint filed 25 September 2019, settlement announced 12 August 2025 | Alleged cancellation flow requiring password, retention offer and two pages of survey questions; guarantee terms; account suspension after billing disputes | $14 million; proposed order requires a simple mechanism to stop recurring charges; no admission of liability |
| Match Group: Tinder, Hinge | Not named in the FTC order's list of covered trade names | None in the FTC documents reviewed | Not applicable |
| eharmony | ACCC, Federal Court of Australia; liability judgment 25 August 2026, declarations [2026] FCA 1445 | Auto-renewal into 12-month terms; "free" claims; early-cancellation claims; undisclosed monthly fee; no total price | Six categories of misleading conduct found; eharmony to seek leave to appeal some findings; penalty not yet set |
| Bumble, Grindr, Feeld | None of the regulator documents reviewed for this report concerns their subscription practices | Not applicable | Not applicable |
Source: FTC complaint (2019), FTC press release and proposed order (August 2025), FTC case page; ACCC media releases (7 September 2023, 25 August 2026); Australasian Lawyer (5 October 2026). Compiled by DII, October 2026.
The FTC's Match order is narrower in brand coverage than is often reported, and its cancellation requirement is the ROSCA standard of a "simple mechanism" rather than a specific click-to-cancel design. The eharmony findings, by contrast, concern presentation at the point of sale as much as cancellation: the total minimum price, the renewal term and the meaning of "free".
What it means for operators
The four regimes differ in form, but the practical requirements overlap enough for one compliant flow to serve all of them. An operator selling in the UK, US, EU and Australia should design to the strictest element of each. The checklist below maps each requirement to its source.
| Area | What to do | Where it comes from |
|---|---|---|
| Price at checkout | Show the total minimum amount payable for multi-month plans next to any monthly equivalent, including any mandatory fees | UK Sch. 23 key information; CMA price transparency guidance; eharmony findings |
| Renewal terms | State before payment that the plan renews, for how long and at what price, and whether later payments may be higher | UK s.256; ROSCA disclosure; Australia UTP law; eharmony findings |
| Consent | Obtain separate, express consent to the auto-renewal terms and keep a record for at least three years | California AB 2863; ROSCA express informed consent |
| "Free" tiers | Do not describe a tier as free if core functions, such as messaging, require payment | eharmony findings |
| Reminders | Send a written reminder before a trial or introductory price ends, before each renewal of a 12-month plan and at least every six months; annual reminder for annual plans in California | UK s.258 and consultation response; California AB 2863 |
| Price changes | Give notice 7 to 30 days before a price change takes effect, with cancellation instructions | California AB 2863 |
| Online cancellation | Let users who joined online cancel online, with instructions where they will look; email alone is not enough in the UK | UK s.260; Australia UTP law; ROSCA simple mechanism |
| Retention offers | Keep save offers short, show a visible cancel button alongside them, and never make the offer a required step | California AB 2863; UK consultation response |
| Renewal cooling-off | Allow cancellation within 14 days after a trial converts or a 12-month plan renews, with a proportionate refund | UK renewal cooling-off period |
| EU withdrawal | Provide a "withdraw from contract here" function during the withdrawal period with confirmation and acknowledgement | CRD Article 11a, applies from 19 June 2026 |
| Billing disputes | Do not lock or penalise accounts because a user disputed a charge | FTC v Match order, Section IV |
| App-store billing | Map which duties the app store performs and which remain with you; give in-app instructions for store-billed users | No app-store exemption identified in the sources reviewed |
Source: DMCC Act 2024 ss.256, 258, 260; GOV.UK consultation response (2 April 2026); California AB 2863 as summarised by Latham & Watkins; ROSCA as summarised by Gibson Dunn; Directive (EU) 2023/2673; ACCC (25 August 2026); DLA Piper (20 July 2026); FTC proposed order (August 2025). DII analysis.
Two further points matter. First, the UK timetable is short. If the regulations follow Brodies' expectation of a draft about 30 days before commencement, operators will have weeks, not months, to read the final detail. The statute itself is fixed, so build to it now.
