Colorado subscription auto-renewal law
Effective January 1, 2022 (enacted via SB 21-190, 2021 session) · Last reviewed 2026-06-26
The statute
C.R.S. § 6-1-732 (Colorado Consumer Protection Act, Art. 1, Part 7)
Effective January 1, 2022 (enacted via SB 21-190, 2021 session)
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SB 25-145 (2025 Regular Session, Ch. 368) amending C.R.S. § 6-1-732 — cancellation provisions effective August 6, 2025; expanded 'consumer' definition effective February 16, 2026
Effective August 6, 2025 (cancellation); February 16, 2026 (consumer definition)
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C.R.S. § 6-1-112 (CCPA civil penalties)
Effective Ongoing; current as of January 1, 2025
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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
C.R.S. § 6-1-732(2)(a) makes it unlawful to fail to present the automatic renewal offer terms in a clear and conspicuous manner before the automatic renewal contract is executed. For offers conveyed by voice, the terms must be presented in temporal proximity to the request for the consumer's consent. Where the offer includes a trial period offer, the offer must also include a clear and conspicuous explanation of the price that will be charged and any further purchase obligations imposed on the consumer after the trial period ends. 'Automatic renewal offer terms' are defined at § 6-1-732(1)(b) to include: (I) that the contract will auto-renew for a set term not to exceed one year unless the consumer gives express written consent for a longer term; (II) a description of the cancellation policy; (III) any recurring charges to the consumer's payment account; (IV) the length of the renewal term; and (V) the minimum purchase obligation, if any.
C.R.S. § 6-1-732(1)(b), (2)(a)Read the statute →
Affirmative consent
C.R.S. § 6-1-732(2)(b) makes it unlawful to utilize an online link presented as part of an automatic renewal contract offer that directs a consumer to detailed information about the contract, unless that link: (I) is available before the consumer elects to purchase any good or service subject to the contract; (II) appears directly adjacent to any online link used by the consumer to purchase the good or service; and (III) is labeled with, or is directly adjacent to, a clear and conspicuous disclosure stating that by purchasing the good or service the consumer agrees to enroll in an automatic renewal contract. This provision constitutes Colorado's primary pre-purchase consent mechanism for online transactions; the statute does not separately require a standalone checkbox or click-to-consent step.
C.R.S. § 6-1-732(2)(b)Read the statute →
Acknowledgment / confirmation
C.R.S. § 6-1-732(2)(c) makes it unlawful to fail to provide the consumer a written acknowledgment that includes the automatic renewal offer terms, the cancellation policy, and information regarding how to cancel, in a manner that is capable of being retained by the consumer. Where the offer includes a trial period offer, the written acknowledgment must also disclose how the consumer may cancel the automatic renewal contract, and the person must allow the consumer to cancel the contract before the consumer is required to pay for the goods or services.
C.R.S. § 6-1-732(2)(c)Read the statute →
Cancellation mechanism
C.R.S. § 6-1-732(2)(d) makes it unlawful to fail to provide a simple, cost-effective, timely, easy-to-use, and readily accessible mechanism for canceling an automatic renewal contract or trial period offer. A person is deemed to comply if they offer: (I) a one-step online cancellation link located on the person's website or contained in an electronic device, service, or communication to the consumer, available immediately or after the consumer completes a reasonable authentication protocol used solely to confirm authorization; or (II) an in-person mechanism at a physical location where the consumer regularly utilizes the goods or services subject to the contract. As amended by SB 25-145 (cancellation provisions effective August 6, 2025): a consumer who enrolled in a subscription online must always be allowed to cancel online via a one-step cancellation link — offering only in-person cancellation no longer satisfies the statute for online enrollees. During the cancellation process, a company may display discount offers or information about the effects of cancellation only if it simultaneously displays a prominently located and continuously proximate direct link to proceed to cancellation; upon the consumer clicking that link, cancellation must be promptly processed without obstruction or delay.
C.R.S. § 6-1-732(2)(d); SB 25-145 (Ch. 368, 2025)Read the statute →
Renewal reminder
C.R.S. § 6-1-732(4) requires a person selling goods or services pursuant to an automatic renewal contract to notify the consumer that the contract will automatically renew or continue unless the consumer cancels. The notice must include the cancellation process, provide clear and accurate information about the sender's identity, and be consistent with the cancellation mechanism required by § 6-1-732(2)(d). Delivery methods: physical mail; email; or another easily accessible form of communication (such as a text message or mobile app) if the consumer specifically authorizes that form or customarily uses it to communicate with the person. Timing: at least 25 and no more than 40 days before the first automatic renewal, and at least 25 and no more than 40 days before each subsequent renewal. Exception for sub-12-month renewal terms: if any renewal term is less than 12 months, the notice is required at least once in the 25-to-40-day window before any renewal that would extend the contract beyond a continuous 12-month period, and at least once in the 25-to-40-day window before any subsequent renewal that would extend the contract beyond each additional consecutive 12-month period.
