Utah subscription auto-renewal law
Effective January 1, 2025 · Last reviewed 2026-06-26
The statute
Utah Code §§ 13-70-101, 13-70-201, 13-70-301 (Automatic Renewal Contracts Act, HB 174, Chapter 132, 2024 General Session)
Effective January 1, 2025
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Utah Code §§ 13-70-101, 13-70-301 amended by Chapter 95, 2026 General Session (definitions expanded; enforcement remedies and order-violation penalty added)
Effective May 6, 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.
Renewal reminder
A person who provides an individual a product or service under a contract with an automatic renewal provision (i.e., a provision that renews at the end of a definite paid term for a subsequent paid term longer than 45 days) must provide a notice to the individual at least 30 but not more than 60 days before the day on which the automatic renewal provision renews. The notice must clearly and conspicuously disclose: (a) the date on which the automatic renewal provision renews [subsection (a) not fully extracted in text rendering but confirmed by multiple secondary sources]; (b) the total renewal cost; and (c) options for cancellation of the contract. 'Clearly and conspicuously disclose' is defined in § 13-70-101(2) as disclosure in larger font, contrasting type/font/color, or marks that clearly call attention to the language, or through audio in volume and cadence readily audible and understandable. A contract provision that violates this requirement is void (§ 13-70-201(4)). This requirement does not apply to entities listed in § 13-70-201(3): entities regulated under Title 31A Insurance Code or affiliates; persons providing a service contract under § 31A-6a-101; financial institutions regulated under Title V of Gramm-Leach-Bliley Act (15 U.S.C. § 6801 et seq.) or their affiliates; public utilities as defined in § 54-2-1; entities providing services regulated by the FCC, FERC, or Federal Professional Services Council or their affiliates; parties to a rental agreement; or parties to a property management agreement under § 61-2f-102.
Utah Code § 13-70-201(1); § 13-70-101(1)-(2)Read the statute →
Free-trial conversion notice
A person who provides an individual a 'trial period offer' (defined in § 13-70-101(5) as an offer to provide a period of time to sample or use a product or service without payment — meaning genuinely free, not discounted or introductory pricing) must provide a notice to the individual at least three days before the day on which the trial period offer expires. The notice must clearly and conspicuously disclose: (a) the trial period offer expiration date; (b) the price to be charged for the product or service, or any further purchase obligations to be imposed on the individual, after the expiration date; and (c) options for cancellation of the contract. The same exemptions listed in § 13-70-201(3) apply to this requirement.
Utah Code § 13-70-201(2); § 13-70-101(5)Read the statute →
Penalties and enforcement
Administrative fine of up to $2,500 per violation imposed by the Division of Consumer Protection director (§ 13-70-301(2)(a)). In a civil action brought by the Division, the court may impose a civil penalty of up to $2,500 per violation (§ 13-70-301(3)(e)), plus potential disgorgement, injunction, declaratory relief, attorney fees, and investigative fees (§ 13-70-301(3)-(4)). A person who violates an administrative or court order issued under the chapter is subject to a separate civil penalty of up to $5,000 per violation (§ 13-70-301(5)(a), added by Chapter 95, 2026 General Session, effective May 6, 2026). No private right of action appears in the statute — enforcement authority belongs to the Division. An automatic renewal provision that violates § 13-70-201 is void (§ 13-70-201(4)). Source: https://le.utah.gov/xcode/Title13/Chapter70/C13-70-S301_2026050620260506.html
No publicly documented Utah Division of Consumer Protection enforcement actions under Chapter 70 have been identified as of June 2026; the law took effect January 1, 2025 and is in its first full enforcement year. No private right of action is provided in the statute, which limits class-action exposure compared to states like California. Multiple law firm surveys (Faegre Drinker, Cobalt, Wiley) note that Utah's ARCA is intentionally narrower than peer state laws — it lacks upfront pre-purchase disclosure, affirmative consent, acknowledgment/confirmation, and click-to-cancel mechanism requirements, making it one of the less burdensome state ARLs. The Wiley State Consumer Protection Series (November 2025) confirms Utah's three-day free-trial notice rule as currently operative and notes it as meaningfully shorter than Maryland's 14-day equivalent. No class-action filings tied to UT ARCA have been reported.
Caveats
1. SUBSECTION 13-70-201(1)(a): Text extraction from the le.utah.gov HTML page did not render subsection (a) of § 13-70-201(1). Multiple independent secondary sources (Faegre Drinker, Cobalt, Thompson Hine) consistently state the notice must disclose the renewal date as the first element. Readers should verify the exact text of § 13-70-201(1)(a) directly at https://le.utah.gov/xcode/Title13/Chapter70/C13-70-S201_2025010120240501.html before relying on this entry. 2. 2026 AMENDMENT: §§ 13-70-101 and 13-70-301 were amended by Chapter 95, 2026 General Session (effective May 6, 2026). The 2026 amendment to § 13-70-101 codified a detailed definition of 'clearly and conspicuously disclose.' The 2026 amendment to § 13-70-301 expanded civil action remedies and added the $5,000 per-violation penalty for order violations. Section 13-70-201 (the operative disclosure/notice requirements) has NOT been amended and remains as enacted in 2024. 3. NARROW SCOPE: The ARCA expressly applies only to contracts with paid renewal terms longer than 45 days — month-to-month subscriptions appear to fall outside its scope. Contracts covered by the listed exemptions (insurance, financial institutions, utilities, service contracts, rental/property management) are wholly excluded. 4. NO UPFRONT DISCLOSURE OR CONSENT RULES: Unlike California, Minnesota, and several other states, Utah ARCA imposes no pre-purchase disclosure obligation, no affirmative consent requirement, no acknowledgment/confirmation requirement, and no specific cancellation mechanism (click-to-cancel) mandate. Businesses subject to this law and also operating in higher-requirement states will still need to meet those states' standards. 5. ENFORCEMENT NOVELTY: As of June 2026, the law has been in effect for approximately 18 months. No published rulemaking under § 13-70-301(6) has been identified, meaning the Division has not yet issued clarifying regulations. Interpretive uncertainty exists on edge cases (e.g., what constitutes a sufficient 'option for cancellation' disclosure).
Last reviewed 2026-06-26
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