What we check
Every rule in the matrix
This page is generated from the rule matrix itself. 9 rules relate to 14 state frameworks currently in effect. Adding a rule changes this page and the state pages with no further edit, which is what keeps the documentation from drifting away from the code.
LEGAL-CLAIMS-TO-VERIFY.md in the repository, so the lot can be reviewed in one pass.
How current this is
Every check below carries the date somebody last read its requirement wording against the sources it was drafted from, and the sources themselves. State automatic-renewal law moves — sections are amended, effective dates slip — so a summary that has not been looked at recently is marked rather than left to look current.
- Checks in the matrix
- 9
- Oldest review date
2026-08-03- Marked overdue
- none — no summary has gone more than 90 days without a review
- Review interval
- 90 days. A figure this project chose — no framework in this matrix states a review interval.
A review date records that the summary was read against its sources on that date. It does not record that a lawyer read it: nobody qualified to practise law has reviewed any summary in this matrix, which is stated in full on the about page and at the foot of every page. Changes to the rules are logged with their dates in the changelog.
How severity is assigned
Severity is a property of the rule, not of the site. It is fixed in the matrix, published here, and never varies by state — so the same observed fact carries the same weight however many statutes relate to it.
| Level | When it is used |
|---|---|
| High | The check concerns something the frameworks in this matrix locate at the moment consent is given — that the renewal terms be presented, or that consent to them be obtained — and the scanner observed a specific condition directly, by a deterministic measurement of the consent screen, rather than inferring it from something it could not find. |
| Medium | Either the element was observed to be present but a property of it fell outside a numeric threshold this tool chose, or the finding rests on something not appearing on the pages the scan could reach. Both are weaker evidence than a direct observation, and both are capped here. |
| Low | Corroborative rather than primary. It narrows where something appeared rather than establishing that it was absent — for example, that language missing from a page was found in a document linked from it. |
| Manual check | Not a severity at all, and deliberately not ranked against the others. The subject sits outside the signup flow entirely — a post-transaction message, a reminder schedule, a journey behind a login — so no outside scan can reach it. These never count toward any total, and they are listed in every report including reports with no findings. |
Ceilings
The easiest way for a tool like this to become dishonest is to rate its own guesses as highly as its measurements. These three rules exist to stop that, and they are applied in the matrix rather than left to judgement.
- A finding whose trigger includes a signal from the visual pass is capped at medium.A model describing a screenshot is making an observation, not a measurement. It is useful evidence and it is not the same kind of evidence as a computed font size.
- A finding that rests on something not appearing is capped at medium, and must say how much was searched.The walk stops at the card field and never authenticates, so it is structurally likely to miss a cancellation route that exists inside an account. Rating a failure to find something as highly as a direct observation would overstate what the scan did.
- Severity never varies by state.The same observed fact carries the same severity however many statutes relate to it. Breadth of relation is shown separately, as a list of jurisdictions.
Ordering
Findings are ordered by severity, then by the first state each relates to, then by rule identifier. The order is fully determined by the rules rather than by the scan, so two reports for the same site can be compared line by line.
Undetermined is not a severity
If a rule references a signal that was never observed, it produces no finding at any level. It is listed separately as could not be determined, with the missing signal names shown. Absent evidence is not evidence, in either direction.
Rules by state
A single observation can relate to several frameworks at once — the scanner sees one thing, and any number of statutes may bear on it. A rule therefore appears under every state it relates to, and each finding names every statute it relates to rather than being duplicated per state.
California
- Statute
- Cal. Bus. & Prof. Code §§17600–17606 (Art. 9), as amended by AB 2863, Stats. 2024, ch. 515.
- Effective
- 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. [medium confidence — flagged for counsel]
- Applies to
- Businesses making an automatic-renewal or continuous-service offer to a consumer in California, including offers that begin free and convert to a paid term.
| Check | Severity | Detected by |
|---|---|---|
| Automatic-renewal terms were not detected in the visible text presented alongside the consent action.
These frameworks are summarized as requiring the automatic-renewal terms to be presented clearly and conspicuously before the consumer agrees, in visual proximity to the request for consent.
ARL-DISCLOSURE-AT-CONSENT
Rule summary last reviewed: 2026-08-03
Due again 2026-11-01.
Drafted from 9 sources:
leginfo.legislature.ca.gov/…/codes_displayText.xhtml · content.leg.colorado.gov/…/2025a_sl_368.pdf · www.cga.ct.gov/…/chap_742d.htm · www.ilga.gov/…/Articles · www.mass.gov/…/940-CMR-3800-unfair-and-dece · legislature.maine.gov/…/title10sec1210-C.html · www.revisor.mn.gov/…/325G.57 · www.nysenate.gov/…/527-A · law.lis.virginia.gov/…/section59.1-207.46
|
High
consent moment absence |
automatic
proximityToConsentAction renewalTermsProminence renewalTextOnlyInLinkedTermsIncludes a signal from the visual pass, which caps this check at medium severity. |
| Renewal text was found on the page, but its type size or its distance from the price and consent control was outside the thresholds this scanner checks.
The "clear and conspicuous" standard in these frameworks is summarized as reaching the legibility and placement of the disclosure, including its type size and its proximity to the price and the consent control.
ARL-DISCLOSURE-PRESENTATION
Rule summary last reviewed: 2026-08-03
Due again 2026-11-01.
Drafted from 3 sources:
leginfo.legislature.ca.gov/…/codes_displayText.xhtml · www.revisor.mn.gov/…/325G.57 · www.nysenate.gov/…/527-A
|
Medium
tool chosen threshold |
automatic
disclosureFontSize priceAndIntervalNearCTA renewalTextOnPage |
| No dedicated, unchecked consent control for the renewal terms was detected separately from general terms acceptance.
Express affirmative consent to the automatic-renewal terms specifically is summarized as needing to be separate from acceptance of general terms and conditions.
