This guide is general information for subscription brands, not legal advice. Laws change and depend on where your customers live. Talk to a lawyer about your own program. We checked every rule and source below on October 18, 2026.
Every subscription renews automatically. That's what makes it convenient for the customer and predictable for you. It's also why lawmakers watch subscriptions closely: a renewal the customer forgot about, or one they can't stop, looks a lot like a charge they never agreed to.
The good news is that the rules mostly ask for what good subscription brands do anyway. Say what the customer is signing up for, get a clear yes, remind them before they're charged, and make leaving as easy as joining. This guide covers what automatic renewal laws usually require, where the federal rules stand today, what California's law adds, and how to set up your checkout, reminders and cancellation flow to match.
What auto-renewal laws usually require
The details differ from law to law, but most follow the same four ideas:
- Clear terms before the customer pays: That the plan renews, how often, how much it costs (including when an introductory price ends) and how to cancel. Shown clearly and close to the button, not buried in the terms of service.
- Consent to the renewal: The customer actively agrees to the renewing terms. A prechecked box, or consent hidden in general terms, usually isn't enough.
- Notice before certain charges: Reminders before a trial turns paid, before a long plan renews, or before a price goes up. What triggers a notice, and how far ahead, varies by law.
- An easy way to cancel: Cancellation that's as simple as signing up, usually through the same channel. A phone-only cancel for an online sign-up is the classic problem.
Most laws also expect a confirmation after sign-up that repeats the terms and how to cancel, and records showing the customer agreed.
Federal rules: ROSCA and the FTC Negative Option Rule
In the United States, two federal sources matter most.
The Restore Online Shoppers' Confidence Act (ROSCA), passed in 2010, covers online sales with a negative option feature, which includes automatic renewals. Under 15 U.S.C. § 8403, a seller may not charge the customer unless it (1) clearly discloses all material terms before taking billing information, (2) gets the customer's express informed consent before charging, and (3) provides simple ways to stop recurring charges. ROSCA is in force, and the FTC enforces it.
The FTC Negative Option Rule dates from 1973 and originally covered prenotification plans, such as book-of-the-month clubs. In 2024 the FTC adopted broad amendments, often called the "click-to-cancel" rule. On July 8, 2025, before the main parts took effect, the U.S. Court of Appeals for the Eighth Circuit vacated those amendments, finding the FTC had skipped a required preliminary regulatory analysis.
The FTC then started over. It published an advance notice of proposed rulemaking in the Federal Register on March 13, 2026, asking whether to update the rule, bring back parts of the 2024 version or do nothing, with comments due April 13, 2026 (Covington summary). An advance notice contains no rule text. As of October 18, 2026, we found no proposed rule published after it. Check the FTC's site for anything newer before you rely on this.
So in practice: there's no federal click-to-cancel rule in force today, but ROSCA already requires clear terms, consent and a simple way to stop, and the FTC keeps bringing cases under it.
State laws, and why California sets the bar
About 30 states have their own automatic renewal or negative option laws, according to a May 2026 Jones Day alert. They apply based on where your customer lives, not where your business is. Since most online brands sell into every state, many design for the strictest common law. Today that's usually California.
California's Automatic Renewal Law (Business and Professions Code § 17600 and following) was amended by AB 2863, which took effect on July 1, 2025, for contracts made, amended or extended from that date. Law firm summaries from Fenwick and Barnes & Thornburg describe these main requirements:
- Express affirmative consent: The customer must actively agree to the renewal terms, and the business must keep proof of that consent for three years or one year after the subscription ends, whichever is longer.
- Free-to-paid conversions: The law covers free trials and introductory offers that turn into paid subscriptions.
- An annual reminder: At least once a year, a reminder of what the customer subscribes to, how often it renews, what it costs and how to cancel.
- Notice of price changes: Between 7 and 30 days before a price change takes effect, with how to cancel.
- Cancel the way you signed up: A customer who subscribed online must be able to cancel online, without unnecessary steps or delays.
- Save offers with a visible exit: You may show a discount or other offer when someone cancels, but only if a clear "click to cancel" link or button stays visible at the same time.
Read the statute itself or ask your lawyer for the exact wording; these are summaries.
How to set up your program to match
Here's how each requirement turns into something you build.
1. Checkout and product page
- Show the renewal terms next to the subscribe option: "Renews every 30 days at $32 until you cancel. Cancel anytime in your account."
- If the first order is discounted, say what later orders cost and when the change happens.
- For a trial, say when it ends, what the first paid charge will be and how to cancel before it.
