California subscription auto-renewal law
Effective January 1, 2010 (operative December 1, 2010 per §17606); amended multiple times thereafter · Last reviewed 2026-06-26
The statute
Cal. Bus. & Prof. Code §§ 17600–17606 (Automatic Purchase Renewals)
Effective January 1, 2010 (operative December 1, 2010 per §17606); amended multiple times thereafter
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AB 2863 (2023–2024 Reg. Sess.), amending Cal. Bus. & Prof. Code §§ 17601 and 17602
Effective July 1, 2025; applies to contracts entered into, amended, or extended on or after that date
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What it addresses
Each requirement below is stated in plain English first, then cited to the statute so you can read the primary source.
Disclosure before purchase
Before a consumer submits billing information, a business offering automatic renewal or continuous service must present the offer terms clearly and conspicuously and in visual proximity to the request for consent. Required disclosures include: the length of the automatic renewal term or that the service continues until canceled; any minimum purchase obligation; and the cancellation policy and how to cancel.
Cal. Bus. & Prof. Code §17602(a)(1)–(3)Read the statute →
Under AB 2863 (eff. July 1, 2025), before confirming a consumer's billing information, the business must disclose the amount or range of costs the consumer will be charged and, if applicable, the frequency of those charges unless the consumer takes timely steps to prevent or stop them. This disclosure must be provided in proximity to where billing information is confirmed.
Cal. Bus. & Prof. Code §17602(a)(8) (as amended by AB 2863)Read the statute →
Affirmative consent
The statute requires the business to obtain express affirmative consent to the automatic renewal or continuous service offer before charging the consumer. As amended by AB 2863 (eff. July 1, 2025), consent must be specifically to the automatic renewal or continuous service offer itself, not merely to the overall agreement. The statute also prohibits including contract terms that interfere with, detract from, contradict, or otherwise undermine the consumer's ability to provide that affirmative consent.
Cal. Bus. & Prof. Code §17602(a)(4)–(5) (as amended by AB 2863)Read the statute →
Under AB 2863 (eff. July 1, 2025), a business must maintain consent verification records for a minimum of three years or one year after termination of the automatic renewal or continuous service agreement, whichever period is longer.
Cal. Bus. & Prof. Code §17602(a)(6) (as amended by AB 2863)Read the statute →
Acknowledgment / confirmation
After obtaining the consumer's consent to automatic renewal or continuous service, the business must provide an acknowledgment that includes the automatic renewal offer terms, the cancellation policy, and information on how to cancel, in a manner capable of being retained by the consumer (e.g., by email). If the initial offer included a free or discounted trial period, the acknowledgment must also disclose when the trial period ends and what charges will apply thereafter.
Cal. Bus. & Prof. Code §17602(b)Read the statute →
Cancellation mechanism
The statute requires a business to allow a consumer to cancel through the same method used to sign up or the medium through which the consumer customarily interacts with the business, including telephone, mail, email, or online. The business must not obstruct or delay the consumer's ability to cancel.
Cal. Bus. & Prof. Code §17602(c)Read the statute →
Under AB 2863 (eff. July 1, 2025), for subscriptions entered into online, the business must provide a prominently located and continuously and proximately displayed direct link or button entitled 'click to cancel.' A business may present a retention offer (discount or other benefit) during cancellation only if the 'click to cancel' button simultaneously remains displayed, ensuring the consumer can complete cancellation at any time.
Cal. Bus. & Prof. Code §17602(c)(2)(A) (as amended by AB 2863)Read the statute →
Under AB 2863 (eff. July 1, 2025), when telephone cancellation is offered, the business must connect the consumer promptly to a live person or voicemail during business hours. If the consumer leaves a voicemail, the business must process the cancellation or call the consumer back within one business day. The cancellation phone number must appear clearly and conspicuously on the business's website in a manner capable of being retained by the consumer.
Cal. Bus. & Prof. Code §17602(c)(2)(B); §17602(f) (as amended by AB 2863)Read the statute →
Renewal reminder
Under AB 2863 (eff. July 1, 2025), for annual automatic renewal or continuous service agreements, the business must send an annual reminder to the consumer in the same medium through which the agreement was activated or the medium the consumer customarily uses to interact with the business (including telephone, mail, or email). For agreements originally entered in person or by voice, the reminder may be delivered by telephone, mail, or any internet-based communication. The reminder must disclose: (A) the product or service to which the automatic renewal or continuous service applies; (B) the frequency and amount of associated charges; and (C) the means to cancel.
