Whitepaper

Aug 18, 2026

Direct Debit, CPA and subscriptions - a guide to key rules and regulations

Recurring income is becoming a bigger part of how arts and cultural organisations stay resilient. Monthly memberships, annual friends' schemes, regular donations: all of it gives you income you can plan around, and gives audiences a way to support your work

That reliability comes with a few rules attached. Every recurring payment, whatever method it uses, sits inside a framework built to protect the person paying, and it's worth understanding those frameworks before you begin to collect payments. What follows is a guide to what you need to know, whether you're offering recurring payments for the first time or you've done it for years but want a refresher.

Those rules differ in the UK and Ireland, so below we’ve covered both. In the UK, there are two regulations to have in mind: the Direct Debit Guarantee, the long-standing scheme that protects every Direct Debit payment, and a statutory subscription contracts regime, introduced by the Digital Markets, Competition and Consumers Act 2024 (DMCC), and coming into effect next year, which will change how organisations manage subscription schemes. In Ireland, the equivalents are the SEPA Direct Debit Core Scheme, the euro-area payment scheme carrying its own set of protections, and the Consumer Rights Act 2022, which already governs pre-contract information, cooling-off periods, and cancellations.

Just to note: this is information based on our experience of best practice rather than specific legal advice for your organisation. We recommend taking expert advice before you take action.

Two separate rulebooks to have in mind

Payment scheme rules and consumer law are the two sets of rules you need to get to know - these apply at different levels, and memberships are subject to both.

A Payment scheme is the set of rules, standards, and procedures that defines how money moves from a sender to a receiver. Payment scheme rules govern how a specific payment method behaves: what happens when a collection is wrong, how much notice you need to give before changing an amount, and how a customer can cancel. It applies whenever money moves by that method, and whatever the customer is paying for. In the UK, that rule is the Direct Debit Guarantee, offered by all banks and building societies that accept instructions to pay Direct Debits and backed by Bacs. In Ireland, where collections are made in euros, it is the SEPA Direct Debit Core Scheme, run by the European Payments Council.
Consumer law governs the contract itself: how you describe it before someone signs up, the reminders you send, and how easily customers can exit the agreement. It applies to your membership or recurring donation agreement no matter what payment method a customer uses. In the UK, the relevant law is the subscription regime under the Digital Markets, Competition and Consumers Act 2024, building on the Consumer Contracts Regulations 2013 and the Consumer Rights Act 2015. In Ireland, it is the Consumer Rights Act 2022.

The payment scheme: what you need to know

In the UK: the Direct Debit Guarantee & Bacs rules

Every bank or building society that manages direct debit instruction offers the Direct Debit Guarantee, and it applies to every single DD payment collected. As a venue collecting payments, it requires you to provide the following:

Advance Notice: You must give notice of any change to the amount, date, or frequency of a collection: normally 10 working days before the payment is taken, unless you have set out a different time frame in your T&Cs. When a customer sets up direct debit you confirm the amount and the date of collection, and you must stick to this going forward
Immediate Refunds for Errors: If your organisation, or the bank who manages collection, make a mistake in collecting a Direct Debit the customer is entitled to a full and immediate refund from their bank.
Cancellation Rights: A customer can cancel a Direct Debit at any time via their bank - (though it is good practice for them to notify you of cancellation, too)

With noting: The Guarantee covers the payment, not the contract. So a member receives a refund for a wrongly collected payment, they still owe whatever they’ve agreed to pay you.

Separately, Bacs rules set out the following:

You need to get authorisation from the customer via a valid Direct Debit Instruction (DDI) in order to collect payment.
If an instruction goes unused for 13 months in a row, it is flagged as “dormant” and banks will no longer track it within their systems as a result. You’ll need to log a new mandate to collect again.

In Ireland: the SEPA Direct Debit Core Scheme

Euro Direct Debits are managed by the SEPA Direct Debit (SDD) Core Scheme, which requires the following:

Pre-notification: You let a supporter know the amount and date that you are collecting before you do so. This should be at least 14 calendar days before the due date, unless a shorter timeframe is agreed in your T&Cs.
No-Questions-Asked Refunds: For authorised collections, payees can request a full refund from their bank on a "no-questions-asked" basis, within 8 weeks of payment being collected. Where a collection was unauthorised (e.g., if there’s no valid mandate), this window extends to 13 months.
Mandate Expiration: A SEPA mandate automatically lapses if nothing is collected for 36 months. It must be cancelled at this point and you’ll need a new mandate to collect again.

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Direct Debit vs. Continuous Payment Authority (CPA)

An alternative to direct debits are recurring card payments - these are typically set up as a Continuous Payment Authority (CPA), where the customer authorises a merchant to charge their card on a continuous basis.

