# Subscription compliance checklist (2026)

> A practical, cited checklist for anyone building a subscription — the checkout disclosure, consent, acknowledgment email, trial and renewal notices, price changes, online cancellation and records — built to the strictest US automatic-renewal rules as of November 2026.

US automatic-renewal law comes down to four obligations that every regime shares — **show the renewal terms clearly
next to the buy button before you take card details, get a separate and provable "yes" to the renewal, confirm the deal
in an email the customer can keep, and let people cancel online as easily as they signed up** — plus notice rules that
vary by state. Because consumer-protection laws follow where the **customer** is, a subscription sold online sells into
every state at once. The practical baseline is to build to the strictest rules (California and New York) once, then add
the handful of state twists below.

Each item links the requirement it comes from. The full text of every rule is on the [law pages](https://checkbox.site/laws/federal) and in
the [open dataset](https://checkbox.site/laws/data).

## Before you write code: know your plan {#facts}

The rules that apply depend on a few facts about the offer. Write them down; every check below uses them.

- Price, billing interval and the **renewal term** (monthly, yearly, "annual, paid monthly").
- **Free trial or introductory price**, and its length in days (31, 15 and 14 days are common thresholds).
- Whether customers sign up **online**, in person or by phone — cancellation must work in the same medium.
- How customers pay: **debit card or ACH** adds Regulation E ([federal law](https://checkbox.site/laws/federal)).
- Whether you sell to **businesses** too: Colorado, DC and Virginia reach some business customers.

## 1. Checkout: the disclosure {#disclosure}

Show, **before the customer enters payment details** and **next to the button that starts the subscription**:

- [ ] That it **renews automatically until cancelled** (the words "automatically renews" or similar, not only "/month").
- [ ] The **price** of each renewal, and that it may change if that is possible.
- [ ] **How often** you charge and the **renewal term** (for example "every month", "every year").
- [ ] **How to cancel** (where and how, ideally a URL) and the cancellation policy.
- [ ] For a **free trial or intro price**: the price after the trial, the date or length of the trial, and how to cancel
      before being charged.
- [ ] Any **minimum purchase** or commitment, and any early-termination fee.
- [ ] The **deadline to act** to avoid the next charge, by date or frequency (New York, NYC).

Make it **clear and conspicuous**: California defines that as larger type than the surrounding text, contrasting type,
font or color, or text set off by symbols — legible grey fine print is the failure plaintiffs cite most often. A boxed
paragraph at body size directly above the button is a safe design.

Sources: [15 U.S.C. § 8403(1)](https://checkbox.site/laws/federal#signup), [Cal. Bus. & Prof. Code § 17602(a)(1)](https://checkbox.site/laws/california#signup),
[N.Y. Gen. Bus. Law § 527-a](https://checkbox.site/laws/new-york#signup).

```bash
checkbox check disclosure \
  --text "Acme Pro renews automatically every month at \$19.99 (plus tax) until you cancel. Cancel anytime online at https://acme.example/account/cancel." \
  --merchant-name Acme --price 19.99 --interval month \
  --consent-checkbox --consent-label "I agree that Acme Pro renews every month at \$19.99 until I cancel." \
  --boxed --font-size 16 --offline
```

## 2. Checkout: consent {#consent}

- [ ] Get **affirmative consent to the renewal terms**, separate from agreeing to the purchase or the Terms of Service.
      An unchecked, required checkbox whose label states the renewal is the most robust design; a clearly labelled
      consent button stating the renewal, with the terms next to it, is accepted by California prosecutors in a
      settlement but is not settled law.
- [ ] Never **pre-check** the box.
- [ ] Offer a plain way to **decline** (not "No, I don't want to save money").
- [ ] **Record** each consent: what the customer saw, the checkbox state, the time. California requires verification
      of consent to be kept for three years, or one year after the contract ends if longer.

Sources: [15 U.S.C. § 8403(2)](https://checkbox.site/laws/federal#signup), [Cal. Bus. & Prof. Code § 17602(a)(4), (a)(6)](https://checkbox.site/laws/california#signup).
Checkbox [consent receipts](https://checkbox.site/docs/receipts) record exactly this, per checkout.

## 3. After sign-up: the acknowledgment {#acknowledgment}

- [ ] Send an **acknowledgment** the customer can keep (an email works) right after sign-up.
- [ ] Repeat the renewal terms, the price and frequency, the cancellation policy and **how to cancel**.
- [ ] For a free trial, explain **how to cancel before being charged**.
- [ ] Payment-processor receipts usually do not include the renewal terms or cancellation instructions: send your own.

