California's automatic renewal law is one of the more detailed state subscription statutes, and the law firm Benesch names California as one of the two main venues for private class actions over renewals. The law was amended with effect from the middle of 2025.
The amended text is specific. It says what has to be on the sign-up page, what goes in the confirmation, how cancellation has to work, and when reminders and fee notices are due. This post goes through section 17602 in that order.
The California automatic renewal law at a glance
It regulates the sign-up page, the confirmation, the cancellation path, reminders and fee changes for subscriptions sold to California consumers.
The table lists the main requirements with the subdivision each comes from. We read the text of section 17602 on a public copy of the California codes that was stamped as verified on 11 November 2026. The official legislative site did not load for us, so check it before relying on a subdivision letter.
| Topic | What section 17602 says | Subdivision |
|---|---|---|
| Disclosure | Renewal terms presented clearly and conspicuously, near the request for consent, before the agreement is fulfilled | (a)(1) |
| Consent | Express affirmative consent to the automatic renewal terms before charging | (a)(2), (a)(4) |
| Acknowledgment | Terms, cancellation policy and how to cancel, in a form the consumer can keep | (a)(3) |
| Consent records | Verification kept three years, or one year after termination, whichever is longer | (a)(6) |
| Free trial or promotion over 31 days | Notice 3 to 21 days before it ends | (b)(1) |
| Initial term of a year or more | Notice 15 to 45 days before renewal | (b)(2) |
| Online cancellation | Available online, at will, without steps that obstruct or delay | (d)(1) |
| Same medium | Cancellation in the medium used to sign up, or one the consumer normally uses with the business | (f) |
| Fee change | Notice 7 to 30 days before the change | (g)(2) |
| Annual reminder | A yearly reminder of the product, the charge and how to cancel | (h) |
What changed on 1 July 2025?
Amendments made by Assembly Bill 2863 began to apply to contracts entered into, amended or extended on or after that date.
Davis+Gilbert reports that AB 2863 was signed in September 2024. The statute's own text sets the scope: the amendments 'shall only apply to a contract entered into, amended, or extended under this article on or after July 1, 2025'.
Davis+Gilbert's summary lists the main additions as same-medium cancellation, annual reminders and advance notice of fee changes. The current text also addresses save offers, asks for consent to the renewal terms themselves, sets a record-keeping period and bars misrepresentations. The sections below take each in turn.
What has to be on the sign-up page?
The renewal terms, shown clearly and conspicuously next to the consent request, with nothing that undermines the consent.
Subdivision (a)(1) makes it unlawful to fail to present the automatic renewal or continuous service offer terms in a clear and conspicuous manner before the subscription or purchasing agreement is fulfilled. The terms must appear in visual proximity to the request for consent, or in temporal proximity when the offer is made by voice. If the offer includes a free gift or trial, it must also explain the price that will be charged after the trial ends.
Consent comes next. Under (a)(2) a business may not charge the consumer's card or account without first obtaining affirmative consent, and that includes an offer made at a promotional or discounted price for a limited time. Subdivision (a)(4) separately bars failing to obtain 'express affirmative consent to the automatic renewal or continuous service offer terms'.
Two further prohibitions police the page around the consent. Subdivision (a)(5) bars including any information in the contract that 'interferes with, detracts from, contradicts, or otherwise undermines' the consumer's ability to give that consent. Subdivision (a)(7) bars misrepresenting any material fact, expressly or by implication.
What goes in the confirmation and the reminders?
An acknowledgment with the terms and cancellation instructions, then dated notices before a long trial ends, before a yearly term renews, and once a year.
Subdivision (a)(3) requires an acknowledgment that includes the automatic renewal offer terms, the cancellation policy and information on how to cancel, in a manner the consumer can retain. If the offer includes a free gift or trial, the acknowledgment must disclose how to cancel and allow the consumer to cancel before paying.
Subdivision (a)(8) describes a notice with six items: that the subscription will renew unless cancelled, the length and terms of the renewal period, the cost and frequency of charges, at least one way to cancel, a link or other accessible cancellation method when the notice is electronic, and the business's contact information. Subdivision (b) says when it is due. For a free gift or trial, or a promotional price, lasting more than 31 days, it is due at least 3 and at most 21 days before that period ends. For an initial term of one year or longer, it is due at least 15 and at most 45 days before renewal. Where both apply, the text says only the second notice is required.