Second, enforcement does not wait for the new regimes. The CMA is using existing law against subscription communications (Microsoft), the FTC is using ROSCA, and the eharmony case was brought under general Australian Consumer Law. A renewal model that would fail the new rules is already at risk under the old ones.
What to watch
- Late 2026: UK draft regulations. The secondary legislation setting reminder timing, cancellation detail and transitional treatment. DBT has also committed to business guidance.
- By end of 2026: CMA update on Microsoft. The CMA's case page says the next update is due by the end of 2026. Any finding on pre-renewal communications will set an early marker.
- From late 2026: eharmony case management. The case returns no earlier than 28 days after the declarations, which were reported in early October 2026. Watch whether leave to appeal is granted and which findings are challenged.
- January 2027: UK subscription regime commences, as announced on 9 August 2026.
- Undated: FTC proposed rule. The FTC has not set a public date for the next stage after the March 2026 advance notice.
- Undated: EU Digital Fairness Act proposal. Watch for the Commission's legislative proposal and its treatment of subscriptions.
- 1 July 2027: Australia's unfair trading practices ban takes effect.
Methodology
This report was researched in October 2026. Legal provisions were read on legislation.gov.uk, EUR-Lex and the Federal Register. Regulator positions were taken from GOV.UK, CMA case pages, the FTC, the ACCC and the Australian Treasury. Where the primary text could not be accessed (California AB 2863, the New York amendment, Schedule 23 of the DMCC Act, the EU Digital Fairness Act initiative page), DII relied on law firm analyses, which are named in the text. The account of FTC v Match Group is drawn from the FTC's complaint, press release, case page and proposed order.
Limitations: the planned comparison of dating app help-centre and terms pages could not be completed because those pages could not be retrieved during the research session; it will be added in an update. DII could not confirm whether the EU Digital Fairness Act proposal had been adopted by 17 October 2026, the details of New York's amended automatic renewal law, or the date the court entered the Match Group order. Statements about what regulators have not done refer only to the documents reviewed. Allegations in pending cases are unproven. This report is analysis, not legal advice.
Sources
- GOV.UK: PM starts roll out of everyday fixes on the cost of living, ending rip-off discounts and subscription traps (9 August 2026)
- GOV.UK: Government response to consultation on the implementation of the new subscription contracts regime (2 April 2026)
- UK Parliament: Written statement HLWS1503, Subscriptions: Government Response to the Implementation Consultation (13 April 2026)
- legislation.gov.uk: Digital Markets, Competition and Consumers Act 2024, Part 4 Chapter 2
- legislation.gov.uk: DMCC Act 2024, section 256, Pre-contract information
- legislation.gov.uk: DMCC Act 2024, section 258, Reminder notices
- legislation.gov.uk: DMCC Act 2024, section 260, Arrangements for consumers to exercise right to end contract
- legislation.gov.uk: DMCC Act 2024, section 182, Final infringement notice
- Brodies via Legal 500: The DMCCA: Subscription Contracts, the timeline just got shorter (14 September 2026)
- Latham & Watkins: New Requirements Accelerated for UK Consumer Subscription Contracts (14 September 2026)
- Farrer & Co: UK consumer law update, autumn 2026 (7 October 2026)
- Osborne Clarke: Regulatory Outlook, consumer law (September 2026)
- Reed Smith: DMCC subscription rules delayed to spring 2027, key takeaways from the consultation response (9 April 2026)
- Ashurst: Click, subscribe, comply: preparing for the UK's new subscription contract regime (7 May 2026)
- HSF Kramer: Enhanced UK consumer protection regime takes effect (7 April 2025)
- CMA: Direct consumer enforcement guidance, CMA200 (14 March 2025, updated 4 April 2025)
- CMA: Unfair commercial practices guidance, CMA207 (4 April 2025, updated 18 November 2025)
- CMA: Online choice architecture, how digital design can harm competition and consumers (5 April 2022)
- Society for Computers and Law: CMA issues final price transparency guidance and launches first investigations under DMCC Act (21 November 2025)
- CMA: Automobile Association Developments Limited consumer protection enforcement case (15 April 2026)
- CMA: Microsoft consumer protection enforcement case (opened 27 July 2026)
