Glossary · Subscriptions

California Automatic Renewal Law (ARL): What It Requires and How Subscribers Enforce It

Published September 16, 2026

The California Automatic Renewal Law (ARL) is the state statute, at Business and Professions Code section 17600 et seq., that controls how a subscription is disclosed, consented to, renewed and canceled in California. Since July 1, 2025 it also requires a seller that signed a consumer up online to offer cancellation online, through a click-to-cancel button displayed alongside any offer made to keep them.

Quick Answer

California's Automatic Renewal Law governs subscriptions, memberships, auto-ship programs and free trials that convert to paid plans. Before charging, a seller must present the renewal terms clearly and conspicuously, obtain the consumer's affirmative consent to those terms specifically, and send an acknowledgement the consumer can keep. It must also provide a cancellation method that is at least as easy as the way the consumer signed up: an online sign-up means an online cancellation. Since amendments took effect on July 1, 2025, a business that shows a retention offer during an online cancellation must display a prominent click-to-cancel link or button alongside it and process the cancellation promptly when it is used.

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What the ARL Requires

The statute covers automatic renewal offers and continuous service offers made to a California consumer: a plan that keeps charging until the consumer cancels, a membership that renews on its own each year, an auto-ship subscription, and a free or discounted trial that converts to a paid plan when the trial runs out.

Four obligations sit at the center of it. The seller must present the automatic renewal terms clearly and conspicuously, in visual proximity to where the consumer agrees, rather than in a linked terms-of-service document. It must obtain the consumer's affirmative consent to the agreement containing those terms, which is why compliant checkouts carry a separate checkbox for the renewal rather than folding it into the main purchase button. It must send an acknowledgement after enrollment that restates the terms and explains how to cancel, in a form the consumer can retain. And it must provide a cost-effective, timely and easy-to-use cancellation mechanism.

The cancellation obligation is the one most consumers meet. A consumer who accepted the offer online must be able to cancel online, without calling anyone and without visiting a location. Longer plans and post-trial conversions also carry reminder-notice duties, so a subscriber is told before an annual plan renews rather than finding the charge afterward.

What Changed on July 1, 2025

Assembly Bill 2863, signed on September 24, 2024, rewrote sections 17601 and 17602 and applies to contracts entered into, amended or extended on or after July 1, 2025. It widened the definitions so free-to-pay conversions are squarely covered, required annual reminders for many plans, and required clear and conspicuous notice before a material change to price or service takes effect.

It also imposed a recordkeeping duty that matters more than it sounds: a business must retain verification of the consumer's affirmative consent for at least three years, or one year after the contract terminates, whichever is longer. That retention window is what lets a regulator audit a checkout flow after the fact instead of taking the seller's word for what the screen looked like. The Federal Trade Commission wrote to the Governor in September 2024 supporting the bill while its own click-to-cancel rule was pending.

Its best-known addition is the cancellation mechanics. A consumer who enrolled through a particular medium is entitled to cancel through that same medium, and the online version of that duty is a direct link or button rather than a form that routes to a person. The amendments also address the telephone equivalent, so a seller that enrolls by phone cannot answer a cancellation call with a queue designed to outlast the caller.

Retention Offers Are Legal; Blocking the Exit Is Not

The statute does not ban the save offer. A business may show a departing subscriber a discount, another retention benefit, or information about what they lose by leaving. Section 17602 permits all three by name.

It attaches a condition to them. When a consumer requests cancellation through an online system and the business responds with a retention offer, the business must simultaneously display a prominently located cancellation link or button, entitled click to cancel or words to that effect, continuously and in proximity to the offer. If the consumer uses it, the business has to process the cancellation promptly and may not otherwise obstruct or delay the consumer's progress toward cancellation.

That is the line the statute draws, and it is a narrow one: an offer the consumer can decline in the same screen is a sales pitch, while an offer the consumer has to answer before the cancel path reappears is an obstruction. A chatbot that will not surface a cancel button until the subscriber has declined five separate discounts, and then transfers them to a live agent with no stated wait, is on the wrong side of that line as to a California consumer.

What a Violation Costs a Seller

Section 17603 supplies the remedy that gives the statute its teeth. Goods sent to a consumer under a continuous service or automatic renewal agreement, where the seller never obtained affirmative consent to the offer terms, are deemed an unconditional gift. The consumer may keep, use or dispose of them with no obligation to the business and no obligation to pay for shipping.

The statute is not a standalone damages vehicle for consumers, so private plaintiffs generally plead ARL violations through California's Unfair Competition Law and the Consumers Legal Remedies Act, which carry restitution, injunctive relief and, under the CLRA, damages. That pairing is why a subscription class action complaint usually lists three statutes rather than one. Federal ROSCA claims often ride alongside for online sign-ups nationwide.

