Auto-renewal laws in the US and Canada: where you have protection

Auto-renewal laws — "ARLs" — exist in nearly every US state and Canadian province. They vary, and the variation matters.

The most comprehensive US state framework is California's Automatic Renewal Law (Business and Professions Code § 17600 et seq.), originally enacted in 2010 and significantly strengthened in 2018 and 2024. The statute requires clear and conspicuous disclosure of auto-renewal terms, affirmative consent (not bundled into a general Terms of Service checkbox), and an online cancellation mechanism that does not require contact with a customer service representative.

California Business & Professions Code § 17602(c): "A consumer who accepts an automatic renewal or continuous service offer online shall be allowed to terminate the automatic renewal or continuous service exclusively online, which may include a termination email formatted and provided by the business that a consumer can send to the business without additional information."

Other US states with similar frameworks include New York (General Business Law § 527-a), Illinois, Oregon, and Washington. Each adapts the California model with varying strictness on disclosure and cancellation. Where state law is more demanding than federal rules, state law governs.

At the federal level, the FTC's 2024 Click-to-Cancel Rule (16 CFR Part 425) sets a national floor. Where state law is stronger, the state law continues to apply.

In Canada, the strongest protections are in Quebec's Consumer Protection Act (CQLR c P-40.1), which requires explicit consent for automatic renewals and provides specific remedies for non-compliant contracts. Ontario, BC, and Alberta operate through their respective consumer protection statutes, which capture auto-renewal abuses through general "unfair business practices" provisions but with less specific framework language.

What this means for consumers

If a subscription is auto-renewing in a jurisdiction with a strong ARL and the provider has not provided clear conspicuous disclosure, affirmative consent (separate from ToS), and an online cancellation path, that provider may be out of compliance. State attorneys general and provincial consumer affairs offices typically accept online complaints and pursue investigations where complaints accumulate.

References

• California Business & Professions Code § 17600–17606. Automatic Renewal Law.
• New York General Business Law § 527-a.
• Quebec Consumer Protection Act (CQLR c P-40.1).
• U.S. FTC Negative Option Rule (16 CFR Part 425), 2024.

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