A Direct Debit is arranged directly with the customer's bank and is protected as per the regulations detailed above. A CPA is an arrangement linked to a payment card.

Under the FCA Payment Services Regulations 2017 in the UK and PSD2 (S.I. No. 6/2018) in Ireland, a customer is legally able to cancel CPA directly with their card-issuing bank at any time before the payment is due. If payments are taken after cancellation, the card issuer must provide a refund.

Unlike Direct Debits, which move automatically if you change bank accounts under switching schemes, CPAs do not transfer automatically if a customer changes bank accounts or gets a replacement card, unless updated via account updater services (e.g. Visa Account Updater, Mastercard Automatic Billing Updater)

Find out more about the differences between Direct Debits and CPA - and which might be better for your organisation - on our blog.

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Consumer law: what applies to subscriptions

The UK: The DMCC Act 2024 Subscription Contracts Regime

A new set of rules is due to come into effect in Spring 2027 : the UK subscription regime under the Digital Markets, Competition and Consumers Act 2024.

Under the DMCC Act you must do the following (unless you’re exempt):

Provide clear statutory pre-contract information before the customer enters the contract.
Send reminder notices before free/discounted trials end or before contracts of 12 months or longer auto-renew.
Provide a straightforward exit mechanism, for example allowing customers to cancel online if they signed up online.
Honour two statutory 14-day cooling-off periods: the at sign-up, and the second following auto-renewals on annual or trial subscriptions.

Charitable Venues Exemption (UK)

Following consultation, the UK Government confirmed that charitable cultural and heritage memberships are excluded from the above DMCC subscription rules.

This applies to memberships offered by registered charities that provide access to performances, collections, or sites connected to the charity’s purpose (so - theatre memberships, museum passes, and heritage subscriptions). The exemption was introduced to protect Gift Aid eligibility (as HMRC rules prevent Gift Aid from being claimed on membership fees that could be subject to refunds. You can read more about this in our Gift Aid Guide)

Note: If you’re not a charitable venue you must comply with the full DMCC subscription regime when it comes into force.

Ireland: The Consumer Rights Act 2022

In Ireland, distance contracts (so, all those set up online or by phone) are governed by the Consumer Rights Act 2022:

Pre-Contract Information: Venues must provide all information about the subscription in a way that is clear and easy to understand before sign-up, including total price (inclusive of VAT), length of contract, renewal terms, and cancellation rights. You need to be able to prove that this information was provided before a customer makes a purchase.
Explicit Consent & Checkout: Online payment buttons must make it clear that payment is required (e.g., "Pay Now" or "Complete Purchase"). It’s illegal to set up pre-ticked boxes for optional extras.
Cooling-off Rights & Refunds: Online customers generally have a 14-day cooling-off period to cancel a membership service to receive a full refund. You also need to inform them of this right, or, the withdrawal window will extend by up to 12 months.
Ticketing & Specific Event Exclusions: It’s worth noting that under distance selling regulations, leisure services provided on a specific date or for a specific period of performance (such as concert tickets or fixed-date event bookings) are excluded from the 14-day cooling-off period.

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What venues should have in place

Whether you’re based in the UK or Ireland, and whether you’re a charity or commercial entity, you should make sure you provide the following:

Clear Pre-Contract Information: Spell out what your purchaser is committing to clearly before checkout: fee amount, payment frequency, auto-renewal rules, and cancellation methods.
Straightforward Exit Options: Offer a simple way to cancel - ideally, this will online for customers who signed up online.
Automated Reminders: Send advance notifications in plenty of time before annual renewals.
Correct Payment Advance Notices: Comply with required notice windows (10 working days under UK Bacs rules; 14 calendar days under SEPA Core rules unless otherwise specified in your own T&Cs).
Fair & Transparent Terms: Ensure contract terms are written in plain language that’s understandable by all and avoid making it really difficult for someone to cancel.

How Ticketsolve supports compliant recurring payments

Ticketsolve Pay is built to make recurring memberships and donations seamless while handling legal and payment scheme compliance through our partnership Mangopay.

Integrated Direct Debit & Card Billing: Collect recurring memberships (via Benefit Products) and regular donations through Direct Debit or card without needing to integrate third-party payment gateways.
Customer Self-Service: Allows supporters to view, manage, and cancel their active memberships directly from their online customer portal, or by contacting your box office.
Automated Renewal Notifications: Schedule automatic pre-notification emails to prompt members ahead of auto-renewals.
Smart Card Retries: Automatically retries failed card transactions every 4 days for up to 5 attempts before escalating to your box office team.

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