Anti-virus software: compliance principles when using auto-renewing contracts
Practical advice for anti-virus software businesses that use auto-renewing contracts in the UK.
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This guidance was published prior to the unfair commercial practices provisions of the Digital Markets, Competition and Consumers Act 2024 (DMCC Act) coming into force on 6 April 2025. These provisions contain broadly similar prohibitions against unfair and misleading commercial practices as under the previous legislation, the Consumer Protection from Unfair Trading Regulations 2008 (CPRs). More detail on the legislative differences between the DMCC Act and the CPRs is available in the technical note. For further guidance, read Unfair commercial practices: CMA207.
The DMCC Act also contains additional protections for consumers who enter into subscription contracts. These provisions are expected to come into force no earlier than Autumn 2026.
These principles explain how anti-virus software businesses must be transparent when offering automatically renewing contracts, to comply with consumer protection law.
The principles cover several stages of a customer’s transaction:
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when the customer first signs up
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during the contract
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once the contract has automatically renewed