Minnesota subscription auto-renewal law
Effective January 1, 2025; applies to contracts entered into, modified, or renewed on or after that date. Enacted by 2024 Minn. Laws ch. 114, art. 3, §§ 55–62. · Last reviewed 2026-06-26
The statute
Minn. Stat. §§ 325G.56–325G.63
Effective January 1, 2025; applies to contracts entered into, modified, or renewed on or after that date. Enacted by 2024 Minn. Laws ch. 114, art. 3, §§ 55–62.
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2024 Minn. Laws ch. 114, art. 3 (Session Law — primary enacting text)
Effective 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
Before a consumer accepts an offer for an indefinite subscription agreement, the seller must present the 'offer terms' in a clear and conspicuous manner in visual proximity to the offer's proposal (or in temporal proximity for voice offers). 'Offer terms' must include: (1) that the agreement continues until the consumer terminates it; (2) the cancellation policy; (3) the recurring charges to be billed, and that the amount may change if applicable; (4) the length of the automatic renewal term or that service is continuous; and (5) any minimum purchase obligation.
Minn. Stat. § 325G.57, Subd. 1 (definitions of 'offer terms' at § 325G.56, Subd. 7)Read the statute →
Acknowledgment / confirmation
In a timely manner after the consumer accepts an indefinite subscription agreement offer, the seller must provide a confirmation in a manner capable of being retained by the consumer. The confirmation must contain: (1) all offer terms; (2) if the offer includes a free trial, instructions on how to cancel before any obligation to pay arises; and (3) easy-to-use, cost-effective, and timely termination options — including, if the offer was made through an online website, a § 325G.60 termination election, and, if the consumer signed up by any means other than toll-free phone, email, or postal address, an option at least as easy to use as the initial sign-up method. Communication by email satisfies this requirement.
Minn. Stat. § 325G.57, Subd. 2Read the statute →
Affirmative consent
Any physical good sent to a consumer under an indefinite subscription agreement without first obtaining the consumer's affirmative consent to the agreement in accordance with § 325G.57 is an unconditional gift. The consumer may use or dispose of the good in any manner without any obligation to the seller, including any obligation relating to shipping. This provision establishes that affirmative consent — through the § 325G.57 offer-presentation and acceptance process — is a prerequisite to charging a consumer for goods.
Minn. Stat. § 325G.61Read the statute →
Cancellation mechanism
If a seller has a website with profile or subscription management capabilities, that website must include a 'termination election' — a simple and easily accessible means for a consumer to quickly provide notice of termination. The termination election must: be clear and conspicuous; use plain language stating any consumer may use it to terminate at any time; require only information necessary to process the termination; include a checkbox, submission button, or similarly simple mechanism; and not include undue complexity, confusion, or misrepresentation by the seller. This requirement applies regardless of the consumer's initial sign-up method.
Minn. Stat. § 325G.60, Subd. 2Read the statute →
A consumer may terminate an indefinite subscription agreement at any time by following the procedure set forth in the post-acceptance confirmation. For automatic renewal (definite term) agreements: termination is effective at the end of the term in which notice is provided, unless the consumer specifies a later term. For continuous service agreements: termination must take effect no later than 31 days after verified consumer notice, or on a future date if the consumer specifies one. If the seller failed to provide the required post-acceptance confirmation or the required annual continuous-service notice, the consumer may terminate by any reasonable means (mail, email, phone, online option, or initial sign-up method) at no cost to the consumer.
Minn. Stat. § 325G.59, Subds. 1–3Read the statute →
Once a seller receives a consumer's notice of cancellation or termination, the seller is prohibited from: (1) making any misrepresentation or using any unfair or abusive tactic to delay or avoid the cancellation; or (2) making or providing save offers (additional benefits, contract modifications, gifts, or similar inducements) until the seller has separately obtained the consumer's permission — where that permission must be granted after the cancellation notice, may only be solicited once per cancellation attempt, and is limited to that single attempt. A seller may still: ask the reasons for cancellation (provided an answer is not a condition of cancellation); inform the consumer of consequences of cancelling; verify identity; or describe options to maintain a relationship such as downgrading, pausing, or suspending the subscription.
Minn. Stat. § 325G.58, Subd. 4 (exceptions at Subd. 5)Read the statute →
Renewal reminder
For indefinite subscription agreements subject to continuous service — meaning agreements that continue until the consumer terminates, with no definite end term — the seller must provide the consumer with written notice at least once per calendar year, delivered by mail or email. The notice must include the terms of the service and how to terminate or manage the service. Note: this annual notice requirement applies specifically to continuous service agreements. The statute does not impose a comparable periodic pre-renewal reminder for definite-term automatic renewal agreements.
