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The Lens

Digital developments in focus

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CMA investigates Microsoft over marketing of subscription plans

On 29 July 2026, the Competition and Markets Authority (CMA) announced an investigation into Microsoft over concerns that customers may not have been given clear, upfront information about their subscription options when changes were made to Microsoft 365 Personal and Family plans. The investigation focuses on whether Microsoft’s communications about the addition of new features and associated price increases were misleading. The case is one of the first to engage directly with the intersection of AI product rollouts and UK consumer protection law and underscores the CMA’s intensifying focus on subscription-related practices.

What the CMA is examining

From January 2025, Microsoft automatically gave existing Microsoft 365 Personal and Family subscribers access to new features, including Copilot, at no extra cost for the remainder of their subscription period. When that period ended, customers were then automatically rolled onto a higher-priced plan incorporating those features, unless they actively chose to switch to a different plan or cancel. Microsoft stopped offering the original Personal and Family plans (without the new features) to new subscribers, but existing customers were given a time-limited option to move to a “Classic” plan at the original price. This amounts to a £25 per year increase for annual Personal subscribers who did not opt out.

The CMA is examining whether Microsoft’s pre-renewal communications gave customers the key information needed to make an informed choice, including the cost difference between upgraded and classic plans (approximately £25 per year). The Australian Competition and Consumer Commission and the Italian Competition Authority are separately investigating Microsoft entities over subscription renewal issues.

Broader enforcement context

The Microsoft investigation has been launched at a time when the CMA has already declared that subscription contracts will be an enforcement priority for the year ahead under the Digital Markets, Competition and Consumers Act 2024 (DMCCA) regime. With its new direct enforcement powers, the CMA can issue infringement notices in relation to consumer law breaches and impose penalties of up to 10% of a business’ global turnover. A dedicated subscription contracts regime under the DMCCA is expected to come into force in Spring 2027. Following the Government’s consultation response published in April 2026, the new rules will target “subscription traps” and introduce various new obligations for businesses.

While the CMA’s Microsoft investigation draws on existing unfair commercial practices law rather than the forthcoming regime, subscription contracts are clearly under the microscope.

 

If you have questions about subscription compliance or the CMA’s enforcement activity, please contact our Consumer Protection team.

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