Several states and the Federal Trade Commission (FTC) have implemented autorenewal laws aimed at (i) better protecting consumers and providing transparency in automatic renewals (e.g., subscriptions) and (ii) mandating easy cancellation processes to terminate such products.
Although state laws vary, the amended California Automatic Renewal Law (CARL) and the FTC’s Click-to-Cancel Rule (FTC Rule) provide a comprehensive overview of what businesses can expect when complying with autorenewal laws. While these autorenewal requirements have consumers saying “click, click hooray” understanding and implementing these obligations can create a compliance conundrum for businesses. Here is a summary of what businesses should know.