Cal. Bus. & Prof. Code §17602(h) (added by AB 2863)Read the statute →
Free-trial conversion notice
Under AB 2863 (eff. July 1, 2025), 'free-to-pay conversions' are expressly included within the statutory definition of 'automatic renewal plan' (§17601(6)). A free-to-pay conversion is defined as a provision under which a consumer receives a product or service for free for an initial period and will incur an obligation to pay for the product or service if they do not take affirmative action to cancel before the end of that period. All ARL requirements — including clear and conspicuous pre-purchase disclosure, express affirmative consent, post-enrollment acknowledgment containing the trial end date and charges that will apply, and a simple cancellation mechanism — apply to such offers.
Cal. Bus. & Prof. Code §17601(6); §17602 (as amended by AB 2863)Read the statute →
Price-change notice
Under §17602(g) as amended by AB 2863 (eff. July 1, 2025), a change in the fee charged to a consumer requires clear and conspicuous notice provided no less than 7 days and no more than 30 days before the new fee becomes effective. The notice must include cancellation instructions in a manner capable of being retained by the consumer.
Cal. Bus. & Prof. Code §17602(g) (as amended by AB 2863)Read the statute →
Penalties and enforcement
Violations of the ARL are not a crime (§17604(a)). Civil remedies are available; a good-faith compliance defense is available under §17604. Primary enforcement vehicle is California's Unfair Competition Law (UCL, Bus. & Prof. Code §17200 et seq.): the AG, district attorneys, and city attorneys may obtain civil penalties up to $2,500 per violation (Bus. & Prof. Code §17206), plus restitution and injunctive relief. No direct private right of action exists under the ARL itself (Mayron v. Google LLC, Cal. Ct. App. 2022); private plaintiffs may bring UCL claims under the "unlawfulness" prong where they can establish economic injury caused by an ARL violation. UCL private actions allow restitution but not the $2,500-per-violation civil penalty, which is reserved for public enforcers. Sources: Cal. Bus. & Prof. Code §§ 17604–17605; §17206; Mayron v. Google LLC (2022).
Active government enforcement by CART (California Automatic Renewal Task Force), a coalition of district attorneys' offices from Los Angeles, Santa Clara, Santa Barbara, San Diego, and Santa Cruz counties plus the Santa Monica City Attorney's Office. Notable CART actions: (1) HelloFresh — $7.5M settlement announced August 2025 (LA and Santa Clara County DAs) for alleged misleading of consumers into recurring subscription charges without adequate notice or authorization, in violation of the ARL. (DA press release: https://da.lacounty.gov/media/news/hellofresh-pay-75-million-deceptive-subscription-practices-consumer-protection-lawsuit). (2) Thrive Market — CART, April 2024, $1.1M civil penalties and costs plus $450K restitution. (3) TFG Holdings (ShoeDazzle/JustFab) — multi-state coordinated AG settlement (34 states) for negative option enrollment without consent. Private class-action wave: Following Mayron v. Google LLC (2022), which confirmed UCL unlawfulness prong remains available, a concentrated wave of putative class actions was filed post-July 2025 alleging pre-AB 2863 violations (failure to provide acknowledgment email, inadequate cancellation policy simplicity). Other notable settlements: Peacock ~$3.7M (Oct. 2024); System1/Total Security/Protected.net $2.5M (Jan. 2025). Secondary sources: Benesch Law (beneschlaw.com); Wiley Law (wiley.law).
Caveats
(1) Subdivision letter identifiers (e.g., §17602(a)(4), §17602(h), §17602(c)(2)(A)) are drawn from secondary law-firm sources — principally KTS Law (ktslaw.com) and the Privacy World blog (privacyworld.blog/2024/11/...) — because leginfo.ca.gov section pages require JavaScript to render statutory text and could not be parsed directly via HTTP. The AB 2863 enrolled bill text page was indexed but paragraph-level subdivision letters were not confirmed by direct parse. Verify each subdivision letter against the enrolled AB 2863 text or the official 2025 California Codes before production use. (2) AB 2863 applies to contracts 'entered into, amended, or extended' on or after July 1, 2025; pre-existing contracts not amended or extended since that date may remain governed by the prior statute version. (3) Cal. Bus. & Prof. Code §17605 exempts services provided by businesses regulated by the California PUC, the FCC, or FERC. (4) The statute covers 'consumers'; B2B transactions are not within scope. (5) The scope of 'material change' triggering the §17602(g) price-change notice is not defined by the statute and has not been extensively litigated under the AB 2863 amendments as of June 2026. (6) AB 2863 did not explicitly create a private right of action; the Mayron v. Google LLC holding remains the controlling authority on that question as of June 2026, though it predates the AB 2863 amendments. (7) The KTS Law client alert contained a typographical error citing §16702(a)(4) instead of §17602(a)(4); all citations in this dataset have been corrected to §17602.
Last reviewed 2026-06-26
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