Who Enforces It

Public enforcement is the more active half. The Attorney General and district attorneys may sue, and a group of California district attorneys coordinates automatic-renewal cases through the California Automatic Renewal Task Force, known as CART. Its cases tend to end in stipulated judgments that combine civil penalties, investigative costs, restitution and injunctive terms dictating how the defendant's checkout and cancellation screens must work going forward.

The online grocer Thrive Market is a representative example. CART alleged that the company enrolled members in its membership and auto-ship programs without clearly and conspicuously disclosing the required subscription terms and without sending proper post-enrollment acknowledgements, in violation of the ARL and the False Advertising Law. Thrive Market resolved the matter by stipulated judgment entered April 30, 2024 in Santa Barbara County Superior Court, paying $1,004,000 in civil penalties, $96,000 in investigative costs and $450,000 in restitution, without admitting wrongdoing. The injunctive terms required it to disclose renewal terms clearly, capture consent through a checkbox, email a confirmation carrying the renewal terms, and let members cancel online at will.

Private class actions run in parallel and are collected on OCA's auto-renewal class action page, which tracks the open and closed subscription cases by status.

What a California Subscriber Can Do

Ask for the click-to-cancel control by name. A California consumer who signed up online is entitled to a cancellation link or button on the same screen as any discount the company offers, and saying so to a chat agent frequently produces the account-settings path that was there the whole time.

Keep the record. Screenshots of the cancellation screen, the timestamp of the request, the confirmation number and the acknowledgement email are what turn a disputed cancellation into a documented one, and they are the same evidence a class action would later rely on. If a charge lands after a documented cancellation, disputing the charge with the card issuer is the practical next step, and the step-by-step cancellation guide is in how to cancel a subscription you cannot get out of.

Complaints go to the state. The California Attorney General's office and the local district attorney both take automatic-renewal complaints, and CART's cases are built out of them. This page is informational and is not legal advice.

Frequently Asked Questions

Does the California ARL let a company show me a discount before it cancels my subscription?

Yes. A business may display a discounted offer, another retention benefit, or information about what cancellation will cost the consumer. What it may not do is make that offer the only path forward. The statute requires a prominently located cancellation link or button, labeled click to cancel or words to that effect, displayed continuously and close to the retention offer, and it requires the business to process the cancellation promptly if the consumer uses it.

Does the California ARL apply if I do not live in California?

The statute protects California consumers, and a business routing a non-California subscriber into a chat queue or a retention call is not violating it. In practice many sellers build one compliant cancellation flow rather than two, so subscribers elsewhere sometimes get the benefit of it without being covered. Other states have their own automatic renewal laws: New York amended its own to require a cancellation mechanism as easy as the sign-up, effective November 5, 2025, and New York City adopted a municipal click-to-cancel rule taking effect October 1, 2026.

What happens to goods a company ships me without proper ARL consent?

Business and Professions Code section 17603 provides that goods sent under an automatic renewal or continuous service agreement without first obtaining the consumer's affirmative consent to the offer terms are an unconditional gift. The consumer may use or dispose of them with no obligation to the seller, including no obligation to pay shipping.

Who enforces the California Automatic Renewal Law?

Public enforcement runs through the Attorney General and district attorneys, several of whom coordinate through the California Automatic Renewal Task Force. Consumers generally reach the ARL through California's Unfair Competition Law and the Consumers Legal Remedies Act rather than suing on the renewal statute by itself, which is why most subscription class actions plead those statutes together.


Sources

• California Business and Professions Code §§ 17600–17606 (Automatic Purchase Renewals), including § 17602 (disclosure, consent, acknowledgement and cancellation) and § 17603 (unconditional gift).
Assembly Bill 2863 (2024), amending §§ 17601 and 17602, approved September 24, 2024, operative July 1, 2025.
Los Angeles County District Attorney and Santa Clara County District Attorney, announcements of the $1.55 million Thrive Market stipulated judgment (Santa Barbara County Superior Court, April 30, 2024).
AB 2863 bill status, California Legislative Information.
• Federal Trade Commission, letter to Governor Newsom supporting AB 2863 (September 4, 2024).
• California Civil Code § 1750 et seq. (Consumers Legal Remedies Act); Bus. & Prof. Code § 17200 et seq. (Unfair Competition Law).

About This Page

OpenClassActions.com is a consumer news and information site, not a law firm. This glossary entry is general information about a California statute and is not legal advice about any particular subscription, contract or dispute.


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