California Automatic Renewal Law
California's Automatic Renewal Law (Bus. & Prof. Code §§ 17600–17606) for developers — the checkout disclosure and express consent, the acknowledgment, trial, renewal, price-change and annual notices, click-to-cancel and the July 2025 amendments, with every requirement cited.
California's Automatic Renewal Law (ARL), Business and Professions Code §§ 17600–17606, is the most detailed state subscription law and the model for many others. It applies to automatic renewal and continuous service offers to consumers in California (personal, family or household purposes), whether the business is in California or not.
California Automatic Renewal Law — Cal. Bus. & Prof. Code §§ 17600-17606. Effective 2010-12-01. Status: in force. Source: https://leginfo.legislature.ca.gov/faces/codes_displayText.xhtml?lawCode=BPC&division=7.&title=&part=3.&chapter=1.&article=9.
Clear and conspicuous offer terms next to the consent request; affirmative (and since July 2025, express affirmative) consent; retainable acknowledgment; online "click to cancel" for online sign-ups; trial (> 31 days, 3-21 days) and 1-year-term (15-45 days) notices; 7-30 day fee-change notice; annual reminder; same-medium cancellation; limits on save offers; consent records kept 3 years. Remedies: civil (UCL) remedies only (§ 17604); unconsented goods are gifts (§ 17603).
Scope: Consumers (personal, family or household purposes) in California. Exempt (§ 17605): CPUC/FCC/FERC-regulated or franchised services, Department of Insurance-regulated entities, alarm company operators, banks and other licensed financial institutions, and BEAR-regulated service contract sellers.
- Amendment: SB 313, Stats. 2017, ch. 356, effective 2018-07-01: Free-trial disclosures and acknowledgment; online cancellation for online sign-ups.
- Amendment: AB 390, Stats. 2021, ch. 450, effective 2022-07-01: Trial/promo and 1-year-term notices; at-will online termination via prominent link/button or termination email.
- Amendment: AB 2863, Stats. 2024, ch. 515, effective 2025-07-01: Express affirmative consent, consent records, misrepresentation, expanded notice contents, same-medium cancellation, phone/voicemail rules, save-offer rules, 7-30 day fee-change notice, annual reminder (contracts entered, amended or extended on or after July 1, 2025).
What it requires, step by step
At sign-up
- The offer terms, clearly and conspicuously, next to the consent request (§ 17602(a)(1); § 17601(a)(2)–(3)): that the subscription continues until the consumer cancels, the cancellation policy, the recurring charges (and that they may change), the length of the renewal term or that the service is continuous, and any minimum purchase obligation. "Clear and conspicuous" (§ 17601(c)) means larger than the surrounding text, or in contrasting type, font or color, or set off by symbols or marks — legible is not enough.
- Free trials: explain the price charged after the trial, or how the pricing will change (§ 17602(a)(1)).
- Consent: affirmative consent before charging (§ 17602(a)(2)) and, for contracts from July 1, 2025, express affirmative consent to the renewal terms themselves, not merely to the purchase (§ 17602(a)(4)). Keep verification of that consent for three years, or one year after the contract ends if longer (§ 17602(a)(6)).
- No undermining or misrepresentation (§ 17602(a)(5), (a)(7)).
After sign-up
An acknowledgment in a form the consumer can keep — an email works — with the offer terms, the cancellation policy and how to cancel (§ 17602(a)(3)). For free trials it must also explain how to cancel before being charged.
Before charges
| Notice | When | Citation |
|---|---|---|
| Trial or promotional price longer than 31 days ending | 3 to 21 days before it ends | § 17602(a)(8), (b)(1) |
| Initial term of one year or longer renewing | 15 to 45 days before it renews | § 17602(a)(8), (b)(2) |
| Any change in the fee | 7 to 30 days before the change | § 17602(g)(2) |
| Material change in terms | Before it takes effect | § 17602(g)(1) |
| Annual reminder of the terms (product, frequency and amount of charges, how to cancel) | Once a year | § 17602(h) |
Cancelling
- Click to cancel (§ 17602(d)): a consumer who signed up online must be able to cancel online, at will and immediately, through a prominently located link or button (for example in account settings) or a pre-formatted termination email — without steps that obstruct or delay it.
- Same medium (§ 17602(f)): cancellation must be available in the medium used to sign up.
- Save offers (§ 17602(e)): retention offers are allowed only with a continuously displayed "click to cancel" option next to them.
- Phone lines (§ 17602(c)(2)): if you offer cancellation by phone, answer promptly and handle voicemail cancellations within one business day.
