That distinction between a monthly payment and a monthly contract matters. Under Adobe’s published UK terms, someone who leaves an “annual contract, billed monthly” more than 14 days after placing the order may be charged 50% of the payments remaining in the contracted year. Access to the software then ends at the close of the current monthly billing period.
In other words, the customer can be required to pay a substantial part of the remaining annual price without continuing to receive the software for the rest of that year.
Adobe describes this as an early cancellation fee. The CMA is investigating whether the term is fair and whether customers receive sufficiently clear and timely information about it before subscribing.
The detail that changes everything: “annual”
Adobe offers several different payment structures. Although the wording and availability can vary between products, purchasing routes and countries, its published UK terms distinguish between a genuine rolling monthly subscription and plans carrying a one-year commitment.
Monthly billing can describe two very different agreements
What about an annual prepaid plan?
- The customer pays the annual price upfront rather than by monthly instalments.
- Adobe says the initial order can generally be cancelled for a full refund within 14 days.
- After 14 days, the annual payment is generally non-refundable.
- Unlike the annual plan billed monthly, access normally continues until the end of the contracted term.
“Billed monthly” describes how the price is collected. It does not necessarily describe the length of the contract.
That is not unique to software. Mobile phone, broadband, gym and finance agreements can all involve fixed contractual periods paid in monthly instalments. A software company can also offer a lower monthly price in exchange for a longer commitment. The important questions are whether that commitment was made sufficiently clear and whether the financial consequence of leaving is fair and proportionate.
Is a software subscription really a contract?
Yes. A contract does not need to be signed on paper or described prominently as a “contract”. When a consumer selects a plan, accepts the terms and provides payment details in exchange for access to software, a contract will normally be formed.
The word “subscription” does not replace the contract. It describes the recurring arrangement created by it.
The problem is not that Adobe calls its software a subscription while treating it as contractual. The problem arises if the overall presentation leads someone reasonably to believe they are choosing an ordinary monthly arrangement when they are actually accepting a minimum 12-month commitment.
A prominent monthly price can influence that impression, especially if the annual commitment and potential exit charge are displayed less clearly.
Can Adobe charge an early cancellation fee?
Potentially, yes. Early cancellation fees are not automatically unlawful.
A business may have a legitimate reason for offering a discounted price in return for a minimum commitment. Consumer law does not guarantee that someone can leave every fixed-term agreement without any financial consequence simply because they have changed their mind.
But a business cannot make a charge lawful merely by writing it into its terms.
This does not mean every cancellation charge is prohibited. It means the amount, purpose and operation of the charge must be capable of justification.
What makes a termination charge more likely to be fair?
- The charge protects a legitimate and objectively reasonable commercial interest.
- Its amount is proportionate and is not punitive.
- The circumstances in which it becomes payable are clear from the outset.
- The consumer receives a genuine benefit in return for accepting the commitment.
- The trader does not recover more than once for the same loss.
- The calculation accounts for relevant savings or gains resulting from the contract ending early.
A fixed charge of 50% of everything remaining is therefore not automatically fair simply because it is less than 100%.
The particularly striking feature of Adobe’s arrangement is that the customer may pay half of the remaining commitment but only retain access until the end of the current monthly billing period. That does not itself determine whether the term is unlawful, but it helps explain why the CMA is examining it.
There are really two separate legal questions
The term and the sales journey must be considered separately
The practical question is not merely whether the words “annual, billed monthly” appeared somewhere on the page. It is whether the annual commitment and possible 50% charge were presented with enough prominence and clarity for an average customer to understand their significance before subscribing.
A technically available term can still be inadequately disclosed.
Why is the CMA investigating Adobe?
The CMA opened its UK investigation on 19 March 2026. It concerns suspected infringements involving Adobe Systems Software Ireland Limited and certain membership plans offered to UK customers.
The regulator is examining two issues
- Whether the early cancellation fee is an unfair term in a consumer contract that binds consumers.
- Whether the presentation of information about the fee is an unfair commercial practice involving a misleading omission.
Adobe is the ninth company investigated using the CMA’s direct consumer-enforcement powers. Those powers allow the regulator to determine specified consumer-law infringements without first having to bring an ordinary court claim. Where wrongdoing is established, the CMA can impose remedies, seek redress for consumers and issue financial penalties of up to 10% of a business’s global turnover.
The case remains open. The CMA has not decided that Adobe infringed the law, and the existence of the investigation does not automatically invalidate every fee charged to a UK customer.
What happened in the United States?
The UK investigation follows substantial action in the United States. In 2024, the US Department of Justice, acting following a referral from the Federal Trade Commission, accused Adobe of pushing customers towards its “annual, paid monthly” plan without adequately disclosing the commitment and potential early termination fee.
The US government alleged that important information was placed in fine print or behind inconspicuous links and that customers encountered unnecessary steps, delays, retention offers and warnings when trying to cancel.
Adobe’s 2026 US settlement package
- A $75 million civil penalty.
- $75 million of free services for qualifying customers.
- Clear disclosure of any early termination fee and how it is calculated before enrolment.
- Reminders before certain free trials convert into paid subscriptions carrying an early termination fee.
- Easier methods for customers to cancel their subscriptions.
Adobe denied wrongdoing. It said its subscription model gives customers choices between lower upfront prices and greater flexibility, and that it had already made its sign-up and cancellation processes more transparent.
The US settlement does not decide whether Adobe’s UK terms are lawful. The laws and enforcement proceedings are different. It does, however, show that concern about the presentation and operation of the annual-paid-monthly model is not confined to the UK.
What does the 14-day period mean?
Adobe’s published terms state that customers who cancel within 14 days of their initial order will generally receive a full refund. After that period, the result depends on the plan selected.
