Your Launch Page Is a Contract: Seven Consumer-Rights Traps UK Founders Copy-Paste Into Trouble

Last month a founder walked me through his pre-launch checklist. Payments: tested. Transactional emails: tested. The cookie banner: argued about for three days. The paragraph sitting directly above the 'Pay now' button — the one that tells a customer what they're actually agreeing to — had been pasted from a template in 2019 and read by nobody since.

That's the usual shape of it. Legal copy is the only part of a launch that nobody demos, and it happens to be the part that generates refund requests, chargeback disputes and, since April 2025, the very real possibility of a letter from the Competition and Markets Authority with a turnover-linked penalty attached.

Worth stating plainly: under the Digital Markets, Competition and Consumers Act (DMCC), the CMA can now enforce consumer law directly, without a court trip, with fines of up to 10% of global turnover. Nobody reading this is going to be the subject of a headline enforcement action. But the same rules govern the small, boring disputes that eat a founder's week — and the regulator's guidance is, conveniently, a fairly good description of what annoys your customers anyway.

Here are the seven clauses I see tripped over most often.

1. Auto-renewal that's disclosed but not noticed

Technically, the renewal is in the terms. Practically, it is buried in clause 11 and the customer finds out when their card is charged eleven months later. Copy-paste traps include annual subscriptions that silently convert to monthly at a different price, trial periods that roll over with no reminder, and a price rise announced via a footer update.

The subscription-contract rules under the DMCC are still phasing in, with the government having consulted on the detail. Treat the existing Consumer Contracts Regulations as your floor, not your ceiling: state the renewal date and price in the confirmation email, send a reminder before the first charge, and make sure the price the customer agreed to is the price on their statement.

2. The pre-ticked box

A pre-ticked box is not consent. Additional payments — gift wrap, priority support, insurance, an extended warranty — need a clear, affirmative action from the customer. Default opt-ins are void, and they're also the single fastest way to make a first-time buyer distrust everything else on the page. Every add-on should start unticked, priced, and skippable in one click.

3. Cooling-off language that's really a disclaimer

Consumer Contracts Regulations give most online buyers 14 days to change their mind. The digital-content exemption — where the right is lost once a download starts — only works if you get express consent plus an acknowledgement that the right disappears. Sell a service that starts immediately and the wording has to change again. A model cancellation form needs to actually exist somewhere reachable, not be gestured at.

If your T&Cs say 'no refunds' and your customer is a consumer, the clause is mostly decorative. It won't win the dispute and it will invite one.

4. Delivery promises with no second date

The Consumer Rights Act sets a 30-day default where no delivery date is agreed. If you publish a date, that date becomes a contractual term. 'Dispatched in 2–3 working days' is not the same promise as 'delivered by Friday', and if you miss your own deadline and then miss the reasonable extra time the customer gives you, they can cancel and claim a refund. Royal Mail delays, a bank holiday weekend and one under-staffed Tuesday in December are all your problem, not theirs.

5. Drip pricing and the word 'from'

Since the DMCC changes landed, mandatory fees need to be in the headline price. That means the booking fee, the service charge, the mandatory admin levy. 'From £9' where every real configuration costs £14 is the kind of thing that attracts complaints and, more painfully, abandonment at checkout. Show the full breakdown before the customer enters card details, not after.

6. Review badges you can't stand behind

Fake reviews are now explicitly banned, as is commissioning them — and you're responsible for what the review widget on your own site displays. That '4.9/5 from 1,200 happy customers' badge needs substantiation you can produce in an afternoon. Same for 'as seen in' strips: if the coverage was a paid listing or a quote in a roundup, say so or lose it.

7. A cancellation flow built like a maze

Sign up in one click, cancel by posting a letter — that asymmetry now sits squarely in the unfair-commercial-practices bucket. So do countdown timers that reset, fake scarcity, and 'are you sure?' screens designed to exhaust people. The test is simple: can a tired person cancel on a phone in under a minute? If not, fix the flow before you fix the copy.

Honourable mention to two old favourites: 'we may change these terms at any time' and 'we exclude all liability'. Neither survives contact with a consumer dispute, and both make your product look like it was built by someone hiding.

Where early adopters actually look

Almost nobody reads your terms page. They do read the button text, the price breakdown at checkout, the delivery estimate on the product page, the footer with your company number and registered address, and the Google result for 'how do I cancel [your product]'. They check Trustpilot and they check the subreddit. If your legal copy contradicts your marketing copy anywhere in that journey, they'll spot it — and they'll tell other people.

A pre-launch checklist worth an hour

• Read your own checkout as a stranger, on a phone, with a stopwatch.
• Highlight every promise: delivery date, price, cancellation window, renewal.
• Confirm each promise is true in the code, not just on the page.
• Run a real cancellation with a real card and time it.
• Run a real refund and time that too.
• Give the price breakdown a component in your design system so nobody hardcodes it again.
• Date and version the terms, and keep the previous version.
• Ask someone who didn't build it to explain what they think they're buying.

The point isn't to become a lawyer. It's to notice that the checkout is a contract, the launch page is an offer, and both are product surfaces your customers experience at the exact moment they're deciding whether to trust you.