Auto-renewal laws and your subscription rights in the U.S.
In the U.S., subscriptions sold online are covered by the federal Restore Online Shoppers' Confidence Act (ROSCA), which requires clear disclosure of terms, your express consent before charging, and a simple way to stop recurring charges. Many states add their own automatic renewal laws. The FTC's 2024 "click-to-cancel" rule, however, was vacated by a federal appeals court in 2025 and is not in effect.
What "negative option" means
A negative option is any offer where your silence or failure to cancel is treated as agreement to be charged. Free trials that convert to paid plans, automatic renewals, and continuity plans that ship products on a schedule are all negative options. They are legal, but federal and state laws set rules for how they must be sold.
Federal law: the Restore Online Shoppers' Confidence Act (ROSCA)
Congress passed ROSCA in 2010. For negative option offers sold over the internet, it requires sellers to:
- Clearly disclose all material terms before collecting billing information — including the price, that charges will recur, and how to cancel.
- Obtain the consumer's express informed consent before charging.
- Provide simple mechanisms to stop recurring charges.
The FTC enforces ROSCA and has brought cases against companies over hidden terms and difficult cancellation processes. ROSCA remains in effect.
The FTC "click-to-cancel" rule: vacated
In October 2024, the FTC finalized amendments to its Negative Option Rule, widely called the click-to-cancel rule. Among other things, it would have required cancellation to be as easy as signing up.
In July 2025, the U.S. Court of Appeals for the Eighth Circuit vacated the rule before its main provisions took effect, finding that the FTC had not followed required rulemaking procedures. As of this writing, the click-to-cancel rule is not in effect. Be skeptical of articles or customer service scripts that cite it as current law. For updates, check FTC.gov.
The vacatur does not erase other protections. ROSCA still applies, the FTC can still act against unfair or deceptive practices under the FTC Act, and state laws continue to apply.
State automatic renewal laws
Many states have their own automatic renewal laws (ARLs), which often go further than federal law. California and New York are among the states with well-known laws, and others have followed. Requirements differ, but common provisions include:
| Common requirement | What it means for you |
|---|---|
| Clear and conspicuous disclosure | Renewal terms must be displayed prominently, near the purchase button |
| Affirmative consent | You must actively agree to the automatic renewal terms |
| Acknowledgment | The company must send you a confirmation with the terms and how to cancel |
| Easy cancellation | Some states require online cancellation if you signed up online |
| Advance notice | Some states require notice before a free trial converts or before certain renewals or price changes |
California's law, for example, requires that consumers who sign up online be able to cancel online, and it has been amended to add further requirements. Because details and effective dates vary, check your state attorney general's website for the rules where you live.
Industry and platform rules
Separate from law, the major platforms have their own policies:
- Apple and Google Play manage every subscription bought through their stores in one standard settings screen, which shows renewal dates and a cancel button. Subscriptions you buy on a company's own website are not listed there.
- Card networks have rules for merchants offering trials and recurring billing, and card issuers can block recurring charges from a merchant at your request.
These policies change and are not legal rights, but they often make cancellation easier than going through the merchant directly.
Your financial dispute rights
If you are charged anyway, two federal laws help:
- Fair Credit Billing Act — for credit cards. You can dispute billing errors in writing within 60 days after the statement containing the charge was sent.
- Electronic Fund Transfer Act and Regulation E — for debit cards and bank transfers. You can report errors within 60 days of the statement and stop future preauthorized recurring transfers by notifying your bank at least three business days in advance.
See how to dispute a subscription charge for step-by-step instructions.
What a fair subscription offer looks like
Use this as a checklist. A trustworthy offer should show, before you pay:
- The total price after any trial or introductory period.
- How often you will be charged.
- When the first charge happens.
- How to cancel, ideally in the same way you signed up.
- Whether you keep access if you cancel early.
If any of these are missing or buried, consider walking away — or at minimum take screenshots and set reminders as described in using free trials without getting charged.
How to report a company
- FTC: ReportFraud.ftc.gov for deceptive trial offers, hidden terms, and cancellation obstacles.
- CFPB: consumerfinance.gov/complaint if your bank or card issuer mishandles a dispute.
- State attorney general: for violations of your state's automatic renewal or consumer protection laws. The National Association of Attorneys General lists each state's office at naag.org.
Reports help regulators identify patterns and bring enforcement actions, even if they cannot resolve your individual case.
Keep yourself protected
Laws set minimums, but the most reliable protection is your own system: know every subscription you have, set reminders before renewals, and keep records of every cancellation. Our renewal tracking guide shows how to set that up in an afternoon.