- Federal Register: Rule Concerning the Use of Prenotification Negative Option Plans, advance notice of proposed rulemaking (13 March 2026)
- FTC: FTC seeks public comment in response to advance notice of proposed rulemaking regarding Negative Option Rule (11 March 2026)
- Covington: FTC launches new rulemaking on the Negative Option Rule (March 2026)
- Fenwick: Eighth Circuit vacates FTC's Click-to-Cancel Rule (10 July 2025)
- Latham & Watkins: Eighth Circuit vacates FTC Click-to-Cancel Rule (July 2025)
- Gibson Dunn: FTC restarts Negative Option rulemaking after Eighth Circuit vacatur; enforcement under ROSCA continues (March 2026)
- Goodwin: FTC's Click-to-Cancel Rule gets new life as FTC's enforcement wave continues (February 2026)
- Jones Day: FTC revives Click-to-Cancel Rule, new risks for subscription businesses (May 2026)
- FTC: Match Group agrees to pay $14 million, permanently stop deceptive advertising, cancellation and billing practices (12 August 2025)
- FTC: Match Group, Inc. case page, matter 172 3013 (accessed October 2026)
- FTC: Proposed order for permanent injunction, monetary judgment and other relief, FTC v Match Group (August 2025)
- FTC: Complaint, FTC v Match Group, Inc., N.D. Tex. 3:19-cv-02281 (25 September 2019)
- Latham & Watkins: In California, new automatic renewal and continuous service requirements signed into law (October 2024)
- New York Attorney General: Attorney General James urges New Yorkers to take advantage of new click-to-cancel rule (8 July 2025)
- EUR-Lex: Directive (EU) 2023/2673 amending Directive 2011/83/EU (22 November 2023)
- ACCC: ACCC court action against eHarmony for alleged misleading online dating membership statements (7 September 2023)
- ACCC: Court finds eHarmony engaged in misleading conduct in relation to automatic renewal and pricing of its subscriptions (25 August 2026)
- Australasian Lawyer: Federal Court declares eHarmony breached Australian Consumer Law (5 October 2026)
- ACCC: JustAnswer to pay $10m in penalties for misleading pricing representations and misleading affiliation claims (8 July 2026)
- Assistant Minister Andrew Leigh: Unfair trading tricks and traps to be banned (2 July 2026)
- DLA Piper: Australia introduces new unfair trading practices laws (20 July 2026)
Questions readers ask
When do the UK DMCC Act subscription rules come into force?+
The government announced on 9 August 2026 that the subscription contracts regime will come into force in January 2027, earlier than the spring 2027 date set in its April 2026 consultation response. The detailed rules depend on secondary legislation, which had not been published by mid-September 2026. Transitional treatment of subscriptions taken out before commencement has not been finalised.
What will the UK subscription rules require from dating apps?+
Dating apps will have to give key pre-contract information separately from the full terms, send written reminders before renewals and before a trial or introductory price ends, let users who joined online cancel online in a straightforward way, and allow a 14-day renewal cooling-off period after a trial converts or a 12-month plan renews, with a proportionate refund.
Is the FTC click-to-cancel rule still in effect?+
No. The Eighth Circuit vacated the FTC's amended Negative Option Rule on 8 July 2025 in Custom Communications v FTC, finding the FTC had skipped a required preliminary regulatory analysis. The FTC restarted rulemaking with an advance notice published on 13 March 2026. The Restore Online Shoppers' Confidence Act and state laws such as California's still apply.
What did Match Group agree in its 2025 FTC settlement?+
Match Group agreed on 12 August 2025 to pay $14 million to resolve FTC charges filed in 2019. The proposed order requires simple mechanisms to stop recurring charges, clear disclosure of guarantee terms and no retaliation against users who dispute charges. It covers 14 named brands including Match.com, OkCupid and Plenty of Fish, but not Tinder or Hinge. Match neither admitted nor denied the allegations.
What did the Australian court find against eharmony?+
On 25 August 2026 the Federal Court found eharmony misled consumers in six ways, including automatic renewal into 12-month terms, advertising free dating when users could not communicate without paying, implying early cancellation, and not showing the minimum total price. eharmony intends to seek leave to appeal some findings. Penalties have not yet been set.
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