ARL-AFFIRMATIVE-CONSENT
Rule summary last reviewed: 2026-08-03
Due again 2026-11-01.
Drafted from 2 sources:
leginfo.legislature.ca.gov/…/codes_displayText.xhtml · legislature.maine.gov/…/title10sec1210-C.html
|
High
consent moment absence |
automatic
prechecked separateConsentCheckbox |
| Trial or promotional pricing was detected without accompanying visible text describing the charge that follows it.
These frameworks are summarized as covering offers that begin free or discounted and convert to a paid term, with the terms of that conversion disclosed before the consumer agrees.
ARL-TRIAL-CONVERSION
Rule summary last reviewed: 2026-08-03
Due again 2026-11-01.
|
High
consent moment absence |
automatic
trialConversionTerms trialLanguage |
| No link or control matching an online cancellation route was found on the pages this scan could reach.
These frameworks are summarized as requiring a subscription entered into online to be cancellable through the same online medium, without additional obstruction.
ARL-CANCEL-ONLINE-ROUTE
Rule summary last reviewed: 2026-08-03
Due again 2026-11-01.
Drafted from 9 sources:
leginfo.legislature.ca.gov/…/codes_displayText.xhtml · content.leg.colorado.gov/…/2025a_sl_368.pdf · www.cga.ct.gov/…/chap_742d.htm · www.ilga.gov/…/Articles · www.mass.gov/…/940-CMR-3800-unfair-and-dece · legislature.maine.gov/…/title10sec1210-C.html · www.revisor.mn.gov/…/325G.57 · www.nysenate.gov/…/527-A · law.lis.virginia.gov/…/section59.1-207.46
|
Medium
non appearance |
automatic
onlineCancelPath |
| The fetched terms text describes cancelling by telephone.
Where a subscription was entered into online, these frameworks are summarized as requiring an online route to cancel, so a route available only by telephone is described as not meeting that requirement on its own.
ARL-CANCEL-TELEPHONE-ONLY
Rule summary last reviewed: 2026-08-03
Due again 2026-11-01.
Drafted from 9 sources:
leginfo.legislature.ca.gov/…/codes_displayText.xhtml · content.leg.colorado.gov/…/2025a_sl_368.pdf · www.cga.ct.gov/…/chap_742d.htm · www.ilga.gov/…/Articles · www.mass.gov/…/940-CMR-3800-unfair-and-dece · legislature.maine.gov/…/title10sec1210-C.html · www.revisor.mn.gov/…/325G.57 · www.nysenate.gov/…/527-A · law.lis.virginia.gov/…/section59.1-207.46
|
High
consent moment absence |
automatic
phoneOnlyCancel |
| Not observable from outside the signup flow.
A post-transaction acknowledgment is summarized as needing to include the renewal terms and cancellation instructions in a form the consumer can retain.
ARL-POST-TRANSACTION-ACK
Rule summary last reviewed: 2026-08-03
Due again 2026-11-01.
|
Manual check
outside flow |
manual verification only
No signal can reach this. It is listed in every report and never counted as a finding. |
Colorado
- Statute
- Colo. Rev. Stat. §6-1-732, as amended by SB25-145 (2025 Colo. Sess. Laws ch. 368). [medium confidence — flagged for counsel]
- Effective
- 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.
- Applies to
- Any person offering an automatic-renewal contract or trial-period offer to a consumer in Colorado. SB25-145 broadened the definition of consumer beyond individuals buying for personal, family or household purposes, so this framework may reach business customers as well. [medium confidence — flagged for counsel]
| Check | Severity | Detected by |
|---|---|---|
| Automatic-renewal terms were not detected in the visible text presented alongside the consent action.
These frameworks are summarized as requiring the automatic-renewal terms to be presented clearly and conspicuously before the consumer agrees, in visual proximity to the request for consent.
ARL-DISCLOSURE-AT-CONSENT
Rule summary last reviewed: 2026-08-03
Due again 2026-11-01.
Drafted from 9 sources:
leginfo.legislature.ca.gov/…/codes_displayText.xhtml · content.leg.colorado.gov/…/2025a_sl_368.pdf · www.cga.ct.gov/…/chap_742d.htm · www.ilga.gov/…/Articles · www.mass.gov/…/940-CMR-3800-unfair-and-dece · legislature.maine.gov/…/title10sec1210-C.html · www.revisor.mn.gov/…/325G.57 · www.nysenate.gov/…/527-A · law.lis.virginia.gov/…/section59.1-207.46
|
High
consent moment absence |
automatic
proximityToConsentAction renewalTermsProminence renewalTextOnlyInLinkedTermsIncludes a signal from the visual pass, which caps this check at medium severity. |
| Trial or promotional pricing was detected without accompanying visible text describing the charge that follows it.
These frameworks are summarized as covering offers that begin free or discounted and convert to a paid term, with the terms of that conversion disclosed before the consumer agrees.
ARL-TRIAL-CONVERSION
Rule summary last reviewed: 2026-08-03
Due again 2026-11-01.
|
High
consent moment absence |
automatic
trialConversionTerms trialLanguage |
| No link or control matching an online cancellation route was found on the pages this scan could reach.
These frameworks are summarized as requiring a subscription entered into online to be cancellable through the same online medium, without additional obstruction.
ARL-CANCEL-ONLINE-ROUTE
Rule summary last reviewed: 2026-08-03
Due again 2026-11-01.
Drafted from 9 sources:
leginfo.legislature.ca.gov/…/codes_displayText.xhtml · content.leg.colorado.gov/…/2025a_sl_368.pdf · www.cga.ct.gov/…/chap_742d.htm · www.ilga.gov/…/Articles · www.mass.gov/…/940-CMR-3800-unfair-and-dece · legislature.maine.gov/…/title10sec1210-C.html · www.revisor.mn.gov/…/325G.57 · www.nysenate.gov/…/527-A · law.lis.virginia.gov/…/section59.1-207.46
|
Medium
non appearance |
automatic
onlineCancelPath |
| The fetched terms text describes cancelling by telephone.
