Amendments to California’s Automatic Renewal Law (ARL) will take effect on July 1, 2025. Enacted in September 2024 through Assembly Bill No. 2863, the amendments expand disclosure, consent, and cancellation obligations for businesses offering subscription or continuous service plans to California consumers.

The amendments impose several new requirements related to consumer consent, cancellation, and disclosures, including:

Putting It Into Practice: The amended ARL closely tracks the FTC’s Negative Option Rule, particularly in its expanded requirements for disclosure, consent, and cancellation—setting a new compliance benchmark for businesses operating in California. While the CFPB has pulled back in this area, the FTC and state lawmakers continue to advance rulemaking related to unfair or deceptive subscription practices (previously discussed here).

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