Auto-Renewal Disclosure Rules: The Decisions That Matter
US rules on disclosing subscription terms, obtaining consent and letting customers cancel automatic renewals.
Marcus Adeyemi
What is at stake
Subscription enforcement is active at federal and state level, and unclear renewal terms bring refunds and penalties.
The playbook
- Disclose price, frequency and renewal terms before payment
- Get separate consent for renewals
- Send renewal reminders
- Offer cancellation as easily as sign-up
- Keep records of consent
Where it goes wrong
Avoid:
- Renewal terms buried in fine print
- Cancellation only by phone where prohibited
- Silent price increases
- Pre-checked renewal boxes
The numbers behind it
| Measure | Figure |
|---|---|
| ROSCA | requires clear terms, informed consent and simple cancellation for negative option offers |
| FTC rulemaking | the FTC's 2024 rule on negative option marketing was set aside by a federal appeals court in 2025 |
| State laws | several states have their own automatic renewal laws |
| Reminders | some state laws require renewal reminders |
Getting outside help
When to hand it over: Bring in help before launching subscription billing.
Where this comes from
- Federal Trade Commission — Negative option rule
- California Attorney General — Automatic renewal law
The figures and practices above come from the sources listed.
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