Rule pack 2026.10.20-1

Rules we track

Plain-English summaries, each linked to its official source. Rules ship as versioned packs so they can be reviewed and updated without changing your setup.

Published Oct 20, 2026 · Review status: Unreviewed draft. Plain-English summaries prepared from official sources; pending review by qualified counsel in each jurisdiction.

United States — federal baseline

In force since Dec 29, 2010

Restore Online Shoppers' Confidence Act (ROSCA), 15 U.S.C. §§ 8401–8405, enforced by the FTC

Before taking billing details online, clearly show the key terms of the subscription, get the customer's express informed consent, and give them a simple way to stop recurring charges. The FTC's 2024 'click-to-cancel' rule was vacated in July 2025, but ROSCA itself is still enforced.

What it asks for

Show the key terms before billing
Before you collect card details, clearly show the price, how often it charges, that it renews until cancelled, and how to cancel.
15 U.S.C. § 8403(1)
Get express informed consent
Get a clear 'yes' to the recurring charge before charging — and keep a record of it.
15 U.S.C. § 8403(2)
Offer a simple way to stop charges
Give customers a simple way to stop the recurring charges.
15 U.S.C. § 8403(3)

Reminders we schedule

Trial-ending courtesy reminder (best practice) optional
7–3 days before
Optional. Turn off in Settings if you prefer.
Best practice — not a federal statutory requirement

Official sources

Note: Card networks have their own trial and subscription rules; they are not covered by this pack.

California — Automatic Renewal Law

In force since Jul 1, 2025

Cal. Bus. & Prof. Code §§ 17600–17606, as amended by AB 2863 (effective 1 Jul 2025)

Get express affirmative consent to the renewal terms, let people who signed up online cancel online immediately, send notices before long trials and yearly renewals end, send an annual reminder, and give notice before price changes.

What it asks for

Clear and conspicuous terms before billing
Show that it renews until cancelled, the renewal length, the price and frequency, and how to cancel — before confirming billing details.
Bus. & Prof. Code § 17602(a)(1)
Express affirmative consent
Get a separate, clear 'yes' to the automatic renewal terms and keep the record.
Bus. & Prof. Code § 17602(a)(2)
Acknowledgment the customer can keep
Send an acknowledgment with the terms and how to cancel after sign-up.
Bus. & Prof. Code § 17602(a)(3)
Online cancel, immediately
If they signed up online, they must be able to cancel online, at will, without steps that obstruct or delay it. A save offer may be shown, but alongside a clear cancel option.
Bus. & Prof. Code § 17602(d)

Reminders we schedule

Notice before a long free trial or promo price ends
21–3 days before
Applies when the free trial or promotional price lasts more than 31 days.
Bus. & Prof. Code § 17602(b)(1)(A)
Notice before a yearly (or longer) term renews
45–15 days before
Bus. & Prof. Code § 17602(b)(2)
Annual reminder
30–3 days before
The statute requires a reminder at least annually but sets no exact timing; we send it before the renewal closest to each sign-up anniversary. Conservative reading — confirm with counsel.
Bus. & Prof. Code § 17602(h) (added by AB 2863)
Notice before a fee change manual for now
30–7 days before
Not automated in this version — schedule price-change notices manually.
Bus. & Prof. Code § 17602(g)(2)

Official sources

New York State — automatic renewal law

In force since Nov 5, 2025

N.Y. General Business Law §§ 527, 527-a (as amended, effective 5 Nov 2025)

Show the material terms next to the consent request, get affirmative consent, let customers cancel through the same medium they used to sign up, send a reminder before yearly-or-longer terms renew, and give notice of material and price changes.

What it asks for

Material terms in visual proximity to consent
Show what renews, the cost, how often, the deadline to cancel and how to cancel — right next to the consent button, before asking for billing details.
GBL § 527-a(1)(a)
Affirmative consent before the first charge
Get a clear 'yes' before charging for the initial term, and keep the record.
GBL § 527-a(1)(b)
Cancel as easily, and through the same medium
Offer a cancel option that is as easy as signing up, through the same medium they used.
GBL § 527-a(1)(d), (d-1)

Reminders we schedule

Reminder before a yearly-or-longer term renews
45–15 days before
Measured from the cancellation deadline; we treat the renewal date as the deadline unless you set a notice period.
GBL § 527-a (2025 amendment)
Notice of a material or price change manual for now
30–5 days before
Not automated in this version.
GBL § 527-a (2025 amendment)

Official sources

Note: Price increases need either fresh consent or a 14-day cancel-with-prorated-refund option (GBL § 527-a(1)(b-1)).

New York City — Click to Cancel rule

In force since Oct 1, 2026

NYC Department of Consumer and Worker Protection rule on cancellation of subscriptions (6 RCNY), in force 1 Oct 2026

Explain subscription terms clearly, tell people about auto-renewal and changes, and give a straightforward cancellation through the same method they used to sign up — without delay.

