The PPA is pleased to observe that the Government has accepted our recommendation on implementation timelines. The new regime will be introduced with a 12-month implementation period, following engagement earlier this year between PPA representatives and ministers.

This additional time will be critical in supporting publishers to make the necessary operational and compliance adjustments.

However, there are areas of concern. On cooling-off periods for digital services, the Government has opted for “option 2”. While this maintains the exemption from refund requirements during the initial cooling-off period for digital services, it removes the “use it and lose it” principle for renewal cooling-off periods.

In practice, this means that publishers will now be required to provide pro-rata refunds where a consumer cancels a digital service during a cooling-off period at the end of a trial or discounted period, or following an annual renewal.

The Government recognises that this creates potential risks for publishers producing seasonal or high-value digital content. In particular, there is a concern that consumers may access or download content shortly after renewal and then seek a refund within the 14-day cooling-off window.

Sajeeda Merali, CEO, PPA commented:

“The Government’s update on subscription models under the Digital Markets, Competition and Consumers Act is a welcome step forward after a lengthy delay. We are particularly pleased that the PPA’s engagement has led ministers to confirm a 12-month implementation period, giving publishers the necessary time to adapt and ensure full compliance.

Subscriptions are one of the most important and fastest-growing revenue streams for publishers, enabling a direct relationship with audiences without reliance on intermediaries. This model underpins the continued investment in high-quality, trusted editorial content and the communities these brands serve.

However, we are disappointed by the decision on renewal cooling-off periods for digital services. Retaining refund requirements at this stage leaves publishers commercially exposed, particularly where audiences can access time-sensitive, high-value content, such as major cultural moments like London Fashion Week or in-depth B2B industry reports, before cancelling and claiming a refund. In these cases, publishers have already incurred the full cost of creating that content, making them especially vulnerable to churn.

This presents a real challenge for publisher brands that are investing in premium digital products and subscription growth, and risks undermining a model that supports sustainable, independent publishing.

The PPA will continue to work constructively with government and partners across the creative industries to ensure the final framework strikes the right balance between consumer protection and a commercially viable future for publishers.”

The PPA has already raised concerns with Government officials and is arranging further engagement. In parallel, we are working with partners across streaming, gaming, and news sectors to coordinate a strategic response.

You can read the Government’s full statement here.

If you have any questions or would like to discuss the implications further, please do get in touch with eilidh.wilson@ppa.co.uk