Where a subscription was entered into online, these frameworks are summarized as requiring an online route to cancel, so a route available only by telephone is described as not meeting that requirement on its own.
ARL-CANCEL-TELEPHONE-ONLY
Rule summary last reviewed: 2026-08-03
Due again 2026-11-01.
Drafted from 9 sources:
leginfo.legislature.ca.gov/…/codes_displayText.xhtml · content.leg.colorado.gov/…/2025a_sl_368.pdf · www.cga.ct.gov/…/chap_742d.htm · www.ilga.gov/…/Articles · www.mass.gov/…/940-CMR-3800-unfair-and-dece · legislature.maine.gov/…/title10sec1210-C.html · www.revisor.mn.gov/…/325G.57 · www.nysenate.gov/…/527-A · law.lis.virginia.gov/…/section59.1-207.46
|
High
consent moment absence |
automatic
phoneOnlyCancel |
Connecticut
- Statute
- Conn. Gen. Stat. §42-158ff (ch. 742d), as amended by P.A. 25-44 §7. An older, overlapping provision sits at §42-126b(c). [medium confidence — flagged for counsel]
- Effective
- 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.
- Applies to
- Businesses offering a consumer agreement containing an automatic-renewal or continuous-services provision to a Connecticut resident for personal, family or household purposes. Utility, insurance, banking and certain predominantly audiovisual services are described as carved out.
| Check | Severity | Detected by |
|---|---|---|
| Automatic-renewal terms were not detected in the visible text presented alongside the consent action.
These frameworks are summarized as requiring the automatic-renewal terms to be presented clearly and conspicuously before the consumer agrees, in visual proximity to the request for consent.
ARL-DISCLOSURE-AT-CONSENT
Rule summary last reviewed: 2026-08-03
Due again 2026-11-01.
Drafted from 9 sources:
leginfo.legislature.ca.gov/…/codes_displayText.xhtml · content.leg.colorado.gov/…/2025a_sl_368.pdf · www.cga.ct.gov/…/chap_742d.htm · www.ilga.gov/…/Articles · www.mass.gov/…/940-CMR-3800-unfair-and-dece · legislature.maine.gov/…/title10sec1210-C.html · www.revisor.mn.gov/…/325G.57 · www.nysenate.gov/…/527-A · law.lis.virginia.gov/…/section59.1-207.46
|
High
consent moment absence |
automatic
proximityToConsentAction renewalTermsProminence renewalTextOnlyInLinkedTermsIncludes a signal from the visual pass, which caps this check at medium severity. |
| Trial or promotional pricing was detected without accompanying visible text describing the charge that follows it.
These frameworks are summarized as covering offers that begin free or discounted and convert to a paid term, with the terms of that conversion disclosed before the consumer agrees.
ARL-TRIAL-CONVERSION
Rule summary last reviewed: 2026-08-03
Due again 2026-11-01.
|
High
consent moment absence |
automatic
trialConversionTerms trialLanguage |
| No link or control matching an online cancellation route was found on the pages this scan could reach.
These frameworks are summarized as requiring a subscription entered into online to be cancellable through the same online medium, without additional obstruction.
ARL-CANCEL-ONLINE-ROUTE
Rule summary last reviewed: 2026-08-03
Due again 2026-11-01.
Drafted from 9 sources:
leginfo.legislature.ca.gov/…/codes_displayText.xhtml · content.leg.colorado.gov/…/2025a_sl_368.pdf · www.cga.ct.gov/…/chap_742d.htm · www.ilga.gov/…/Articles · www.mass.gov/…/940-CMR-3800-unfair-and-dece · legislature.maine.gov/…/title10sec1210-C.html · www.revisor.mn.gov/…/325G.57 · www.nysenate.gov/…/527-A · law.lis.virginia.gov/…/section59.1-207.46
|
Medium
non appearance |
automatic
onlineCancelPath |
| The fetched terms text describes cancelling by telephone.
Where a subscription was entered into online, these frameworks are summarized as requiring an online route to cancel, so a route available only by telephone is described as not meeting that requirement on its own.
ARL-CANCEL-TELEPHONE-ONLY
Rule summary last reviewed: 2026-08-03
Due again 2026-11-01.
Drafted from 9 sources:
leginfo.legislature.ca.gov/…/codes_displayText.xhtml · content.leg.colorado.gov/…/2025a_sl_368.pdf · www.cga.ct.gov/…/chap_742d.htm · www.ilga.gov/…/Articles · www.mass.gov/…/940-CMR-3800-unfair-and-dece · legislature.maine.gov/…/title10sec1210-C.html · www.revisor.mn.gov/…/325G.57 · www.nysenate.gov/…/527-A · law.lis.virginia.gov/…/section59.1-207.46
|
High
consent moment absence |
automatic
phoneOnlyCancel |
| Not observable from a checkout flow.
An annual reminder is summarized as required for agreements that are indefinite or that renew continuously, regardless of the length of the term.
ARL-ANNUAL-REMINDER
Rule summary last reviewed: 2026-08-03
Due again 2026-11-01.
Drafted from 2 sources:
www.cga.ct.gov/…/chap_742d.htm · www.revisor.mn.gov/…/325G.57
|
Manual check
outside flow |
manual verification only
No signal can reach this. It is listed in every report and never counted as a finding. |
| Not observable from a checkout flow.
These frameworks are summarized as requiring notice ahead of a renewal in defined circumstances — in Virginia, where a renewal term runs longer than 30 days and extends the contract beyond 12 months.
ARL-RENEWAL-NOTICE
Rule summary last reviewed: 2026-08-03
Due again 2026-11-01.