Every California requirement in the catalog
| Requirement | Citation | Applies when | Timing | Severity | Checkbox checks |
|---|---|---|---|---|---|
| Present the automatic-renewal offer terms clearly and conspicuously, next to the consent request Before the subscription is fulfilled, present the automatic renewal offer terms (§ 17601(a)(2)): that the subscription continues until the consumer cancels; the cancellation policy; the recurring charges (and, if the amount may change, that it may change and the new amount if known); the length of the renewal term or that the service is continuous; and any minimum purchase obligation — clearly and conspicuously and in visual proximity (for voice offers, temporal proximity) to the request for consent to the offer. | Cal. Bus. & Prof. Code § 17602(a)(1); § 17601(a)(2)-(3) | always | — | critical | signup.disclosure.autorenew_language, signup.disclosure.price, signup.disclosure.frequency, signup.disclosure.cancellation_policy, signup.disclosure.term_length, signup.disclosure.proximity, signup.disclosure.conspicuous |
| Explain the post-trial price for free gifts or trials If the offer includes a free gift or trial, the offer must clearly and conspicuously explain the price that will be charged after the trial ends, or the manner in which the subscription pricing will change when the trial ends. | Cal. Bus. & Prof. Code § 17602(a)(1) (second sentence) | free trial | — | critical | signup.disclosure.trial_terms, signup.disclosure.price |
| Obtain affirmative consent before charging Do not charge the consumer's credit or debit card or third-party payment account for an automatic renewal or continuous service without first obtaining the consumer's affirmative consent to the agreement containing the automatic renewal offer terms, including terms offered at a promotional or discounted price for a limited time. | Cal. Bus. & Prof. Code § 17602(a)(2) | always | — | critical | signup.consent.affirmative, signup.consent.not_prechecked |
| Obtain express affirmative consent to the automatic-renewal terms themselves Obtain the consumer's express affirmative consent to the automatic renewal or continuous service offer terms (not merely to a purchase or to general terms of service). | Cal. Bus. & Prof. Code § 17602(a)(4) | always | — | critical | signup.consent.affirmative, signup.consent.not_prechecked |
| Do not undermine consent with contradictory or distracting information Do not include any information in the contract that interferes with, detracts from, contradicts, or otherwise undermines the consumer's ability to provide affirmative consent to the automatic renewal or continuous service. | Cal. Bus. & Prof. Code § 17602(a)(5) | always | — | medium | signup.disclosure.conspicuous, signup.consent.affirmative |
| Keep verification of consent for three years (or one year after termination, if longer) Maintain verification of the consumer's affirmative consent for at least three years, or one year after the contract is terminated, whichever period is longer. | Cal. Bus. & Prof. Code § 17602(a)(6) | always | — | medium | signup.consent.affirmative |
| Do not misrepresent material facts, including that the plan auto-renews Do not misrepresent, expressly or by implication, any material fact related to the transaction, including the inclusion of an automatic renewal or continuous service, or any material fact about the underlying good or service. | Cal. Bus. & Prof. Code § 17602(a)(7) | always | — | medium | signup.disclosure.autorenew_language, signup.disclosure.conspicuous |
| Send a retainable acknowledgment with the renewal terms, cancellation policy and how to cancel Provide an acknowledgment, in a form the consumer can retain (e.g. email), that includes the automatic renewal offer terms, the cancellation policy, and information on how to cancel — including the cancellation mechanism required by § 17602(c). It may be sent after the initial order is completed. | Cal. Bus. & Prof. Code § 17602(a)(3), (c)(1), (i)(1) | always | — | high | confirmation.email.sent, confirmation.email.terms, confirmation.email.cancellation_instructions |
| For free gifts/trials, the acknowledgment explains how to cancel before being charged If the offer includes a free gift or trial, the acknowledgment must also disclose how to cancel, and the business must allow the consumer to cancel, before the consumer pays for the goods or services. | Cal. Bus. & Prof. Code § 17602(a)(3) (second sentence) | free trial | — | high | confirmation.email.trial_terms |
| Notice before a free trial or promotional price longer than 31 days ends If the consumer accepted a free gift or trial lasting more than 31 days (or a promotional price lasting more than 31 days), send a notice 3 to 21 days before the trial/promotional period expires stating: that the subscription will automatically renew unless cancelled; the length and other terms of the renewal period; the amount (or range) and frequency of the charges; one or more ways to cancel; a link (or other electronic method) to the cancellation process if sent electronically; and the business's contact information. | Cal. Bus. & Prof. Code § 17602(a)(8), (b)(1) | free trial, trial ≥ 32 days | 3-21 days before the trial ends | high | reminder.trial_ending, config.trial_reminder_enabled |
| Renewal notice for initial terms of one year or longer If the consumer accepted an offer with an initial term of one year or longer that automatically renews unless cancelled, send the § 17602(a)(8) notice (renewal statement, renewal length and terms, amount/range and frequency of charges, cancellation methods, cancellation link if electronic, contact information) 15 to 45 days before it renews. | Cal. Bus. & Prof. Code § 17602(a)(8), (b)(2) | term ≥ 12 months | 15-45 days before renewal | high | reminder.annual_renewal |
