The DMCC Act isn't just for big retailers and tech platforms - here's what membership organisations need to know

Whether you’re a professional body, trade association, chartered institute or commercial membership organisation, this Act will change how you interact with members, how you sell services, how you communicate value - and, crucially, how you govern.  

The DMCC Act (Digital Markets, Competition and Consumers Act) probably didn’t cause much of a stir for many when it passed last year. But while much of the commentary has focused on tech platforms and big digital retailers, if you’re running a membership organisation - particularly one that offers rolling subscriptions or annual auto-renewals, which most do - it’s time to look again. 

Whether you’re a professional body, trade association, chartered institute or commercial membership organisation, this Act will change how you interact with members, how you sell services, how you communicate value - and, crucially, how you govern.  

The days of relying on legacy processes and lightly-polished T&Cs are numbered! 

What is the DMCC Act, in plain English? 

The DMCC Act is wide-ranging. It brings together reforms across digital markets, consumer rights, and competition enforcement into a single, integrated regime. 

It has three main pillars: 

1. Digital Markets Regulation 

Giving the Competition and Markets Authority (CMA) new powers to designate firms as having “Strategic Market Status” and impose conduct requirements, including the power to fine businesses up to 10% of global turnover for breaches of consumer law, without going through the courts. 

2. Consumer Protection Reform 

Updating and replacing older regulations like the Consumer Protection from Unfair Trading Regulations 2008. The DMCC Act is tightening rules around misleading practices, hidden charges, fake reviews, aggressive selling, and subscriptions. These changes apply to all organisations selling goods, services, or digital content to consumers - including membership bodies. 

3. Competition Law 

A number of Changes to the current Competition Act, including increasing existing merger thresholds and strengthening the CMA's investigatory and fining powers in this area. 

What does the DMCC Act means for membership organisations? 

For the membership sector, the biggest challenges will be around how subscriptions are managed, how marketing is framed, how member communications are handled, and how risk is governed. 

Here’s where things start to bite:

1. Subscription models are under the microscope

If your organisation relies on subscriptions (monthly, annual, auto-renewing or trial-based) the DMCC Act introduces very specific rules about how these must work. 

From April 2026, when the subscription-specific rules are expected to come into force, you’ll need to: 

    • Provide clear, upfront information about the subscription, including renewal terms, price changes, and cancellation options 
    • Send timely reminders before a free trial ends or a renewal takes effect 
    • Offer a cooling-off period of 14 days - both at the start and after certain renewals 
    • Allow members to cancel as easily as they signed up (i.e. if they joined online, they should be able to leave online) 
    • Issue refunds where required, including for digital content and hybrid offers (e.g. physical + online member benefits) 

None of this is optional. The Act explicitly empowers regulators to pursue any organisation offering subscription-based services to consumers, including those in the membership sector. 

That means everyone from professional bodies, trade associations, learned societies, institutes, regulators and commercial membership outfits all need to take note.

2. Misleading or incomplete claims carry more risk

Under the Act, unfair commercial practices are more tightly defined and more easily enforced. 

This includes: 

    • Exaggerated or vague benefit statements ("industry-leading", "only provider of X", "fully accredited") 
    • Missing or unclear pricing information 
    • Overstated impact or social value claims without evidence 
    • Using trust marks or logos without appropriate permissions 

So if you’re positioning your membership as “carbon neutral” or “the only CPD-accredited provider”,  you’ll need to back that up with specifics. Plus, if you advertise discounts or limited-time offers, they must be genuine. 

The Act also introduces the concept of professional diligence, meaning organisations are expected to behave as a reasonably competent operator in their field would. That sets a high bar for how marketing and member comms are governed!

3. Cancellation must be simple and fair

One of the most common complaints in the membership sector is difficulty cancelling. Legacy systems, awkward processes and delays are all too familiar. But the DMCC Act now sets legal minimum standards for how members must be allowed to leave. 

    • No more hiding cancellation options in footnotes or PDF forms 
    • No more “call us to cancel” if the sign-up process is digital 
    • No more silence before an auto-renewal 

This shift aligns with what modern members increasingly expect anyway. But now, it’s also enforceable.

4. Governance teams must take the lead

This is where the governance function becomes central and not just peripheral. 

Boards, company secretaries, risk officers and heads of compliance need to understand this legislation and build it into how the organisation operates, not just within legal checklists. 

Because the CMA can now act directly, including issuing fines, naming organisations publicly, or demanding compliance plans without court proceedings. That’s a reputational risk as well as a regulatory one. 

In membership organisations, governance professionals often sit at the intersection of policy, operations and accountability, and are best placed to coordinate the necessary response. 

Here are some key questions that governance teams should be asking now: 

    • Have we reviewed our subscription terms, trials, and renewals in light of the Act? 
    • Do our systems support compliant processes (e.g. reminders, easy exits)? 
    • Are marketing and member services aligned on what can and can’t be claimed? 
    • Is the board aware of the reputational and financial risks? 
    • Where do we need to engage external support? Legal, digital, or CRM? 

At its heart, the DMCC Act is about building fairer, more transparent relationships between organisations and individuals. 

For membership organisations, that should feel familiar. Many already pride themselves on putting members first, and on offering clear, ethical services. 

This legislation raises the bar but it also offers a chance to prove that those values aren’t just window dressing. It can help show that they’re reflected in how systems work, how terms are written, how easy it is to leave, and how fairly people are treated when they do. 

Building a brilliant governance team 

The DMCC Act isn’t something governance professionals can just read up on and carry on as usual. It demands real-world implementation, cross-department coordination, and the ability to spot risk early - and that takes the right people, in the right roles, with the right experience. 

For many membership organisations, that means reviewing not just your contracts and CRM systems, but your governance capability. 

If your team doesn’t have the capacity or capability to lead that work confidently, now’s the time to address it. Whether it’s strengthening your secretariat, bringing in compliance expertise, or reshaping your governance function, getting the right people in place is critical. 

Here’s what to consider: 

    1. Do you have governance professionals who understand compliance and operations? 
    2. Is your board or leadership team getting the right insight? 
    3. Are your secretariat and compliance teams resourced to deliver? 
    4. Do you need to upskill, restructure, or recruit? 

The bottom line 

The DMCC Act is a legal shake up you really can’t afford to ignore. It’s about how you govern more than just avoiding fines or updating Ts & Cs. You can have the right values, the right policies - even the right tech - but without the right people in place to lead, interpret and implement these changes, you’re still exposed. 

Strong governance is now a front-line defence, not just against compliance risk, but to protect member trust, reputation and long-term value. And while capable governance will be key to managing this risk, it can’t carry the whole load. 

Making sure your membership organisation is ready will mean having the right mix of roles and expertise in place across your whole structure, including: 

    • A legal or compliance professional who understands the DMCC Act’s implications 
    • A CRM or digital lead who can align systems with the new subscription and cancellation rules 
    • A comms or marketing head who will be able to translate compliance into member-friendly language 
    • A data analyst or finance professional who can help support evidence-based decisions 
    • And ideally, a COO or CEO who will champion change from the top – a trustee with experience in consumer law or digital regulation would also be a significant advantage 

If you need to strengthen your team, whether that’s reviewing your current workforce, bringing in new skills, or finding someone who can bridge key aspects of the Act, Membership Bespoke is here to help. Get in touch today for a no obligation consultation with our specialists - no pressure, just honest advice.