Rule 32 of 33

Subscription auto-renewal laws (ROSCA + state ARLs)

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.

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.

What this looks like in practice. A customer signs up on your site in two clicks, but to cancel they have to phone in and wait. That asymmetry is the violation - Amazon paid $2.5B to the FTC over exactly this.

How to check whether you comply

The checkIf 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.

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.

Primary source FTC - ROSCA ↗ Real case Amazon: $2.5B to the FTC for a hard-to-cancel subscription ↗

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

Rule 33Colorado AI Act (SB 24-205, as amended) Rule 2ADA Title III (US web accessibility) Rule 3Accessible Canada Act (federal) Rule 4European Accessibility Act All of themThe full 33-rule table, searchable

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 risk

This 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.