Minn. Stat. § 325G.57, Subd. 5Read the statute →
Free-trial conversion notice
Two distinct free trial obligations exist. First, for any indefinite subscription offer that includes a free trial (of any length), the post-acceptance confirmation must include information on how to cancel the free trial before the consumer pays or becomes obligated to pay (§ 325G.57, Subd. 2(2)). Second, for free trials lasting MORE THAN 30 days, the seller must send a separate advance notice no fewer than 5 days and no more than 30 days before the end of the free trial, informing the consumer of their option to cancel before the trial ends to avoid any obligation to pay for goods or services (§ 325G.57, Subd. 4). The 5-to-30-day notice applies only when the free trial exceeds 30 days.
Minn. Stat. § 325G.57, Subds. 2(2) and 4Read the statute →
Price-change notice
Upon any material change in the terms of an indefinite subscription agreement (including changes to pricing, charges, or material conditions), the seller must — prior to implementing the change — provide the consumer with a clear and conspicuous notice of the material change and information on how to terminate the agreement, in a form capable of being retained by the consumer. A material change implemented in violation of this requirement is void and unenforceable. The 'offer terms' definition also requires upfront disclosure that recurring charges may change and the amount to which they will change if known.
Minn. Stat. § 325G.57, Subd. 3 (offer terms definition at § 325G.56, Subd. 7(3))Read the statute →
Penalties and enforcement
Civil penalties up to $25,000 per violation, recoverable by the Minnesota Attorney General under Minn. Stat. § 8.31, Subd. 3(b) (cited at https://www.revisor.mn.gov/statutes/cite/8.31). Private right of action also available: injured consumers may sue for actual damages plus costs, investigation expenses, and reasonable attorney's fees under § 8.31, Subd. 3a. Injunctive relief is additionally available. Good faith safe harbor: under Minn. Stat. § 325G.63, a seller is not subject to civil penalties if the seller made a good faith effort to comply with each applicable provision of §§ 325G.56–325G.61 (https://www.revisor.mn.gov/statutes/cite/325G.63). Caution: § 8.31's express $25,000 civil penalty provision references laws listed in Subd. 1 of that section; §§ 325G.56–63 are not expressly enumerated there. The AG may also enforce via the Prevention of Consumer Fraud Act (§§ 325F.68–70), which is listed in § 8.31 Subd. 1 and provides the same penalty mechanism. The precise penalty pathway for §§ 325G.56–63 violations may require further clarification by the AG or courts.
No known Minnesota AG enforcement actions specifically under Minn. Stat. §§ 325G.56–325G.63 have been publicly reported as of June 2026; the law has been in effect only since January 1, 2025. No class actions specifically under the MN statute have been identified in public sources reviewed. General industry context (Faegre Drinker, January 2025: https://www.faegredrinker.com/en/insights/publications/2025/1/new-year-new-regulations-2025-brings-significant-developments-to-federal-and-state-automatic-renewal-laws) notes that auto-renewal enforcement nationally has produced seven- and eight-figure settlements, and that both the plaintiff class action bar and government regulators are active. The MN AG has broad investigative authority under § 8.31. The law's prohibition on 'save' offers without consumer permission after a cancellation request is identified by practitioners as a distinctive and potentially closely-watched enforcement risk under the MN statute.
Caveats
1. Effective date scope: The statute applies to contracts 'entered into, modified, or renewed' on or after January 1, 2025 (2024 Minn. Laws ch. 114, art. 3). Contracts entered before that date but renewed after it are covered. 2. 'Good faith effort' safe harbor (§ 325G.63): The statutory text provides no definition or factors for what constitutes a 'good faith effort.' Its scope has not yet been interpreted by courts or the MN AG. 3. Civil penalty mechanism: Section 325G.63 references 'civil penalties' without expressly specifying the authorizing statute or amount. The $25,000 figure comes from § 8.31 Subd. 3(b), but that provision's express list in Subd. 1 does not include §§ 325G.56–63. The AG may enforce through the Consumer Fraud Act pathway or under general authority; practitioners should monitor for AG guidance. 4. Annual renewal reminder for definite-term auto-renewals: Unlike some other states, MN's § 325G.57 Subd. 5 annual notice applies only to 'continuous service' (no definite end date), NOT to annual or other definite-term automatic renewal agreements. Scanners should not apply this requirement to monthly or annual subscriptions that renew at end of a definite term. 5. Free trial threshold: The advance pre-conversion notice under § 325G.57 Subd. 4 is triggered only when the free trial lasts MORE THAN 30 days; a 30-day free trial does not trigger it. 6. Broad exemptions: § 325G.62 exempts: contracts governed by another statute specifically targeting auto-renewal; certain licensed insurance entities; DLI-licensed technology system contractors; PUC/FCC/FERC-regulated services; and FINRA/SEC/MN Securities Act registrants. 7. No case law or AG guidance as of June 2026: The law is new and untested; all interpretive positions above derive from the statutory text, legislative history (the enrolled bill), and secondary law-firm commentary.
Last reviewed 2026-06-26
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