Drafted from 10 sources:
www.cga.ct.gov/…/chap_742d.htm · code.dccouncil.gov/…/2 · delcode.delaware.gov/…/index.html · data.capitol.hawaii.gov/…/HRS_0481-0009_0005.htm · www.ilga.gov/…/Articles · www.mass.gov/…/940-CMR-3800-unfair-and-dece · ndlegis.gov/…/t51c37.pdf · www.nysenate.gov/…/527-A · law.lis.virginia.gov/…/section59.1-207.46 · legislature.vermont.gov/…/02454a
|
Manual check
outside flow |
manual verification only
No signal can reach this. It is listed in every report and never counted as a finding. |
Delaware
- Statute
- 6 Del. C. §2734, within subch. IV of ch. 27 (§§2731–2737).
- Effective
- The subchapter states that its automatic-renewal provisions take effect on January 1, 2022.
- Applies to
- Sellers of merchandise to a consumer under a contract containing an automatic-renewal provision. Contracts over $50,000, banking organisations, filed utility tariffs, matters under utility, insurance or federal communications jurisdiction, and residential and manufactured housing leases are described as excluded.
- Scope limit
- This framework is summarized as reaching contracts above a term threshold rather than every subscription, so an ordinary month-to-month plan may sit outside it. Only the checks that concern longer contracts relate to it here. The definition is described as reaching renewal for a specified period of more than one month where the renewal causes the contract to run more than twelve months from initiation, which places an ordinary monthly subscription outside it.
| Check | Severity | Detected by |
|---|---|---|
| Not observable from a checkout flow.
These frameworks are summarized as requiring notice ahead of a renewal in defined circumstances — in Virginia, where a renewal term runs longer than 30 days and extends the contract beyond 12 months.
ARL-RENEWAL-NOTICE
Rule summary last reviewed: 2026-08-03
Due again 2026-11-01.
Drafted from 10 sources:
www.cga.ct.gov/…/chap_742d.htm · code.dccouncil.gov/…/2 · delcode.delaware.gov/…/index.html · data.capitol.hawaii.gov/…/HRS_0481-0009_0005.htm · www.ilga.gov/…/Articles · www.mass.gov/…/940-CMR-3800-unfair-and-dece · ndlegis.gov/…/t51c37.pdf · www.nysenate.gov/…/527-A · law.lis.virginia.gov/…/section59.1-207.46 · legislature.vermont.gov/…/02454a
|
Manual check
outside flow |
manual verification only
No signal can reach this. It is listed in every report and never counted as a finding. |
District of Columbia
- Statute
- D.C. Code §28A-201 et seq.
- Effective
- The chapter carries a source note giving an effective date of March 13, 2019, with a later amendment. [medium confidence — flagged for counsel]
- Applies to
- Sellers offering consumer contracts with automatic-renewal provisions or free trials in the District. Insurers, depository institutions, utility and federally regulated services and certain service contracts are described as excluded.
- Scope limit
- This framework is summarized as reaching contracts above a term threshold rather than every subscription, so an ordinary month-to-month plan may sit outside it. Only the checks that concern longer contracts relate to it here. The renewal-notice duty is described as attaching where the initial term is twelve months or more; a separate duty reaches free trials of one month or more.
| Check | Severity | Detected by |
|---|---|---|
| Not observable from a checkout flow.
These frameworks are summarized as requiring notice ahead of a renewal in defined circumstances — in Virginia, where a renewal term runs longer than 30 days and extends the contract beyond 12 months.
ARL-RENEWAL-NOTICE
Rule summary last reviewed: 2026-08-03
Due again 2026-11-01.
Drafted from 10 sources:
www.cga.ct.gov/…/chap_742d.htm · code.dccouncil.gov/…/2 · delcode.delaware.gov/…/index.html · data.capitol.hawaii.gov/…/HRS_0481-0009_0005.htm · www.ilga.gov/…/Articles · www.mass.gov/…/940-CMR-3800-unfair-and-dece · ndlegis.gov/…/t51c37.pdf · www.nysenate.gov/…/527-A · law.lis.virginia.gov/…/section59.1-207.46 · legislature.vermont.gov/…/02454a
|
Manual check
outside flow |
manual verification only
No signal can reach this. It is listed in every report and never counted as a finding. |
Hawaii
- Statute
- Haw. Rev. Stat. §481-9.5.
- Effective
- The source consulted states no calendar effective date, carrying only session-law history for 2011, 2015 and 2023. [medium confidence — flagged for counsel]
- Applies to
- Persons selling to a consumer under a consumer contract containing an automatic-renewal or continuous-service clause. Financial institutions, insurers, telecommunications providers and cable operators are described as excluded to the extent of their regulated activities.
- Scope limit
- This framework is summarized as reaching contracts above a term threshold rather than every subscription, so an ordinary month-to-month plan may sit outside it. Only the checks that concern longer contracts relate to it here. The disclosure duty is described as attaching where a contract has a specified term of more than one month that renews for a term of more than one month, and the renewal-notice duty where the term is twelve months or more.
| Check | Severity | Detected by |
|---|---|---|
| Not observable from outside the signup flow.
A post-transaction acknowledgment is summarized as needing to include the renewal terms and cancellation instructions in a form the consumer can retain.
ARL-POST-TRANSACTION-ACK
Rule summary last reviewed: 2026-08-03
Due again 2026-11-01.
|
Manual check
outside flow |
manual verification only
No signal can reach this. It is listed in every report and never counted as a finding. |
| Not observable from a checkout flow.
These frameworks are summarized as requiring notice ahead of a renewal in defined circumstances — in Virginia, where a renewal term runs longer than 30 days and extends the contract beyond 12 months.
ARL-RENEWAL-NOTICE
Rule summary last reviewed: 2026-08-03
Due again 2026-11-01.