Civil penalties start at $525 and businesses may have to refund consumers (DCWP).

What it asks for

Clear subscription terms and rights
Clearly explain the subscription terms and the customer's rights when buying or cancelling.
NYC DCWP Click-to-Cancel rule
Cancel the same way they signed up
If they signed up online, they must be able to cancel online — not only by phone or in person — and you can't delay it.
NYC DCWP Click-to-Cancel rule
Tell them about auto-renewal and changes
Inform customers about auto-renewal and about changes to their subscription terms.
NYC DCWP Click-to-Cancel rule

Reminders we schedule

No timed reminder in this rule set.

Official sources

Note: NYC customers also get New York State rules. Reminder timing in this pack follows NY State GBL § 527-a; the NYC rule text needs counsel review for any additional timing.

European Union — online withdrawal function

In force since Jun 19, 2026

Directive (EU) 2023/2673, inserting Article 11a into the Consumer Rights Directive 2011/83/EU (applies from 19 Jun 2026)

For contracts concluded online, consumers must find a clearly labelled 'withdraw from contract here' function during the 14-day withdrawal period, confirm it in a second step, and get an acknowledgment with the date and time on a durable medium such as email.

What it asks for

A 'withdraw from contract here' function
Show a clearly labelled withdrawal function, prominently and continuously available during the withdrawal period.
Directive 2011/83/EU Art. 11a(1)–(2)
A 'confirm withdrawal' step
After they start withdrawing, let them confirm with a clearly labelled 'confirm withdrawal' button.
Directive 2011/83/EU Art. 11a(3)
Acknowledgment on a durable medium
Send an acknowledgment of receipt, including the date and time, without undue delay (email works).
Directive 2011/83/EU Art. 11a(4)

Reminders we schedule

No timed reminder in this rule set.

Official sources

Note: EEA countries (Iceland, Liechtenstein, Norway) are matched here too; confirm local transposition.
Note: Withdrawal usually means a refund is due; refunds are flagged for you to handle in this version.
Note: Some member states (for example Germany) also require an ongoing cancellation button; not yet modelled.

United Kingdom — DMCC Act subscription contracts

Starts Jan 1, 2027

Digital Markets, Competition and Consumers Act 2024, Part 4 Chapter 2 (for contracts entered into from 1 Jan 2027)

Give key information up front, send reminder notices by email or another durable medium (roughly every 6 months on rolling plans, before a trial or discount ends, and twice before 12-month-plus renewals), offer cooling-off periods, and make it easy to end the contract.

What it asks for

Key pre-contract information
Before sign-up, give the key terms — including when you'll send reminder notices (the windows you choose).
DMCC Act 2024 s.254, Sch. 23
Reminders on a durable medium
Send reminders by email, SMS or post — not app pop-ups — and make the renewal information the most prominent thing in the message.
DMCC Act 2024 s.259(2)
Cooling-off periods
Offer a 14-day cooling-off period at the start and a renewal cooling-off period in certain cases.
DMCC Act 2024 Part 4 Ch. 2
Easy exit
Let consumers end the contract in a straightforward way, including online if they signed up online.
DMCC Act 2024 Part 4 Ch. 2

Reminders we schedule

Six-monthly reminder notice
Within the window you choose (default 14–3 days before)
Sent within the window you state in your key pre-contract information (default 14 to 3 days before the payment).
DMCC Act 2024 s.258(1)–(2), s.259(3)–(5)
Reminder before a free trial or discount ends
Within the window you choose (default 14–3 days before)
DMCC Act 2024 s.258(3)(a)
Additional earlier reminder before a 12-month-plus renewal
Within the window you choose (default 14–3 days before)
DMCC Act 2024 s.259(6)–(8)

Official sources

Note: The government's consultation response anticipated spring 2027; the later GOV.UK announcement says January 2027. We use 1 Jan 2027 and will update if commencement regulations differ.
Note: Reminder windows are yours to choose but must be reasonable and match your key pre-contract information.

On our watchlist

EU Digital Fairness Act proposal (subscriptions, auto-renewal, free-trial conversion) — Proposal expected Q4 2026
FTC negative option rulemaking restarted (ANPRM) — Rulemaking in progress
UK DMCC subscription regulations and final guidance — Commencement announced for January 2027

Updates

Oct 20, 2026 · 2026.10.20-1
First rule pack: US federal (ROSCA), California ARL as amended by AB 2863, New York State GBL §527-a (as amended 2025), NYC Click-to-Cancel (in force 1 Oct 2026), EU withdrawal function (Directive 2023/2673, in force 19 Jun 2026), UK DMCC Act subscription regime (contracts from 1 Jan 2027).

Not legal advice. Rule summaries are our plain-English reading of official sources and may be incomplete or out of date. Check with a qualified lawyer for your situation.

These rule summaries are not legal advice. They are our reading of the official sources linked on each rule, may be incomplete or out of date, and do not cover every law that may apply to your business.