Each of these is a refusal this regime lets a counterparty attempt, paired with the answer to it. Reading them before you write is worth more than any amount of polish on the letter itself.
"Your 14 days ran out"
high likelihoodThe trader counts 14 days from sign-up.
What answers it
Regulation 31 extends the cancellation period by 12 months where the trader did not give the reg 10(1) or reg 13(1) information about the right to cancel — including the conditions, the time limit, the procedure and the model cancellation form. Ask the trader to produce the exact information it says it gave you and when. If it cannot, you have 12 months and 14 days.
Consumer Contracts Regulations 2013, reg 31 — reg 31 — where the trader did not give the information on the right to cancel required by reg 10(1) or 13(1), the cancellation period is extended by 12 months
"You used the service, so you cannot cancel"
high likelihoodThe trader says performance began and the right to cancel was lost.
What answers it
The reg 36 exclusion applies only where the service has been fully performed and the consumer gave prior express consent with an acknowledgment that the cancellation right would be lost. A continuing subscription is not fully performed. And reg 36(6) provides that where the trader failed to give the reg 10/13 information, the consumer bears no cost for what was supplied at all.
Consumer Contracts Regulations 2013, regs 36 and 37 — reg 36(4)-(6) — the consumer pays for a service supplied during the cancellation period only where they made an express request and were given the reg 10/13 information; reg 37 — the equivalent rule for digital content
"Our terms say renewals are non-refundable"
high likelihoodThe trader relies on its own contract.
What answers it
Regulation 44 makes a term of a contract void to the extent that it is inconsistent with a provision for the consumer's protection in the 2013 Regulations. Part 2 of the Consumer Rights Act 2015 independently strikes down unfair terms, and s.50 makes information the trader gave about the service a binding term.
Consumer Rights Act 2015 — s.50 — information said or written by the trader about the service, on which the consumer relies, is a binding term; Part 2 — unfair contract terms
"The DMCCA subscription rules do not apply yet"
medium likelihoodThe trader correctly points out that Part 4 Chapter 2 is not commenced.
What answers it
That is right and it does not help them. The cancellation right you are exercising comes from the 2013 Regulations, which have been in force since 2014. And Part 4 Chapter 1 of the DMCCA — unfair commercial practices, with CMA fines of up to 10% of global turnover — commenced on 6 April 2025 and covers obstructive cancellation and buried renewal terms.
Digital Markets, Competition and Consumers Act 2024, Part 4 Chapter 1 — Unfair commercial practices, in force 6 April 2025, revoking the Consumer Protection from Unfair Trading Regulations 2008. Schedule 20 lists the 32 automatically unfair practices; s.230 requires material information, including the total price, to be given in an invitation to purchase.