Drafted from 10 sources:
www.cga.ct.gov/…/chap_742d.htm · code.dccouncil.gov/…/2 · delcode.delaware.gov/…/index.html · data.capitol.hawaii.gov/…/HRS_0481-0009_0005.htm · www.ilga.gov/…/Articles · www.mass.gov/…/940-CMR-3800-unfair-and-dece · ndlegis.gov/…/t51c37.pdf · www.nysenate.gov/…/527-A · law.lis.virginia.gov/…/section59.1-207.46 · legislature.vermont.gov/…/02454a
|
Manual check
outside flow |
manual verification only
No signal can reach this. It is listed in every report and never counted as a finding. |
Illinois
- Statute
- 815 ILCS 601, Automatic Contract Renewal Act.
- Effective
- The original Act carries a 2000 effective date, with later amendments including ones effective in 2021, 2022 and afterwards. [medium confidence — flagged for counsel]
- Applies to
- Persons selling products or services to a consumer under a contract that renews automatically. Business-to-business contracts, depository institutions, certain utility providers and insurance-regulated parties are described as excluded.
| Check | Severity | Detected by |
|---|---|---|
| Automatic-renewal terms were not detected in the visible text presented alongside the consent action.
These frameworks are summarized as requiring the automatic-renewal terms to be presented clearly and conspicuously before the consumer agrees, in visual proximity to the request for consent.
ARL-DISCLOSURE-AT-CONSENT
Rule summary last reviewed: 2026-08-03
Due again 2026-11-01.
Drafted from 9 sources:
leginfo.legislature.ca.gov/…/codes_displayText.xhtml · content.leg.colorado.gov/…/2025a_sl_368.pdf · www.cga.ct.gov/…/chap_742d.htm · www.ilga.gov/…/Articles · www.mass.gov/…/940-CMR-3800-unfair-and-dece · legislature.maine.gov/…/title10sec1210-C.html · www.revisor.mn.gov/…/325G.57 · www.nysenate.gov/…/527-A · law.lis.virginia.gov/…/section59.1-207.46
|
High
consent moment absence |
automatic
proximityToConsentAction renewalTermsProminence renewalTextOnlyInLinkedTermsIncludes a signal from the visual pass, which caps this check at medium severity. |
| No link or control matching an online cancellation route was found on the pages this scan could reach.
These frameworks are summarized as requiring a subscription entered into online to be cancellable through the same online medium, without additional obstruction.
ARL-CANCEL-ONLINE-ROUTE
Rule summary last reviewed: 2026-08-03
Due again 2026-11-01.
Drafted from 9 sources:
leginfo.legislature.ca.gov/…/codes_displayText.xhtml · content.leg.colorado.gov/…/2025a_sl_368.pdf · www.cga.ct.gov/…/chap_742d.htm · www.ilga.gov/…/Articles · www.mass.gov/…/940-CMR-3800-unfair-and-dece · legislature.maine.gov/…/title10sec1210-C.html · www.revisor.mn.gov/…/325G.57 · www.nysenate.gov/…/527-A · law.lis.virginia.gov/…/section59.1-207.46
|
Medium
non appearance |
automatic
onlineCancelPath |
| The fetched terms text describes cancelling by telephone.
Where a subscription was entered into online, these frameworks are summarized as requiring an online route to cancel, so a route available only by telephone is described as not meeting that requirement on its own.
ARL-CANCEL-TELEPHONE-ONLY
Rule summary last reviewed: 2026-08-03
Due again 2026-11-01.
Drafted from 9 sources:
leginfo.legislature.ca.gov/…/codes_displayText.xhtml · content.leg.colorado.gov/…/2025a_sl_368.pdf · www.cga.ct.gov/…/chap_742d.htm · www.ilga.gov/…/Articles · www.mass.gov/…/940-CMR-3800-unfair-and-dece · legislature.maine.gov/…/title10sec1210-C.html · www.revisor.mn.gov/…/325G.57 · www.nysenate.gov/…/527-A · law.lis.virginia.gov/…/section59.1-207.46
|
High
consent moment absence |
automatic
phoneOnlyCancel |
| Not observable from a checkout flow.
These frameworks are summarized as requiring notice ahead of a renewal in defined circumstances — in Virginia, where a renewal term runs longer than 30 days and extends the contract beyond 12 months.
ARL-RENEWAL-NOTICE
Rule summary last reviewed: 2026-08-03
Due again 2026-11-01.
Drafted from 10 sources:
www.cga.ct.gov/…/chap_742d.htm · code.dccouncil.gov/…/2 · delcode.delaware.gov/…/index.html · data.capitol.hawaii.gov/…/HRS_0481-0009_0005.htm · www.ilga.gov/…/Articles · www.mass.gov/…/940-CMR-3800-unfair-and-dece · ndlegis.gov/…/t51c37.pdf · www.nysenate.gov/…/527-A · law.lis.virginia.gov/…/section59.1-207.46 · legislature.vermont.gov/…/02454a
|
Manual check
outside flow |
manual verification only
No signal can reach this. It is listed in every report and never counted as a finding. |
Maine
- Statute
- 10 M.R.S. §§1210-C and 1210-D, as amended by 2025 Maine Public Law ch. 376.
- Effective
- 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”. [medium confidence — flagged for counsel]
- Applies to
- Sellers making an automatic subscription or health-club membership renewal offer to a consumer in Maine. The chapter heading names health clubs, but the provisions are not limited to them.
| Check | Severity | Detected by |
|---|---|---|
| Automatic-renewal terms were not detected in the visible text presented alongside the consent action.
These frameworks are summarized as requiring the automatic-renewal terms to be presented clearly and conspicuously before the consumer agrees, in visual proximity to the request for consent.
ARL-DISCLOSURE-AT-CONSENT
Rule summary last reviewed: 2026-08-03
Due again 2026-11-01.