| Offer a cost-effective, timely, easy-to-use cancellation mechanism and describe it in the acknowledgment Provide a toll-free telephone number, email address, postal address (if the seller bills directly), or another cost-effective, timely and easy-to-use cancellation mechanism, and describe it in the acknowledgment. | Cal. Bus. & Prof. Code § 17602(c)(1) | always | — | high | cancel.mechanism_findable, confirmation.email.cancellation_instructions |
| Phone cancellation lines must be answered promptly; voicemail cancellations handled next business day If cancellation is offered by toll-free number, answer calls promptly during normal business hours and do not obstruct or delay cancellation; if the consumer leaves a cancellation voicemail, process the cancellation or call back within one business day. | Cal. Bus. & Prof. Code § 17602(c)(2) | always | — | medium | cancel.flow_friction |
| Online sign-ups must be able to cancel online, at will, immediately ("click to cancel") A business that lets consumers accept an offer online must let them terminate exclusively online, at will, and without further steps that obstruct or delay immediate termination, via either a prominently located direct link or button (in the account/profile or device/user settings) or an immediately accessible termination email formatted and provided by the business that the consumer can send without additional information. The business may require account login/authentication, but a consumer unable or unwilling to authenticate online must be able to cancel offline. | Cal. Bus. & Prof. Code § 17602(d)(1)-(3) | online sign-up | — | critical | cancel.online_available, cancel.mechanism_findable, cancel.flow_friction, config.portal_cancel_enabled |
| Save offers only with a continuously displayed "click to cancel" option Retention offers or information about the effect of cancelling are not an obstruction only if the consumer can still cancel: online, any discount/retention offer must be shown together with a prominently located, continuously and proximately displayed direct link or button labelled "click to cancel" (or similar); by phone, the consumer must first be told clearly that they can complete cancellation at any time by saying "cancel". Once the consumer uses that option, the cancellation must be processed promptly. | Cal. Bus. & Prof. Code § 17602(e) | always | — | high | cancel.flow_friction, cancel.confirmation |
| Cancellation in the same medium used to sign up Cancellation must be available in the same medium the consumer used to activate the subscription, or the medium in which the consumer is accustomed to interacting with the business. If the subscription was activated by phone, a retainable cancellation phone number must be available and clearly and conspicuously displayed on the website. | Cal. Bus. & Prof. Code § 17602(f) | always | — | high | cancel.online_available, cancel.mechanism_findable |
| Notice of material changes before they take effect Before implementing a material change in the terms of an accepted automatic renewal or continuous service, give the consumer a clear and conspicuous notice of the change and information on how to cancel, in a retainable form. | Cal. Bus. & Prof. Code § 17602(g)(1), (i)(3) | always | any time before the price change | high | reminder.price_change |
| Price-change notice 7 to 30 days in advance For any change in the fee charged under an existing automatic renewal or continuous service (including changes the consumer previously agreed to), provide a clear and conspicuous notice of the fee change and retainable information on how to cancel no less than 7 and no more than 30 days before the change takes effect. | Cal. Bus. & Prof. Code § 17602(g)(2), (i)(3) | always | 7-30 days before the price change | high | reminder.price_change |
| Annual reminder of the subscription terms Send an annual reminder to consumers under an annual automatic renewal agreement or continuous service agreement, in the medium that activated the subscription or the medium the consumer is accustomed to (telephone, mail, or email; phone, mail or any internet-based communication for in-person or voice sign-ups), disclosing the product or service, the frequency and amount of the charges, and how to cancel. | Cal. Bus. & Prof. Code § 17602(h), (i)(4) | always | — | high | reminder.annual_terms_notice |
| Terms must allow online sign-ups to cancel online, at will and immediately Consumers who accepted an automatic renewal offer online must be able to terminate exclusively online, at will, and without steps that obstruct or delay immediate termination. Terms that require a phone call, a letter, written notice or a notice period before cancelling conflict with that right. | Cal. Bus. & Prof. Code § 17602(d)(1) | online sign-up | — | high | terms.cancellation_policy_consistent |
| Terms of service restate the automatic renewal offer terms The automatic renewal offer terms (that the subscription continues until canceled, the cancellation policy, the recurring charges, the renewal term and how to cancel) must be presented clearly before the subscription is fulfilled. The Terms of service the consumer agrees to should state the same terms, so the contract does not silently differ from the checkout disclosure. | Cal. Bus. & Prof. Code §§ 17601(b), 17602(a)(1) | always | — | low | terms.renewal_terms_present |
Remedies
The ARL is enforced through California's Unfair Competition Law (§ 17604): the Attorney General, district attorneys and private plaintiffs. Goods sent without the required consent are treated as an unconditional gift to the consumer (§ 17603).
Check against California only
Shell
checkbox check disclosure --text "Subscribe for \$9.99/month. Cancel anytime." --price 9.99 --interval month \
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