The Department for Business and Trade (DBT) is working with a number of stakeholders to develop guidance on how the subscription rules apply. This guidance will include a section on the limited exclusion for charitable memberships.
We are aware that some charitable memberships may remain subject to the DMCCA where a charity is providing goods or services to members other than in connection with viewing property or performances.
As we reported in 2025, HMRC implemented an interim solution to ensure that Gift Aid continues to be available on memberships which fall under the DMCCA (see Chapter 3.13.4) subject to the normal rules on donor benefits. We are however talking to HMRC about whether there is a need to implement a more permanent solution through a legislation change.