Drafted from 9 sources:
leginfo.legislature.ca.gov/…/codes_displayText.xhtml · content.leg.colorado.gov/…/2025a_sl_368.pdf · www.cga.ct.gov/…/chap_742d.htm · www.ilga.gov/…/Articles · www.mass.gov/…/940-CMR-3800-unfair-and-dece · legislature.maine.gov/…/title10sec1210-C.html · www.revisor.mn.gov/…/325G.57 · www.nysenate.gov/…/527-A · law.lis.virginia.gov/…/section59.1-207.46
|
High
consent moment absence |
automatic
proximityToConsentAction renewalTermsProminence renewalTextOnlyInLinkedTermsIncludes a signal from the visual pass, which caps this check at medium severity. |
| No dedicated, unchecked consent control for the renewal terms was detected separately from general terms acceptance.
Express affirmative consent to the automatic-renewal terms specifically is summarized as needing to be separate from acceptance of general terms and conditions.
ARL-AFFIRMATIVE-CONSENT
Rule summary last reviewed: 2026-08-03
Due again 2026-11-01.
Drafted from 2 sources:
leginfo.legislature.ca.gov/…/codes_displayText.xhtml · legislature.maine.gov/…/title10sec1210-C.html
|
High
consent moment absence |
automatic
prechecked separateConsentCheckbox |
| No link or control matching an online cancellation route was found on the pages this scan could reach.
These frameworks are summarized as requiring a subscription entered into online to be cancellable through the same online medium, without additional obstruction.
ARL-CANCEL-ONLINE-ROUTE
Rule summary last reviewed: 2026-08-03
Due again 2026-11-01.
Drafted from 9 sources:
leginfo.legislature.ca.gov/…/codes_displayText.xhtml · content.leg.colorado.gov/…/2025a_sl_368.pdf · www.cga.ct.gov/…/chap_742d.htm · www.ilga.gov/…/Articles · www.mass.gov/…/940-CMR-3800-unfair-and-dece · legislature.maine.gov/…/title10sec1210-C.html · www.revisor.mn.gov/…/325G.57 · www.nysenate.gov/…/527-A · law.lis.virginia.gov/…/section59.1-207.46
|
Medium
non appearance |
automatic
onlineCancelPath |
| The fetched terms text describes cancelling by telephone.
Where a subscription was entered into online, these frameworks are summarized as requiring an online route to cancel, so a route available only by telephone is described as not meeting that requirement on its own.
ARL-CANCEL-TELEPHONE-ONLY
Rule summary last reviewed: 2026-08-03
Due again 2026-11-01.
Drafted from 9 sources:
leginfo.legislature.ca.gov/…/codes_displayText.xhtml · content.leg.colorado.gov/…/2025a_sl_368.pdf · www.cga.ct.gov/…/chap_742d.htm · www.ilga.gov/…/Articles · www.mass.gov/…/940-CMR-3800-unfair-and-dece · legislature.maine.gov/…/title10sec1210-C.html · www.revisor.mn.gov/…/325G.57 · www.nysenate.gov/…/527-A · law.lis.virginia.gov/…/section59.1-207.46
|
High
consent moment absence |
automatic
phoneOnlyCancel |
Massachusetts
- Statute
- 940 CMR 38.05 — an Attorney General regulation made under the Massachusetts consumer protection act, not a statute. The automatic-renewal content sits at 38.05 within 940 CMR 38.00. [medium confidence — flagged for counsel]
- Effective
- 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. [medium confidence — flagged for counsel]
- Applies to
- Any person whose advertising, marketing or offer of sale is targeted to or results in a sale in Massachusetts, where the product — including memberships and subscriptions — is for personal, family or household use.
| Check | Severity | Detected by |
|---|---|---|
| Automatic-renewal terms were not detected in the visible text presented alongside the consent action.
These frameworks are summarized as requiring the automatic-renewal terms to be presented clearly and conspicuously before the consumer agrees, in visual proximity to the request for consent.
ARL-DISCLOSURE-AT-CONSENT
Rule summary last reviewed: 2026-08-03
Due again 2026-11-01.
Drafted from 9 sources:
leginfo.legislature.ca.gov/…/codes_displayText.xhtml · content.leg.colorado.gov/…/2025a_sl_368.pdf · www.cga.ct.gov/…/chap_742d.htm · www.ilga.gov/…/Articles · www.mass.gov/…/940-CMR-3800-unfair-and-dece · legislature.maine.gov/…/title10sec1210-C.html · www.revisor.mn.gov/…/325G.57 · www.nysenate.gov/…/527-A · law.lis.virginia.gov/…/section59.1-207.46
|
High
consent moment absence |
automatic
proximityToConsentAction renewalTermsProminence renewalTextOnlyInLinkedTermsIncludes a signal from the visual pass, which caps this check at medium severity. |
| Trial or promotional pricing was detected without accompanying visible text describing the charge that follows it.
These frameworks are summarized as covering offers that begin free or discounted and convert to a paid term, with the terms of that conversion disclosed before the consumer agrees.
ARL-TRIAL-CONVERSION
Rule summary last reviewed: 2026-08-03
Due again 2026-11-01.
|
High
consent moment absence |
automatic
trialConversionTerms trialLanguage |
| No link or control matching an online cancellation route was found on the pages this scan could reach.
These frameworks are summarized as requiring a subscription entered into online to be cancellable through the same online medium, without additional obstruction.
ARL-CANCEL-ONLINE-ROUTE
Rule summary last reviewed: 2026-08-03
Due again 2026-11-01.