C.R.S. § 6-1-732(4)(a), (4)(b)Read the statute →
Free-trial conversion notice
C.R.S. § 6-1-732(2)(a) and (2)(c) impose specific requirements where an automatic renewal offer includes a trial period offer. At the time of the offer, the person must include a clear and conspicuous explanation of the price that will be charged and any further purchase obligations imposed after the trial period ends (§ 6-1-732(2)(a)). In the written acknowledgment delivered after enrollment, the person must disclose how the consumer may cancel the automatic renewal contract and must allow the consumer to cancel before the consumer is required to pay for the goods or services (§ 6-1-732(2)(c)). The statute does not prescribe a separate advance notice to be sent a specified number of days before a trial period converts to a paid subscription; the required disclosures are made at the point of offer and at the time of the written acknowledgment.
C.R.S. § 6-1-732(2)(a), (2)(c)Read the statute →
Price-change notice
C.R.S. § 6-1-732(3) requires that if a material change occurs in the terms of an automatic renewal contract that has been accepted by a consumer, the person must provide to the consumer, in a manner that may be retained by the consumer, a clear and conspicuous notice of the material change and information regarding how to cancel the automatic renewal contract, including information about the cancellation mechanism described in § 6-1-732(2)(d). The statute uses 'material change' without separately defining the term; price increases would constitute a material change. The statute does not prescribe a specific advance-notice window for the material change notice (unlike peer states such as New York, which requires 5 to 30 days' advance notice). The notice requirement applies whenever a material change occurs after the consumer has accepted the contract.
C.R.S. § 6-1-732(3)Read the statute →
Penalties and enforcement
Violations of C.R.S. § 6-1-732 constitute deceptive trade practices under the Colorado Consumer Protection Act (C.R.S. § 6-1-105). C.R.S. § 6-1-732(6) vests exclusive enforcement authority in the attorney general and district attorneys (no private right of action expressly provided within § 6-1-732 itself). Under C.R.S. § 6-1-112(1)(a), any person who violates any provision of CCPA Article 1 is subject to a civil penalty of up to $20,000 per violation, with each consumer or transaction constituting a separate violation. Violations against elderly persons carry a penalty of up to $50,000 per violation (§ 6-1-112(1)(c)). Violation of a court order or injunction entered under the CCPA carries an additional civil penalty of up to $10,000 per violation (§ 6-1-112(1)(b)). Source: https://codes.findlaw.com/co/title-6-consumer-and-commercial-affairs/co-rev-st-sect-6-1-112/
No Colorado-specific enforcement actions targeting C.R.S. § 6-1-732 were identified in primary sources consulted. Nationally, multi-state coordinated AG enforcement of negative-option and auto-renewal laws is active: 34 AGs settled with TFG Holdings (online apparel) over unauthorized recurring-charge enrollment; New York AG secured a $600,000 settlement with Equinox in June 2025 over difficult-cancellation practices (cited by Perkins Coie, July 1, 2025: https://perkinscoie.com/insights/update/new-york-and-colorado-update-auto-renewing-subscription-requirements). Colorado's exclusive-enforcement-by-AG/DA model (§ 6-1-732(6)) has not been tested in published case law found in this research; whether it forecloses any private suits under the general CCPA private-action provision (§ 6-1-113) is not settled. Class-action risk under general CCPA § 6-1-113 remains a live question. The Wiley Law State Consumer Protection Series (Nov. 20, 2025) identifies Colorado among states with new 2025 ARL obligations and notes increasing joint state-federal enforcement risk across the subscription sector.
Caveats
1. The prompt's starting hint referenced 'SB 24-110' as the Colorado auto-renewal bill. No Colorado Senate Bill 24-110 related to automatic renewals was found in any primary or secondary source consulted. The original statute was enacted via SB 21-190 (2021, effective January 1, 2022); the most recent amendment is SB 25-145 (2025). The 'SB 24-110' reference appears to be incorrect. 2. SB 25-145 has a phased implementation: one-step online cancellation amendments took effect August 6, 2025; expansion of 'consumer' to 'a person' (covering B2B subscriptions) took effect February 16, 2026. As of June 2026 both amendments are fully operative. The consumer_facing: true flags in this dataset reflect the statute's original consumer-focused scope; scanners should note B2B subscriptions are now covered as of February 16, 2026. 3. The FindLaw and colorado.public.law versions of § 6-1-732 used here were current as of January 1, 2025; the SB 25-145 session law (Chapter 368) should be consulted for the complete amended text, particularly the new cancellation subsection language. The Colorado General Assembly PDF of the signed bill (https://leg.colorado.gov/sites/default/files/2025a_145_signed.pdf) returned HTTP 403 during this research. 4. The exemptions subsection § 6-1-732(5)(a) text was not fully retrieved. Confirmed exemptions under § 6-1-732(5)(b)-(f): services regulated by the FCC, FERC, or the Colorado Public Utilities Commission (§ 40-2-101); entities regulated by the Colorado Division of Insurance; banks and bank holding companies licensed under state or federal law (and their subsidiaries/affiliates); credit unions and other financial institutions licensed under state or federal law; air carriers regulated under the Federal Aviation Act of 1958 (49 U.S.C. § 40101 et seq.). 5. The statute does not separately define 'material change' in § 6-1-732(3) and does not specify a timing window for delivering a material change notice, leaving open questions about adequate advance notice for price increases. 6. The renewal notice timing exception for sub-12-month renewals (§ 6-1-732(4)(b)) was partially retrieved; the full exception text — particularly the threshold language — should be verified against the enrolled session law before relying on it for scanner logic.
Last reviewed 2026-06-26
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