The Maze: A shopper sees one price on a product page, then discovers a fixed fee at checkout. A free trial ends and the first paid charge arrives before the customer has decided to stay. The European Commission’s proposed Digital Fairness Act would change both experiences for EU consumers. It would bring predictable charges forward, require customers to agree to paid trial conversion and give them a visible way to request cancellation online. The European Parliament and EU governments still have to consider the proposal.
Source: European Commission factsheet. The Commission’s proposed changes to free trials, renewals and cancellation. © European Union, cropped, [CC BY 4.0](https://creativecommons.org/licenses/by/4.0/).
The details
🏷️ The first price would have to carry more. The proposal’s list of unfair practices would require the first displayed price to include foreseeable fees and taxes the buyer cannot avoid. A fixed delivery fee is one example. The draft’s explanation distinguishes costs that depend on later choices, such as a delivery address or shipping method. The list also targets fake stock warnings, repeated scarcity prompts during ordering and default options that add paid products unless shoppers remove them.
💳 A free trial and a paid renewal would follow different rules. Under the draft contract rules, a seller would send a reminder with the trial end date, price, duration and cancellation terms in a form the customer can keep, such as an email. The customer would have to agree to the paid plan before the trial ends. If the reminder is missing or the customer does not agree, the customer would not be bound. For automatically renewing online contracts of six months or longer for an ongoing supply of goods or services, the draft instead sets a reminder window from one month to 14 days before renewal. Shorter contracts have a separate schedule.
🚪 Customers could send a cancellation request online. If a seller offers online signup, its proposed termination tool would have to let customers identify the contract and confirm their request, even if they signed up another way. Within a week of submission, the seller would send a receipt that says when the contract will end. An existing EU directive already provides for an online tool to back out of qualifying purchases during the time allowed by law. The draft addresses the separate job of ending an ongoing contract.
Our take
Retailers selling to EU consumers should start by tracing where their customers first see a price, agree to pay and ask to leave. Each decision can sit in a different system, even when customers see a single store.
🛒 Check where the price appears first. If a product listing or partner feed shows the first price, a predictable fixed fee would have to be included there. A checkout update alone could leave the earlier listing incomplete. Check which partners can receive the full amount and which charges still depend on information supplied later.
🧾 Measure agreement and cancellation separately. Amazon committed to a two-step Prime exit on its EU sites in 2022, after talks with the Commission and national authorities. That precedent gives subscription teams a concrete benchmark for how much work they ask of a customer who wants to leave. For a free trial, a separate measure is the share of users who actively choose the paid plan before it starts.
🧮 Price out the work system by system. The Commission’s impact assessment models €678 million in annual recurring business costs for its preferred package after adjusting for overlapping measures. That aggregate spans different types of business. Industry association CCIA Europe says the plan could reduce differences between EU countries while also adding obligations that overlap existing rules. Cross-border sellers can start with the tools they share across markets, then identify where local requirements could still change the work.
