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.
Regardless of whether you are a professional body, trade association, chartered institute, or commercial membership organisation, this Act fundamentally reshapes your approach to member engagement, service delivery, value communication - and, most importantly, governance.
The days of relying on legacy processes and lightly-polished T&Cs are numbered!
The DMCC Act is wide-ranging. It brings together reforms across digital markets, consumer rights, and competition enforcement into a single, integrated regime.
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.
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.
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.
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:
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.
Under the Act, unfair commercial practices are more tightly defined and more easily enforced.
This includes:
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!
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.
This shift aligns with what modern members increasingly expect anyway. But now, it’s also enforceable.
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:
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.
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:
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:
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.