Connecticut subscription auto-renewal law
Effective October 1, 2023 · Last reviewed 2026-06-26
The statute
Conn. Gen. Stat. § 42-158ff (Chapter 742d — Automatic Renewal and Continuous Services), enacted by P.A. 23-191, S. 1; P.A. 23-205, S. 156
Effective October 1, 2023
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Conn. Gen. Stat. § 42-158ff as amended by P.A. 25-113, S. 20 (adds statutory definition of 'clearly and conspicuously disclose' and affirmative consent record-of-consent evidentiary guidance)
Effective October 1, 2025
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Conn. Gen. Stat. § 42-158ff as amended by P.A. 25-44, S. 7 (adds annual reminder, expands cancellation to include telephone option with voicemail rules, removes 'no private right of action' clause, adds per se CUTPA unfair trade practice designation)
Effective July 1, 2026
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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
Conn. Gen. Stat. § 42-158ff(b)(1)(B) requires that, before an automatic renewal, a business must clearly and conspicuously disclose to the consumer: (i) that the agreement will automatically renew until the consumer acts to prevent it; (ii) the actions required to prevent renewal (and, if disclosed electronically, a link or other electronic means to take those actions); (iii) all recurring charges to the consumer's credit card, debit card, or third-party payment account, and the amount of any known changes; (iv) the length of any automatic renewal term (unless the consumer selects the term); (v) any additional provisions concerning the renewal term; (vi) any minimum purchase obligation; and (vii) contact information for the business. Section 42-158ff(b)(1)(C) imposes the same seven-item disclosure requirement for continuous services provisions, required before the consumer enters the agreement. Section 42-158ff(b)(2) specifies that electronic and written disclosures must be retained by the consumer and appear in text that is either larger than surrounding text or in a contrasting typeface, font, or color (or set off by symbols); verbal and telephonic disclosures must be in a volume and cadence readily audible and understandable to the consumer.
Conn. Gen. Stat. § 42-158ff(b)(1)(B)-(C), (b)(2)Read the statute →
Affirmative consent
Conn. Gen. Stat. § 42-158ff(c) prohibits a business from charging a consumer's credit card, debit card, or third-party payment account for any automatic renewal or continuous consumer services — regardless of whether offered at a promotional or discounted price — unless the business has first obtained the consumer's affirmative consent to such renewal or continuous services. As amended by P.A. 25-113 (effective October 1, 2025), when a state agency or court considers whether affirmative consent was obtained, it must consider, among other factors, whether the business produced a record of such affirmative consent obtained in accordance with applicable law, including Conn. Gen. Stat. §§ 52-570d and 53a-189 (concerning recording of telephonic communications). The statute does not expressly mandate a specific consent-record format but creates an evidentiary expectation in enforcement proceedings.
Conn. Gen. Stat. § 42-158ff(c)Read the statute →
Acknowledgment / confirmation
Conn. Gen. Stat. § 42-158ff(c) (as amended by P.A. 25-113, effective October 1, 2025) directs that state agencies and courts assessing affirmative consent compliance 'shall consider, without limitation, whether the business has produced a record of such affirmative consent that was obtained in accordance with applicable law, including, but not limited to, sections 52-570d and 53a-189, concerning recording telephonic communications.' The statute does not expressly impose a standalone recordkeeping mandate but establishes that consent documentation is a factor in enforcement proceedings. This creates a functional compliance expectation that businesses retain evidence of how and when consumer consent was captured.
Conn. Gen. Stat. § 42-158ff(c) (as amended by P.A. 25-113, S. 20)Read the statute →
Cancellation mechanism
Conn. Gen. Stat. § 42-158ff(b)(1)(A) requires that a business entering or offering to enter a consumer agreement with an automatic renewal or continuous services provision must establish and maintain an electronic mail address, postal address, or the telephone number or online means required under the statute's cancellation subsection, which the consumer may use to prevent automatic renewal or terminate continuous consumer services. Under the pre-July 1, 2026 version, this includes a toll-free telephone number. Under the July 1, 2026 amendments (P.A. 25-44), 'toll-free' is removed. Section 42-158ff(e)(2) (effective July 1, 2026) specifies that each business must enable cancellation by at least one of: (A) a prominently displayed direct link or button in the consumer's account, profile, device, or user settings; (B) a reply-able email message from the business; or (C) beginning July 1, 2026, a telephone number clearly and conspicuously displayed on the business's website. The statute (§ 42-158ff(e)(3)) requires the business to promptly answer all calls during normal business hours, and if a consumer leaves a voicemail requesting cancellation, the business must either process the cancellation or return the call within one business day. If the voicemail contains sufficient information to effectuate cancellation and the business cannot reach the consumer, it must process the cancellation within one business day. No business subject to these provisions may obstruct or delay a consumer's efforts to cancel (§ 42-158ff(e)(4)).