Drafted from 9 sources:
leginfo.legislature.ca.gov/…/codes_displayText.xhtml · content.leg.colorado.gov/…/2025a_sl_368.pdf · www.cga.ct.gov/…/chap_742d.htm · www.ilga.gov/…/Articles · www.mass.gov/…/940-CMR-3800-unfair-and-dece · legislature.maine.gov/…/title10sec1210-C.html · www.revisor.mn.gov/…/325G.57 · www.nysenate.gov/…/527-A · law.lis.virginia.gov/…/section59.1-207.46
|
Medium
non appearance |
automatic
onlineCancelPath |
| The fetched terms text describes cancelling by telephone.
Where a subscription was entered into online, these frameworks are summarized as requiring an online route to cancel, so a route available only by telephone is described as not meeting that requirement on its own.
ARL-CANCEL-TELEPHONE-ONLY
Rule summary last reviewed: 2026-08-03
Due again 2026-11-01.
Drafted from 9 sources:
leginfo.legislature.ca.gov/…/codes_displayText.xhtml · content.leg.colorado.gov/…/2025a_sl_368.pdf · www.cga.ct.gov/…/chap_742d.htm · www.ilga.gov/…/Articles · www.mass.gov/…/940-CMR-3800-unfair-and-dece · legislature.maine.gov/…/title10sec1210-C.html · www.revisor.mn.gov/…/325G.57 · www.nysenate.gov/…/527-A · law.lis.virginia.gov/…/section59.1-207.46
|
High
consent moment absence |
automatic
phoneOnlyCancel |
| Not observable from a checkout flow.
These frameworks are summarized as requiring notice ahead of a renewal in defined circumstances — in Virginia, where a renewal term runs longer than 30 days and extends the contract beyond 12 months.
ARL-RENEWAL-NOTICE
Rule summary last reviewed: 2026-08-03
Due again 2026-11-01.
Drafted from 10 sources:
www.cga.ct.gov/…/chap_742d.htm · code.dccouncil.gov/…/2 · delcode.delaware.gov/…/index.html · data.capitol.hawaii.gov/…/HRS_0481-0009_0005.htm · www.ilga.gov/…/Articles · www.mass.gov/…/940-CMR-3800-unfair-and-dece · ndlegis.gov/…/t51c37.pdf · www.nysenate.gov/…/527-A · law.lis.virginia.gov/…/section59.1-207.46 · legislature.vermont.gov/…/02454a
|
Manual check
outside flow |
manual verification only
No signal can reach this. It is listed in every report and never counted as a finding. |
Minnesota
- Statute
- Minn. Stat. §325G.57, within the automatic-renewal group at §§325G.56–325G.63.
- Effective
- 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. [medium confidence — flagged for counsel]
- Applies to
- Sellers making automatic-renewal or continuous-service offers to consumers under an indefinite subscription agreement. A general consumer framework, not sector-limited.
| Check | Severity | Detected by |
|---|---|---|
| Automatic-renewal terms were not detected in the visible text presented alongside the consent action.
These frameworks are summarized as requiring the automatic-renewal terms to be presented clearly and conspicuously before the consumer agrees, in visual proximity to the request for consent.
ARL-DISCLOSURE-AT-CONSENT
Rule summary last reviewed: 2026-08-03
Due again 2026-11-01.
Drafted from 9 sources:
leginfo.legislature.ca.gov/…/codes_displayText.xhtml · content.leg.colorado.gov/…/2025a_sl_368.pdf · www.cga.ct.gov/…/chap_742d.htm · www.ilga.gov/…/Articles · www.mass.gov/…/940-CMR-3800-unfair-and-dece · legislature.maine.gov/…/title10sec1210-C.html · www.revisor.mn.gov/…/325G.57 · www.nysenate.gov/…/527-A · law.lis.virginia.gov/…/section59.1-207.46
|
High
consent moment absence |
automatic
proximityToConsentAction renewalTermsProminence renewalTextOnlyInLinkedTermsIncludes a signal from the visual pass, which caps this check at medium severity. |
| Renewal text was found on the page, but its type size or its distance from the price and consent control was outside the thresholds this scanner checks.
The "clear and conspicuous" standard in these frameworks is summarized as reaching the legibility and placement of the disclosure, including its type size and its proximity to the price and the consent control.
ARL-DISCLOSURE-PRESENTATION
Rule summary last reviewed: 2026-08-03
Due again 2026-11-01.
Drafted from 3 sources:
leginfo.legislature.ca.gov/…/codes_displayText.xhtml · www.revisor.mn.gov/…/325G.57 · www.nysenate.gov/…/527-A
|
Medium
tool chosen threshold |
automatic
disclosureFontSize priceAndIntervalNearCTA renewalTextOnPage |
| No link or control matching an online cancellation route was found on the pages this scan could reach.
These frameworks are summarized as requiring a subscription entered into online to be cancellable through the same online medium, without additional obstruction.
ARL-CANCEL-ONLINE-ROUTE
Rule summary last reviewed: 2026-08-03
Due again 2026-11-01.
Drafted from 9 sources:
leginfo.legislature.ca.gov/…/codes_displayText.xhtml · content.leg.colorado.gov/…/2025a_sl_368.pdf · www.cga.ct.gov/…/chap_742d.htm · www.ilga.gov/…/Articles · www.mass.gov/…/940-CMR-3800-unfair-and-dece · legislature.maine.gov/…/title10sec1210-C.html · www.revisor.mn.gov/…/325G.57 · www.nysenate.gov/…/527-A · law.lis.virginia.gov/…/section59.1-207.46
|
Medium
non appearance |
automatic
onlineCancelPath |
| The fetched terms text describes cancelling by telephone.
Where a subscription was entered into online, these frameworks are summarized as requiring an online route to cancel, so a route available only by telephone is described as not meeting that requirement on its own.
ARL-CANCEL-TELEPHONE-ONLY
Rule summary last reviewed: 2026-08-03
Due again 2026-11-01.
