What Is California’s Automatic Renewal Law 17600?

California’s Automatic Renewal Law, found at Business and Professions Code sections 17600 through 17606, requires any business that bills a California consumer on a recurring basis to disclose the renewal terms up front, get the consumer’s affirmative consent, send a saved acknowledgment, offer an easy way to cancel, remind the consumer annually, and give advance notice before raising the price. The rules apply whether the company is based in California or anywhere else, and they cover streaming services, subscription boxes, software, and any other paid plan that keeps billing until the customer stops it. Getting the details wrong is expensive: shipped goods can become free gifts the consumer owes nothing for, and civil penalties reach $2,500 per violation.

Who Has to Follow the Law

The statute applies to any business making an “automatic renewal offer” or “continuous service offer” to a consumer in California. An automatic renewal is a paid plan that renews for another term at the end of the current one. A continuous service runs until the consumer cancels. Both trigger the same obligations.¹

“Consumer” means an individual buying for personal, family, or household purposes. Business-to-business subscriptions sit outside the statute, so a company selling software licenses only to other companies is not covered.¹

Several industries are fully exempt because they already answer to their own regulators: utilities and telecom services under the CPUC, FCC, or FERC; insurers regulated by the California Department of Insurance; banks, credit unions, and their affiliates; alarm company operators under Chapter 11.6 of Division 3 of the Business and Professions Code; and service contract sellers and administrators regulated by the Bureau of Electronic and Appliance Repair.²

What Must Be Disclosed Before You Pay

Before a consumer completes a purchase, the business has to present the renewal terms in a “clear and conspicuous” way. The statute defines that as text in a larger size than the surrounding copy, in a contrasting typeface or color, or set off by symbols that draw attention to it. For voice transactions, the disclosure has to be loud and clear enough to be easily understood.¹

The disclosures have to appear in visual proximity to the consent request and must cover:

That the subscription will continue until the consumer cancels
A description of the cancellation policy
The recurring charge amount, whether the amount may change, and the new amount if known
The length of the renewal term, or that the service is continuous
Any minimum purchase obligation

Burying these terms deep in a terms-of-service document does not satisfy the standard.³

Affirmative Consent to the Renewal

A business cannot charge a credit card, debit card, or third-party payment account without first getting the consumer’s affirmative consent to the specific renewal or continuous service terms. That rule applies to full-price offers, discounted introductory periods, and free trials alike.³

The consent has to be genuine and unambiguous. A contract cannot contain language that interferes with, contradicts, or undermines informed consent. Pre-checked boxes or consent folded into a general terms-of-service acceptance will not hold up. The business must also keep verification of that consent for at least three years, or one year after the contract ends, whichever is longer.³

The Acknowledgment You Should Receive After Signing Up

Once the consumer agrees, the business must send an acknowledgment the consumer can retain, such as an email or downloadable document. It has to include the renewal terms, the cancellation policy, and instructions for how to cancel. This is a separate, post-purchase confirmation, not a substitute for the pre-purchase disclosure.³

Free Trials and Introductory Pricing

Trials and discounted intro offers face extra scrutiny. If an offer includes a free gift or trial period, the business has to clearly disclose the price that will kick in after the trial, or explain how the pricing will change once the introductory period ends. Vague language like “regular price applies” is not enough.³

The acknowledgment for a free-trial offer also has to tell the consumer how to cancel and let them cancel before any charge hits. Sending a trial confirmation email that omits the cancellation instructions, or forcing the consumer to hunt through an account dashboard, is a common failure point.³

How Cancellation Has to Work

Every covered business must give consumers a cost-effective, timely, and easy-to-use way to cancel. At minimum, the business has to offer one of the following: a toll-free phone number, an email address, a postal address (if the business bills the consumer directly), or another mechanism that meets the standard. Whichever method is chosen has to be described in the post-sign-up acknowledgment.³