Conn. Gen. Stat. § 42-158ff(b)(1)(A); § 42-158ff(d) [pre-July 1, 2026] / § 42-158ff(e)(2)-(4) [from July 1, 2026 per P.A. 25-44]Read the statute →
Conn. Gen. Stat. § 42-158ff(d)(1) [pre-July 1, 2026] / § 42-158ff(e)(1) [from July 1, 2026 per P.A. 25-44] requires that each business entering into a consumer agreement online must allow the consumer to take any action necessary to prevent automatic renewal or terminate continuous consumer services online, without requiring any offline action. The business must enable this online cancellation via at least one of the methods specified in the statute (prominently displayed direct link or button; reply-able email). A business may require account authentication online before processing cancellation, but consumers unwilling or unable to authenticate online must not be precluded from authenticating or canceling by another available method. The business may not obstruct or delay the consumer's efforts to cancel online.
Conn. Gen. Stat. § 42-158ff(d)(1)-(2) [pre-July 1, 2026] / § 42-158ff(e)(1), (5) [from July 1, 2026 per P.A. 25-44]Read the statute →
Renewal reminder
Conn. Gen. Stat. § 42-158ff(d) (added by P.A. 25-44, effective July 1, 2026) requires that beginning on July 1, 2026, each business entering into a consumer agreement with an automatic renewal or continuous services provision must send the consumer an annual reminder about that provision. The reminder must be sent: (A) in the same manner in which the provision was activated, if activation occurred by any means other than an in-person transaction; (B) by the means in which the consumer is accustomed to interacting with the business (electronic mail, mail, or telephone), if applicable; or (C) by electronic mail, mail, or telephone, if the provision was activated in-person or the consumer has no established interaction channel. The annual reminder must include: (A) a statement identifying (i) the goods or services subject to the provision and (ii) the means by which the consumer may prevent renewal or terminate continuous services; and (B) the frequency and amount of charges associated with the renewal or continuous services. This requirement applies regardless of subscription term length.
Conn. Gen. Stat. § 42-158ff(d) (added by P.A. 25-44, S. 7, effective July 1, 2026)Read the statute →
Free-trial conversion notice
Conn. Gen. Stat. § 42-158ff(b)(1)(E) requires that, before a consumer enters into a consumer agreement that includes a free gift or trial period, the business must clearly and conspicuously disclose: (i) the price that the consumer will be charged following expiration of the free gift or trial period; and (ii) any manner in which pricing for the agreement will change following expiration. This disclosure must meet the format requirements of § 42-158ff(b)(2) (retainable, contrasting text for written/electronic; readily audible for verbal/telephonic). 'Free gift' in this context does not include a free promotional item or gift that differs from the consumer goods or services that are the subject of the consumer agreement.
Conn. Gen. Stat. § 42-158ff(b)(1)(E)Read the statute →
Conn. Gen. Stat. § 42-158ff(b)(1)(F) requires that, for consumer agreements offered electronically or telephonically that include a free gift or trial period, or a discounted or promotional price period, the business must send a timed notice to the consumer disclosing: (I) that the agreement will automatically renew or continuous services will continue until the consumer acts to prevent it; (II) the duration of the renewal term or continuous services; (III) any additional provisions; (IV) the actions required to prevent renewal or termination; and (V) if offered electronically, a prominently displayed direct link or button or a reply-able email as required by the cancellation subsection. Timing requirements: (1) if the free gift/trial/discounted period is at least 32 days in duration, the notice must be sent at least 21 days after such period commences and not earlier than 3 days before expiration; (2) if the period is at least one year in duration, the notice must be sent at least 15 days but not more than 45 days before expiration. Exception: a business is not required to send this timed notice if it has not collected, or does not maintain, the consumer's electronic mail address or telephone number, as applicable, and is unable to reach the consumer by other electronic means.
Conn. Gen. Stat. § 42-158ff(b)(1)(F)(i)-(iii)Read the statute →
Price-change notice
Conn. Gen. Stat. § 42-158ff(b)(1)(D) requires that before a business makes any material change to the terms of an automatic renewal provision or continuous services provision, it must clearly and conspicuously disclose to the consumer: (i) the material change; and (ii) a description of the actions the consumer is required to take to cancel the automatic renewal or terminate the continuous consumer services. This disclosure must meet the format requirements of § 42-158ff(b)(2). The statute uses 'material change' without further statutory definition; the provision applies to changes beyond price (it covers terms generally), but price increases and term changes would qualify.