The annual reminder is separate. Under subdivision (h), a business must send a yearly reminder in the same medium the consumer used to activate the service or one they normally use with the business. It must state the product or service, the frequency and amount of the charge, and how to cancel.
| Notice | When it is due | Subdivision |
|---|---|---|
| Acknowledgment | After sign-up, in a form the consumer can keep | (a)(3) |
| End of a free trial or promotion longer than 31 days | 3 to 21 days before the period ends | (b)(1) |
| Renewal of an initial term of one year or longer | 15 to 45 days before renewal | (b)(2) |
| Fee change | 7 to 30 days before the change takes effect | (g)(2) |
| Other material change | Before the change takes effect | (g)(1), (i) |
| Annual reminder | Once a year | (h) |
How does cancellation have to work?
A consumer who signed up online must be able to cancel online without obstruction, and every consumer must be able to cancel in the medium they used to sign up.
Subdivision (c) requires a toll-free telephone number, an email address, a postal address if the business bills directly, or another cost-effective, timely and easy-to-use mechanism for cancellation, described in the acknowledgment. A business that offers telephone cancellation must answer promptly during normal business hours and must not obstruct or delay the request. If a consumer leaves a cancellation voicemail, the business has one business day to process it or call back.
Subdivision (d) covers online sign-ups. The consumer must be allowed to terminate 'exclusively online, at will, and without engaging any further steps that obstruct or delay' the ability to end the subscription immediately. The text gives two acceptable forms: a prominently located link or button in the account, profile or settings, or an immediately accessible termination email, provided by the business, that the consumer can send without adding further information. A business may ask the consumer to log in or verify their identity first.
Subdivision (f) is the same-medium rule. Cancellation must be available in the same medium the consumer used to enter the agreement, or one they are accustomed to using with the business, such as in person, by telephone, by mail or by email.
Are save offers allowed?
Yes, as long as the consumer can still cancel and the route to cancel is shown at the same time.
Subdivision (e) says a business does not obstruct cancellation by presenting a discount offer, a retention benefit or information about the effect of cancelling. The permission comes with conditions for each channel.
On the telephone, the business must first tell the consumer that they can complete the cancellation at any time by saying they want to cancel, or words to that effect. If the consumer says so, the business must process the cancellation promptly.
Online, the business must simultaneously display a prominent direct link or button labeled 'click to cancel', or similar wording, with the offer. It has to stay on screen, and if the consumer uses it the business must process the cancellation promptly. A cancellation flow that shows an offer on one screen and hides the cancel control until a later one does not match that description.
What records does the law ask for?
It asks for verification of each consumer's consent, kept for at least three years or one year after the contract ends, whichever is longer.
Subdivision (a)(6) is the record-keeping rule. It is short, and it puts the burden on the business to be able to show, per subscriber, that consent was given.
Practitioners describe the cases as contests over logs. A California lawyer's memo that reviewed roughly two dozen state-court complaints filed between October 2024 and early 2026 calls them template-driven and says they turn on 'logs of consent timestamp, disclosure version served, acknowledgment delivery, and pre-renewal notice delivery'. That memo is one practitioner's view, and its author also sells demand-letter templates.
The list below follows the statute's own requirements. It describes what the text makes relevant and is not a statement of what any particular business must keep.
- The sign-up page as each subscriber saw it, with the renewal terms and their position on the page
- The consent action and its date and time
- The acknowledgment sent, with proof of delivery
- Each trial-end, renewal and annual notice, with the date sent
- Each fee-change notice and the date the change took effect
- Each cancellation request, the channel it came through and when it was processed
- Any save offer shown, and whether the cancel control was displayed with it
Who enforces the law, and what has it cost?
District attorneys enforce it directly, and private plaintiffs reach it through California's unfair competition and consumer remedies statutes.
Benesch reports that after the decision in Mayron v. Google the automatic renewal law has no direct private right of action. Plaintiffs instead sue under the Unfair Competition Law and the Consumers Legal Remedies Act. Benesch also points to the law's unconditional gift provision, which it says supports claims for full restitution of what the subscriber paid.
