Subscription auto-renewal laws (ROSCA + state ARLs)
Auto-renewal rules under ROSCA and a growing set of state laws require clear up-front disclosure of terms, express informed consent before charging, and cancellation that is at least as easy as signing up. Phone-only or retention-gauntlet cancellation is the specific practice regulators target.
What the rule requires
Cancelling must be as easy as signing up - even after the 2024 federal rule was struck down.
Who it catches
Any business billing on an auto-renewing subscription - SaaS, memberships, retainers. California’s amended ARL (Bus. & Prof. Code §17602, since 1 Jul 2025) is the strictest; the FTC still enforces ROSCA and Section 5 nationwide.
How to check whether you comply
Read it yourself
We would rather you checked us than took our word for it. This links to the law as published, not to our summary of it.
Questions people ask
What are the rules for auto-renewing subscriptions?
Auto-renewal rules under ROSCA and a growing set of state laws require clear up-front disclosure of terms, express informed consent before charging, and cancellation that is at least as easy as signing up. Phone-only or retention-gauntlet cancellation is the specific practice regulators target.
Who does Subscription auto-renewal laws (ROSCA + state ARLs) apply to?
Any business billing on an auto-renewing subscription - SaaS, memberships, retainers. California’s amended ARL (Bus. & Prof. Code §17602, since 1 Jul 2025) is the strictest; the FTC still enforces ROSCA and Section 5 nationwide.
How do I check whether we comply with Subscription auto-renewal laws (ROSCA + state ARLs)?
If a customer signs up online, can they cancel online in the same number of steps? Do you capture affirmative consent to the renewal terms and send pre-renewal notice for long free trials? Obstructed cancellation is the trigger. You can also run our free website check, which tests 25 technical items in about twenty seconds, or book a review if this rule needs a documented answer.
Other rules that catch the same businesses
Find out which of the 33 apply to you
The fine risk check asks a few questions about your business and tells you which rules catch you, with the deadlines. Nothing you tick leaves your browser.
Check my fine riskThis page summarises a legal obligation in plain language so you can work out whether it applies to you. It is not legal advice, and the primary source linked above governs. Last reviewed 2026-10-03.