Conn. Gen. Stat. § 42-158ff(b)(1)(D)Read the statute →
Penalties and enforcement
Prior to July 1, 2026: Conn. Gen. Stat. § 42-158ff expressly excluded a private right of action ('Nothing in this section shall be construed to create a private right of action,' former § 42-158ff(e)). Enforcement was limited to the Connecticut Department of Consumer Protection (DCP) and Attorney General under CUTPA (Conn. Gen. Stat. Chapter 735a). DCP Commissioner remedies include cease-and-desist orders (§ 42-110d) and restitution orders in cases involving less than $10,000 (as amended by P.A. 15-60). From July 1, 2026 (per P.A. 25-44, S.7): § 42-158ff(f) provides that 'any violation of the provisions of this section shall constitute an unfair trade practice under subsection (a) of section 42-110b,' making violations per se CUTPA violations. Full CUTPA enforcement then applies: (1) Private plaintiffs may sue for actual damages, punitive damages, costs, and reasonable attorneys' fees under Conn. Gen. Stat. § 42-110g; ascertainable loss of money or property is required to maintain a private action. (2) Class actions are available under Conn. Gen. Stat. § 42-110h. (3) Courts may impose civil penalties up to $5,000 per willful violation and up to $25,000 for violation of a court restraining order under Conn. Gen. Stat. § 42-110o. Source for CUTPA penalty amounts: CGA Research Report 2005-R-0261 (https://www.cga.ct.gov/2005/rpt/2005-R-0261.htm); restitution threshold updated by P.A. 15-60 per CGA annotated history.
No Connecticut DCP or AG enforcement actions specifically targeting § 42-158ff violations have been identified as of June 2026. The statute's express exclusion of a private right of action (in effect until July 1, 2026) significantly limited enforcement exposure prior to that date. CT AG William Tong publicly supported FTC negative option rule amendments in June 2023, co-signing a 26-state coalition letter citing consumer complaints about unwanted subscription renewals (portal.ct.gov press release, June 26, 2023). Wiggin and Dana (July 2025 client alert, https://www.wiggin.com/publication/caveat-venditor1-the-connecticut-general-assembly-has-added-seven-new-per-se-cutpa-violations/) identified § 42-158ff violations as one of seven new per se CUTPA violations effective July 1, 2026, noting the significant increase in private litigation exposure. The CT AG has demonstrated active CUTPA consumer-protection enforcement capacity: first CTDPA enforcement settlement with TicketNetwork ($85,000, 2025). The opening of the private right of action on July 1, 2026 creates material class action risk under Conn. Gen. Stat. § 42-110h; no class action filings under § 42-158ff have been identified as of the research date.
Caveats
(1) P.A. 25-44 (the private-right-of-action and annual-reminder amendment) takes effect July 1, 2026 — five days after this research date. No enforcement actions, class action filings, or agency guidance interpreting the amended statute yet exist. (2) The effective date of P.A. 25-113 (October 1, 2025) was confirmed by InsidePrivacy (a Covington law-firm publication) but could not be independently verified against a primary CGA public-act PDF due to SSL certificate errors on the cga.ct.gov domain during this research session; the codified statute text at cga.ct.gov/2026/sup/chap_742d.htm confirms P.A. 25-113's textual changes. (3) The audiovisual content exemption — 'global or national service largely or predominantly consisting of audiovisual content' (§ 42-158ff(a)(4)(E)) — has no statutory definition or regulatory guidance; its scope is uncertain (e.g., whether hybrid streaming/software services qualify is unresolved). (4) Civil penalty amounts cited ($5,000 per willful violation; $25,000 for restraining order violation) originate from a 2005 CGA research report and the CGA annotated CUTPA chapter; while the $10,000 restitution update from P.A. 15-60 was confirmed in the annotated history, independent verification of the current civil penalty cap against the most recent CUTPA text (§ 42-110o) was not possible because Justia and LawServer require JavaScript rendering. (5) The 2026 Connecticut legislative session (per Mondaq, June 2026) reportedly reserved several new per se CUTPA violations for AG-only enforcement — it is uncertain whether any 2026 act further modifies the private right of action under § 42-158ff; verification against 2026 session acts is recommended before relying on this dataset for litigation purposes. (6) The statute applies only to 'consumer agreements' initially entered into or amended on or after October 1, 2023; pre-existing agreements not amended after that date are not covered.
Last reviewed 2026-06-26
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