Online Sign-Up Means Online Cancellation

If you signed up online, the business has to let you cancel online, immediately, without extra steps designed to delay or obstruct. The online cancel path must take one of two forms: a prominently placed direct link or button inside the consumer’s account, profile, or device settings, or a pre-formatted cancellation email the consumer can send without adding any extra information. A business may require you to log in before canceling, but a consumer who is unwilling or unable to authenticate online still has to be able to cancel through an offline method.⁴

Retention Offers Cannot Hide the Cancel Button

A business can present a discount, an upgrade, or information about the downsides of leaving when the consumer starts to cancel. But any retention pitch has to appear alongside a clear and obvious cancel button or link. The cancel option cannot be hidden behind or underneath retention offers.⁵

Annual Reminders

Businesses have to send an annual reminder to every consumer on an automatic renewal or continuous service. The reminder goes out through the same channel the consumer used to sign up, or the channel the consumer normally uses to interact with the business. For subscriptions started in person or over the phone, the reminder can go by phone, mail, or any internet-based communication.⁵

Each annual reminder has to include the product or service covered, how often the consumer is charged and the amount, and how to cancel. Skipping the reminder is its own violation, separate from any issue with the original disclosure or consent.⁵

Notice Before a Price Increase

When a business changes fees or makes a material change to the terms of an existing subscription, it has to send the consumer a clear and conspicuous notice along with cancellation instructions. For fee changes, the notice must arrive no fewer than 7 days and no more than 30 days before the new price takes effect. That applies even when the original plan disclosed that prices might change. A general “prices may change” line at sign-up does not substitute for specific advance notice when the change actually happens.⁵

What Happens When a Business Breaks the Rules

Shipped Goods Become Free Gifts

If a business ships products under a renewal or continuous service agreement without properly obtaining affirmative consent, those products are legally treated as unconditional gifts. The consumer can keep them, give them away, or throw them out, with no obligation to the business. There is no duty to return anything and no obligation to pay shipping.⁶ For a subscription box company, every package sent without proper consent is inventory the business gave away with no legal way to recover the cost.

Civil Penalties

A violation of the ARL is not a crime, but all civil remedies are available.¹ Because violations count as unfair business practices, they carry civil penalties of up to $2,500 per violation, and consumers can also bring their own civil actions seeking restitution of unauthorized charges.⁷ The exposure adds up quickly. A company with 10,000 subscribers that failed to include proper cancellation instructions in its acknowledgment emails has potentially committed 10,000 separate violations.

The Good Faith Defense

A business that complies with the law in good faith is not subject to civil remedies.¹ That is not a blanket excuse. A business claiming good faith needs to show it had real compliance procedures in place and that any failure was not the result of indifference or cost-cutting. The consent verification records the law already requires (kept at least three years) double as evidence that the business was actually collecting and preserving consent.³

How This Interacts With Federal Law

California businesses that sell subscriptions online also have to comply with the federal Restore Online Shoppers’ Confidence Act. ROSCA covers any internet transaction with a negative option feature and requires disclosure of material terms before billing information is collected, express informed consent before any charge, and a simple mechanism for stopping recurring charges.⁸ California’s law is more detailed and more demanding, so a business that fully complies with the ARL will generally satisfy ROSCA as well. The FTC enforces ROSCA under its authority to police unfair or deceptive trade practices; a separate proposed federal “click-to-cancel” rule was vacated by the Eighth Circuit in 2025 and remains under review as of early 2026.⁹

1
California Legislative Information. California Business and Professions Code – Article 9 Automatic Purchase Renewals
2
California Legislative Information. California Code Business and Professions Code 17605
3
California Legislative Information. California Code Business and Professions Code 17602
4
California Legislative Information. Bill Text – AB 390 Advertising Automatic Renewal and Continuous Service Offers
5
California Legislative Information. California Business and Professions Code 17602
6
California Legislative Information. California Code Business and Professions Code 17603
7
California Legislative Information. California Business and Professions Code 17206
8
Office of the Law Revision Counsel. 15 USC 8403 – Negative Option Marketing on the Internet
9
Federal Trade Commission. Do You Have Thoughts on Negative Option-Related Regulations? Share Them With the FTC