- Don't preselect the subscription option in a way the customer could miss. Make choosing it an active step.
- Use your platform's consent text. On Shopify, Shopify's help center says the subscription disclosure at checkout can't be removed on any plan, and editing the agreement label and consent text needs Shopify Plus (checked October 18, 2026).
2. The confirmation
Send a welcome email right after sign-up that repeats the terms: product, price, how often it renews, the next charge date and a direct link to manage or cancel. It doubles as the record of what the customer was told.
3. Reminders before charges
- Before every renewal: A short upcoming-order reminder a few days ahead is good practice for any plan and covers most reminder rules for monthly subscriptions. See our subscription reminder text examples.
- Before long plans renew: For prepaid and annual plans, send the reminder well ahead, often 15 to 30 days, with the price and how to cancel.
- Before a trial converts: Tell the customer before the first paid charge.
- Once a year, the full picture: What they subscribe to, how often it renews, what it costs and how to cancel. Your regular reminder can carry this if it includes all four.
- Before price increases: Give notice ahead of the change (California's window is 7 to 30 days) and say how to cancel.
4. Cancellation
- Put cancel in the customer portal, where customers manage the subscription, and make it findable.
- Keep the flow short. A reason question and one offer are fine; a maze is not.
- If you show a save offer, keep a clear cancel button on the same screen.
- Don't require a phone call or email for an online sign-up. If customers also contact you by text or chat, let them cancel there too.
- Confirm every cancellation in writing, with the date it takes effect and any final order.
Our cancellation flow examples show how to offer skips, swaps and pauses without trapping anyone.
5. Records
Keep what the customer saw and agreed to at checkout, the order and subscription records, the reminders you sent and the cancellations you processed. If a customer disputes a charge, or a regulator asks, this is what you'll need.
A compliance checklist for subscription brands
- Renewal terms, price, frequency and how to cancel appear next to the subscribe option.
- Introductory and trial prices say what happens after.
- Customers actively choose the subscription; nothing is preselected or hidden.
- A confirmation goes out after every sign-up with the terms and a manage link.
- Reminders go out before renewals, with earlier notice for long plans and trials.
- At least one message a year carries the full terms and how to cancel.
- Price increases are announced ahead of time with how to cancel.
- Customers can cancel online, in the portal, without calling.
- Save offers never hide the cancel button.
- Every cancellation gets a written confirmation.
- Consent, reminders and cancellations are kept on record.
- A lawyer has reviewed your setup for the states you sell into.
How Chargezen helps
Chargezen doesn't decide which laws apply to you or check your wording; that's for you and your lawyer. What it does is give you the pieces these laws ask for, built into Chargezen Subscriptions:
- Upcoming order reminders: An email and a text before each renewal, sent 1 to 30 days ahead (3 by default), with wording you edit. Each reminder is a workflow you can switch on, change or test.
- Welcome and confirmation messages: A welcome email when a customer subscribes at checkout, and confirmations when a subscription is paused, resumed, restarted or canceled.
- Price change notices: When you raise a product's price, the order already scheduled keeps the old price, the new price applies after it, and subscribers get an email and text about the change.
- Cancel in the portal: Customers can cancel themselves in the customer portal, and by text or chat through Concierge. Your cancellation flow shows offers first, and customers can always finish canceling.
- Shopify checkout: Subscriptions run on Shopify's checkout and subscription contracts, so Shopify's subscription disclosure appears at checkout.
Subscriptions is $199 a month or $1,990 a year for Shopify Advanced and Shopify Plus stores, with no commission. See pricing. Glossary: automatic renewal law, negative option rule and auto-renewal.
Frequently asked questions
Is the FTC click-to-cancel rule in effect?
No. The Eighth Circuit vacated the 2024 amendments on July 8, 2025. The FTC published an advance notice about a new rule on March 13, 2026, and as of October 18, 2026 we found no proposed rule after it. ROSCA still requires clear terms, consent and a simple way to stop recurring charges.
Does California law apply if my business is in another state?
State auto-renewal laws generally protect customers who live in that state, so selling to California customers can bring the law into play wherever you're based. Ask your lawyer how it applies to you.
Can I still show a save offer when someone cancels?
Under California's amended law, yes, as long as a clear way to cancel stays visible at the same time. It's a good rule everywhere: offers work better when customers don't feel trapped.
How far ahead should I remind subscribers?
A few days before monthly renewals works for most brands. Give more notice for prepaid and annual renewals, trials and price changes, and check the specific windows in the laws that apply to you.
