This Practice Note sets out the key issues to consider when setting up a subscription model for the sale and supply of goods, services or digital content to consumers.
Subscription types
There are broadly three types of subscription:
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curation—the customer receives a curated selection of different items. For example monthly subscription boxes for clothing, pet products, cosmetics, personal hygiene products, or recipe boxes or food services
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replenishment—the customer receives regular deliveries of the same or similar items. For example, monthly subscriptions for toilet paper, razors, vitamins or other commodities
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access—the customer gets access to content or to premium services. For example content streaming services, gaming services, premium subscriptions, and cloud storage subscription services
Regulatory landscape
When setting up subscription models, there is a variety of regulation to be aware of, in particular consumer protection legislation, data protection legislation, the rules on direct marketing and the self-regulatory advertising codes.
Consumer protection legislation
When entering into subscription contracts with consumers, various consumer protection legislation needs to be considered, in particular the following:
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Consumer Contracts (Information, Cancellation and Additional Charges)
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