Background

Why this is a patchwork

For a moment it looked as though one federal rule would govern automatic renewals sold online. It does not. What follows is how that happened, and what it leaves behind — which is the reason this tool evaluates a signup flow against 14 separate state frameworks rather than one national standard.

What happened federally

On July 8, 2025 the United States Court of Appeals for the Eighth Circuit vacated the Federal Trade Commission’s 2024 Negative Option Rule — the rule widely called “click-to-cancel” — in its entirety, on the ground that the Commission had not carried out a preliminary regulatory analysis the FTC Act required. The rule had been due to take effect on July 14, 2025.

On February 12, 2026 the Commission published a final rule restoring the Negative Option Rule in the form it had before the 2024 amendments took effect. The restored rule, titled “Use of Prenotification Negative Option Plans” (16 C.F.R. part 425), reaches prenotification plans — arrangements in which a seller periodically announces merchandise and ships it unless the subscriber declines.

The result is that no federal rule now addresses online automatic renewals specifically. The requirements that reach a subscription signup flow today come from state statutes, from the Federal Trade Commission Act’s prohibition on unfair or deceptive acts or practices, and from the Restore Online Shoppers’ Confidence Act.

What that leaves

The practical consequence for anyone selling a subscription online is that the rules now depend on where a subscriber lives, and the answer differs state by state. A checkout page is one page; the frameworks that bear on it are many, and they do not agree with each other about what has to be disclosed, where it has to appear, or how a customer must be allowed to cancel.

That is why this tool reports observations scoped to the states you select, rather than a single verdict. There is no single verdict to give. Every framework in the matrix, and what each one is summarized as requiring.

Where the state frameworks stand

Each of these has its own page with the statute, the official code link, and the date the summary was last read against its sources.

• California — The AB 2863 amendments carry a 2024 chapter. Secondary sources describe the amended requirements as reaching contracts entered into, amended or extended on or after July 1, 2025.
• Colorado — The act was approved June 3, 2025. It states that one provision takes effect February 16, 2026 and the remainder on the day following the expiration of the ninety-day period after final adjournment, applying to automatic-renewal contracts offered or renewed on or after the applicable date.
• New York — The source consulted stated no effective date on its face. Secondary sources describe amendments to this article as effective in November 2025.
• Minnesota — The source consulted states no effective date on its face; it carries a 2024 session-law history note. Secondary sources describe these requirements as effective January 1, 2025.
• Virginia — The section carries a history line running 2018, 2022, 2023, 2024 and 2026. The 2026 chapters may have changed the operative duties.
• Illinois — The original Act carries a 2000 effective date, with later amendments including ones effective in 2021, 2022 and afterwards.
• Maine — The 2025 amendments are described as applying to offers and agreements entered into or renewed on or after January 1, 2026. That applicability date comes from the session law rather than the statute page, and the provision carrying it is captioned “Application” rather than “Effective date”.
• Massachusetts — The regulation states that it applies to acts committed or practices in force as of September 2, 2025. That is an applicability date rather than a promulgation date.
• Connecticut — The section was enacted in 2023 and amended since. The official source states that on and after July 1, 2026 the section reads as amended by P.A. 25-44 §7.
• Hawaii — The source consulted states no calendar effective date, carrying only session-law history for 2011, 2015 and 2023.
• North Dakota — The source consulted carries no source notes and states no effective date.
• Delaware — The subchapter states that its automatic-renewal provisions take effect on January 1, 2022.
• District of Columbia — The chapter carries a source note giving an effective date of March 13, 2019, with a later amendment.
• Vermont — The section carries a credit line giving an effective date of July 1, 2019, with a later amendment.
• Georgia — The online framework is described as effective January 1, 2024. This tool could not confirm that against an official code page.
• Michigan — Nothing in force. Michigan’s constitution provides that business pending at the final adjournment of an odd-year regular session carries over to the next regular session, so a bill introduced in August 2025 remains live through the 2026 session and would lapse at the end of the two-year term.
• Pennsylvania — Nothing general in force. Two bills are live in the 2025–2026 session, which runs until it adjourns at the end of November 2026; Pennsylvania bills carry over within that two-year session.
• Texas — Nothing in force. Two subscription-contract bills were filed in 2025 and both were referred to committee and went no further. Texas bills do not carry over, the legislature meets in regular session only in odd-numbered years, and the next regular session convenes in January 2027.
• Utah — The source consulted states no calendar effective date, carrying only session-law notes for 2011 and 2014.
• Maryland — The official page states that the section takes effect June 1, 2026 under two 2025 chapters, and at the time this data was gathered that page still carried a “not in effect” marker even though the stated date had passed.

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