Sources: [Cal. Bus. & Prof. Code § 17602(a)(3)](https://checkbox.site/laws/california#confirmation), [N.Y. Gen. Bus. Law § 527-a](https://checkbox.site/laws/new-york#confirmation).

```bash
checkbox check email --kind acknowledgment --subject "Welcome to Acme Pro" \
  --text "Thanks for subscribing to Acme Pro. Your subscription renews automatically every month at \$19.99 until you cancel. Cancel anytime online at https://acme.example/account/cancel." \
  --merchant-name Acme --price 19.99 --interval month --cancel-url https://acme.example/account/cancel --offline
```

## 4. Before charges: notices {#notices}

- [ ] **Trial ending:** for trials longer than 31 days, 3 to 21 days before the trial ends (California, New York);
      shorter thresholds elsewhere (Illinois 15+ days, Maryland over 14 days, Utah and Louisiana any length). See
      [free-trial notices](https://checkbox.site/docs/learn/free-trial-notices).
- [ ] **Renewal of a term of a year or more:** California and New York 15–45 days before; about ten states 30–60 days
      before; Colorado 25–40 days. **One notice sent 30 to 40 days out fits nearly all of them.**
- [ ] **Monthly plans:** Massachusetts expects a notice or a per-charge notice with cancellation instructions;
      Connecticut, Minnesota and Colorado expect a yearly reminder for every plan.
- [ ] **Price increases and material changes:** 7–30 days before (California), 5 business days to 30 days (New York),
      and New York requires consent to the new price or a post-charge cancellation right with a pro-rata refund. See
      [price increases](https://checkbox.site/docs/learn/subscription-price-increases).
- [ ] **Annual reminder** of the terms (California, Arkansas, Connecticut, Minnesota).

Get exact send dates for your plan from [`checkNoticeSchedule`](https://checkbox.site/docs/api/checks#checkNoticeSchedule), which
intersects every applicable window and returns the fewest sends.

## 5. Cancellation {#cancellation}

- [ ] Customers who signed up **online can cancel online**, immediately, without calling or chatting.
- [ ] The cancel option is **easy to find** (account settings, one click from the account page).
- [ ] Cancellation is **as easy as sign-up**, in the same medium (New York, NYC, Virginia, Maryland, Massachusetts).
- [ ] **Save offers** never block the exit: California and Arkansas require a continuously displayed "click to cancel"
      option next to them; Minnesota allows them only if the customer opts in.
- [ ] **Confirm** the cancellation on screen and by email, with the date service ends.
- [ ] **Stop charging** after the request. NYC requires refunding everything charged after the first attempt to cancel.
- [ ] Your **Terms of Service** do not contradict any of this ("no cancellations", "cancel by phone only").

See [how to build an online cancellation flow](https://checkbox.site/docs/learn/online-cancellation-flow).

## 6. Payments and records {#records}

- [ ] **Debit card or ACH:** a signed (or e-signed) authorization for recurring transfers, and a copy to the customer,
      ideally before the first debit (Regulation E).
- [ ] Keep, per customer: the disclosure as shown, the consent, the acknowledgment sent, every notice sent and every
      cancellation request. When a claim arrives, **records of what that customer saw** are what win or lose it.

## 7. Claims that do not match reality {#claims}

- [ ] "Cancel anytime", "no commitment" and "free" must be true as the refund and term policies actually work.
- [ ] A one-time purchase or a trial must not silently become a subscription.

These are the theories behind several of the largest recent settlements; see
[what plaintiffs' lawyers look for](https://checkbox.site/docs/learn/what-plaintiffs-look-for).

## Automate the checklist {#automate}

Checkbox checks every item above against the federal rules and every state law in its catalog, on your real pages and
emails, and tells you (or your coding assistant) exactly what to change. It is free to start.

- With a coding assistant: connect the MCP server at `https://app.checkbox.site/mcp` and ask it to make your subscription flow compliant
  with automatic-renewal laws using Checkbox.
- With the API: [quickstart](https://checkbox.site/docs/quickstart) · [preflight checks](https://checkbox.site/docs/preflight) · [compliance plan](https://checkbox.site/docs/guides/compliance-plan).

```text title="Prompt for your coding assistant"
We sell a subscription. Using Checkbox (https://checkbox.site/docs/learn/subscription-compliance-checklist.md), check
our checkout disclosure and consent, acknowledgment email, trial / renewal / price-change notices and cancellation flow
against US automatic-renewal laws, apply the corrections it returns, and re-check until everything passes or only
needs_review items remain. Ask me before changing prices, terms or anything legal.
```

> **Not legal advice**
>
> A practical checklist, not legal advice. It is built from Checkbox's legal catalog and litigation research, which are
> drafted from the cited sources and pending attorney review. Have counsel review your final terms.