Public enforcement has mostly come from a task force of district attorneys and a city attorney. Benesch lists a consent judgment with HelloFresh on 18 August 2025 for 7.5 million dollars, made up of 6.38 million in penalties and 1 million in restitution, and earlier settlements ranging from 650,000 dollars to 3.58 million.
Private cases have reached the same scale. Benesch reports a 7.5 million dollar class settlement in Dutcher v. Google over YouTube TV renewals, announced in July 2026 with a final approval hearing set for 15 October 2026. We did not confirm the outcome of that hearing. Benesch also counted at least 12 consumer class actions filed against e-commerce retailers within a few weeks around September 2025. Jeffer Mangels published an article in April 2026 on demand letters that cite the automatic renewal law and the Consumers Legal Remedies Act. It observes that 'even well-intentioned businesses using standard e-commerce platforms can find themselves exposed'.
How does California sit beside federal law?
A federal statute sets a general floor for online subscriptions, and the more detailed federal rule that would have matched California was vacated in 2025.
The Restore Online Shoppers' Confidence Act, at 15 U.S.C. 8403, makes it unlawful to charge a consumer for goods or services sold online through a negative option feature unless the seller clearly and conspicuously discloses all material terms before obtaining billing information, obtains express informed consent before charging, and provides simple mechanisms to stop recurring charges. It sets those three conditions and has none of California's time windows.
The FTC tried to add detail. Its amended negative option rule, often called click-to-cancel, was vacated by the Eighth Circuit in the summer of 2025 on procedural grounds. Covington reports that the FTC announced a new advance notice of proposed rulemaking on 11 March 2026, published on 13 March 2026, with comments due by 13 April 2026. The research notes behind this post found no proposed rule after that.
Common questions
Does the California automatic renewal law apply to businesses outside California?
We did not open the section that sets the law's reach, so this post does not answer that from the text. Benesch describes a California class settlement covering California residents who paid for a renewal. A business based elsewhere that sells subscriptions to people in California should ask counsel whether it is in scope.
When did the amended law take effect?
The amendments apply to a contract entered into, amended or extended on or after 1 July 2025. Subscriptions that began earlier come under the amended text when they are amended or extended.
Can I show a discount before letting someone cancel online?
The statute allows a retention offer, but the offer must be shown together with a prominent, continuously displayed link or button to cancel. If the consumer uses it, the cancellation has to be processed promptly.
How much notice does a price increase need?
Section 17602(g)(2) requires a clear and conspicuous notice of a fee change no less than 7 days and no more than 30 days before the change takes effect, with information on how to cancel that the consumer can keep.
Can a customer sue directly under the automatic renewal law?
Benesch reports that the law has no direct private right of action after Mayron v. Google. Plaintiffs bring claims through the Unfair Competition Law and the Consumers Legal Remedies Act, and district attorneys enforce the law directly.
Does this post cover the whole law?
No. It covers section 17602 as we read it in November 2026. The article also has definitions, exemptions and remedies in other sections that we did not open, and this post is not legal advice.
Reviewed November 13, 2026
Consentra is software. Nothing on this site is legal advice, and using Consentra does not by itself make a business compliant with any law or carrier rule. Whether a rule applies to your business is a question for your counsel.
Sources
- California Public Law: Business and Professions Code section 17602 (text current from 1 January 2025; verified 11 November 2026)
- Davis+Gilbert: California's enhanced automatic renewal law is signed into law (2024)
- Benesch: A dozen new lawsuits and two 7.5 million dollar settlements signal a new era for automatic renewal compliance (23 September 2025)
- Benesch: The coming state-law litigation wave of 2026-27, subscription trap class actions (14 August 2026)
- Terms.law: Auto-renewal enforcement in California (undated practitioner memo)
- Jeffer Mangels: ARL and CLRA demand letters against subscription-based businesses, how to respond (22 April 2026)
- Cornell Legal Information Institute: 15 U.S.C. 8403, negative option marketing on the internet (read November 2026)
- Covington: FTC launches new rulemaking on the Negative Option Rule (March 2026)