Customers should not assume that a new 14-day period begins every month simply because another monthly payment is taken. With an annual plan billed monthly, Adobe regards those payments as instalments under the same annual contract.
Different statutory rules can apply to services and digital content, particularly where a customer expressly asks for supply to begin immediately. Adobe’s published refund promise may therefore be more straightforward than trying to determine the precise extent of a separate statutory cooling-off right.
The important practical point is to act quickly. Someone who has only recently subscribed should check the date of the initial order rather than the date of the latest payment.
How is Adobe’s cancellation fee calculated?
For an annual plan billed monthly, Adobe states that the charge may be 50% of the remaining contractual obligation.
Illustrative calculation
Monthly contractual price: £20
Months remaining: 8
Remaining contractual payments: £160
Illustrative 50% early cancellation charge: £80
The actual calculation may differ where a plan began with an introductory discount, changed price or includes additional services.
Ask Adobe to show
- The original contract start date.
- The minimum contractual term.
- Every payment already made.
- The number of months remaining.
- The monthly price applied to each remaining month.
- How the final cancellation figure was produced.
What can you do if Adobe demands a cancellation fee?
Build the evidence before disputing the charge
Sign in to the Adobe account and identify whether the plan is month-to-month, annual billed monthly or annual prepaid.
Check the original order confirmation as well as the current account page. Current wording does not prove what was displayed when an older contract was formed.
Take screenshots of the plan, cancellation screen, amount demanded, retention offers and any expandable sections containing the termination terms.
Save chat transcripts, emails and the original confirmation. The position and prominence of wording may be as important as the wording itself.
Ask Adobe in writing to identify the term, show where it was presented before purchase and explain the calculation and proportionality of the charge.
Keep Adobe’s final response and any evidence of the payment being taken before approaching an advice service or card provider.
A concise written challenge
Please identify the contractual term relied upon, provide a complete calculation of the cancellation charge and show how the annual commitment and 50% early cancellation fee were presented to me before I placed the order. Please also explain why the amount is proportionate, taking account of the fact that access to the service will end at the close of the current billing period.
Blocking the payment does not necessarily cancel the contract
Stopping a recurring card payment may prevent money leaving the account, but it does not necessarily terminate the underlying agreement. Adobe could continue to regard money as due and may attempt recovery. Give clear notice of cancellation and state expressly that the fee is disputed.
If Adobe does not resolve the complaint, a UK consumer can seek advice from the Citizens Advice consumer service. Citizens Advice can pass relevant intelligence to Trading Standards.
A card issuer may consider a chargeback request where a payment is disputed, although chargeback is a card-scheme process rather than an automatic legal right. The issuer will normally want evidence of the contract, the cancellation attempt and the complaint made to Adobe.
Court proceedings may also be possible where a disputed fee has been collected, but the legal position will depend on the individual transaction and evidence.
Consumer protections differ for business users
Creative Cloud is frequently used by freelancers, designers, photographers and other professionals. Consumer legislation does not necessarily apply simply because the purchaser is an individual.
The question is whether the person entered the agreement wholly or mainly for purposes outside their trade, business, craft or profession. Someone who bought Creative Cloud mainly for commercial work may be treated as a business customer and may not receive the same protections under the Consumer Rights Act. Teams, enterprise and education plans can also carry different terms.
If the plan was bought through Apple, Google or another retailer, the contractual party and cancellation arrangements may also differ.
New subscription protections are coming, but they are not yet in force
The DMCCA contains a separate subscription-contract regime intended to introduce clearer pre-contract information, reminder notices, straightforward cancellation methods and new cooling-off rights following some renewals. The government has announced an intended start in January 2027.
Those future subscription rules should not be confused with the consumer laws already being considered in the Adobe investigation. Existing rules on unfair terms and misleading commercial practices apply now.
ConsumerWise has separately examined what the new subscription regime will and will not change.
The wider lesson: monthly payment does not always mean monthly commitment
Adobe’s plans illustrate a recurring problem in the subscription economy. Consumers often focus on the amount leaving their bank account each month. Businesses may focus on the minimum period behind that payment schedule.
Four questions to ask before subscribing
- How frequently will I be charged?
- How long am I agreeing to remain?
- What happens if I leave before that period ends?
- When and how will the contract renew?
A plan can be billed monthly while still creating a year-long obligation. But the existence of a contract is not the end of the discussion. A cancellation term must still be fair, and important information must be presented clearly enough for consumers to understand the bargain before entering it.
That is the real issue now facing Adobe.
Official sources and responses
- CMA: Adobe consumer protection enforcement caseThe live UK case page, timetable, issues under investigation and current case status.
- CMA: Adobe cancellation-fee investigation announcementThe CMA announcement explaining the annual billed monthly term and 50% charge.
- Adobe UK: Subscription and cancellation termsAdobe’s published terms for month-to-month, annual billed monthly and annual prepaid plans.
- CMA37: Unfair contract terms guidanceUpdated in July 2026, including guidance on transparency, termination fees and payment for services not supplied.
- CMA207: Unfair commercial practices guidanceOfficial guidance on material information, misleading omissions and presentation.
- Consumer Rights Act 2015: Part 2The statutory framework governing unfair terms, transparency and interpretation.
- Consumer Rights Act 2015: Schedule 2The indicative and non-exhaustive list of terms which may be regarded as unfair.
- CMA: Cancelling goods or servicesConsumer guidance on cancellation charges and challenging terms that may be unfair.
- US Department of Justice: Adobe settlementThe US allegations, settlement package and required changes to disclosure and cancellation.
- Adobe: Statement regarding the US settlementAdobe’s response, denial of wrongdoing and description of its subscription choices.