Drafted from 9 sources:
leginfo.legislature.ca.gov/…/codes_displayText.xhtml · content.leg.colorado.gov/…/2025a_sl_368.pdf · www.cga.ct.gov/…/chap_742d.htm · www.ilga.gov/…/Articles · www.mass.gov/…/940-CMR-3800-unfair-and-dece · legislature.maine.gov/…/title10sec1210-C.html · www.revisor.mn.gov/…/325G.57 · www.nysenate.gov/…/527-A · law.lis.virginia.gov/…/section59.1-207.46
|
High
consent moment absence |
automatic
phoneOnlyCancel |
| Not observable from outside the signup flow.
A post-transaction acknowledgment is summarized as needing to include the renewal terms and cancellation instructions in a form the consumer can retain.
ARL-POST-TRANSACTION-ACK
Rule summary last reviewed: 2026-08-03
Due again 2026-11-01.
|
Manual check
outside flow |
manual verification only
No signal can reach this. It is listed in every report and never counted as a finding. |
| Not observable from a checkout flow.
An annual reminder is summarized as required for agreements that are indefinite or that renew continuously, regardless of the length of the term.
ARL-ANNUAL-REMINDER
Rule summary last reviewed: 2026-08-03
Due again 2026-11-01.
Drafted from 2 sources:
www.cga.ct.gov/…/chap_742d.htm · www.revisor.mn.gov/…/325G.57
|
Manual check
outside flow |
manual verification only
No signal can reach this. It is listed in every report and never counted as a finding. |
New York
- Statute
- N.Y. Gen. Bus. Law §527-a, in Article 29-BB. The operative duties sit in §527-a; §527 carries the definitions.
- Effective
- The source consulted stated no effective date on its face. Secondary sources describe amendments to this article as effective in November 2025. [medium confidence — flagged for counsel]
- Applies to
- Any business making an automatic-renewal or continuous-service offer to a consumer in New York. A general consumer framework, not sector-limited.
| Check | Severity | Detected by |
|---|---|---|
| Automatic-renewal terms were not detected in the visible text presented alongside the consent action.
These frameworks are summarized as requiring the automatic-renewal terms to be presented clearly and conspicuously before the consumer agrees, in visual proximity to the request for consent.
ARL-DISCLOSURE-AT-CONSENT
Rule summary last reviewed: 2026-08-03
Due again 2026-11-01.
Drafted from 9 sources:
leginfo.legislature.ca.gov/…/codes_displayText.xhtml · content.leg.colorado.gov/…/2025a_sl_368.pdf · www.cga.ct.gov/…/chap_742d.htm · www.ilga.gov/…/Articles · www.mass.gov/…/940-CMR-3800-unfair-and-dece · legislature.maine.gov/…/title10sec1210-C.html · www.revisor.mn.gov/…/325G.57 · www.nysenate.gov/…/527-A · law.lis.virginia.gov/…/section59.1-207.46
|
High
consent moment absence |
automatic
proximityToConsentAction renewalTermsProminence renewalTextOnlyInLinkedTermsIncludes a signal from the visual pass, which caps this check at medium severity. |
| Renewal text was found on the page, but its type size or its distance from the price and consent control was outside the thresholds this scanner checks.
The "clear and conspicuous" standard in these frameworks is summarized as reaching the legibility and placement of the disclosure, including its type size and its proximity to the price and the consent control.
ARL-DISCLOSURE-PRESENTATION
Rule summary last reviewed: 2026-08-03
Due again 2026-11-01.
Drafted from 3 sources:
leginfo.legislature.ca.gov/…/codes_displayText.xhtml · www.revisor.mn.gov/…/325G.57 · www.nysenate.gov/…/527-A
|
Medium
tool chosen threshold |
automatic
disclosureFontSize priceAndIntervalNearCTA renewalTextOnPage |
| Trial or promotional pricing was detected without accompanying visible text describing the charge that follows it.
These frameworks are summarized as covering offers that begin free or discounted and convert to a paid term, with the terms of that conversion disclosed before the consumer agrees.
ARL-TRIAL-CONVERSION
Rule summary last reviewed: 2026-08-03
Due again 2026-11-01.
|
High
consent moment absence |
automatic
trialConversionTerms trialLanguage |
| No link or control matching an online cancellation route was found on the pages this scan could reach.
These frameworks are summarized as requiring a subscription entered into online to be cancellable through the same online medium, without additional obstruction.
ARL-CANCEL-ONLINE-ROUTE
Rule summary last reviewed: 2026-08-03
Due again 2026-11-01.
Drafted from 9 sources:
leginfo.legislature.ca.gov/…/codes_displayText.xhtml · content.leg.colorado.gov/…/2025a_sl_368.pdf · www.cga.ct.gov/…/chap_742d.htm · www.ilga.gov/…/Articles · www.mass.gov/…/940-CMR-3800-unfair-and-dece · legislature.maine.gov/…/title10sec1210-C.html · www.revisor.mn.gov/…/325G.57 · www.nysenate.gov/…/527-A · law.lis.virginia.gov/…/section59.1-207.46
|
Medium
non appearance |
automatic
onlineCancelPath |
| The fetched terms text describes cancelling by telephone.
Where a subscription was entered into online, these frameworks are summarized as requiring an online route to cancel, so a route available only by telephone is described as not meeting that requirement on its own.
ARL-CANCEL-TELEPHONE-ONLY
Rule summary last reviewed: 2026-08-03
Due again 2026-11-01.
Drafted from 9 sources:
leginfo.legislature.ca.gov/…/codes_displayText.xhtml · content.leg.colorado.gov/…/2025a_sl_368.pdf · www.cga.ct.gov/…/chap_742d.htm · www.ilga.gov/…/Articles · www.mass.gov/…/940-CMR-3800-unfair-and-dece · legislature.maine.gov/…/title10sec1210-C.html · www.revisor.mn.gov/…/325G.57 · www.nysenate.gov/…/527-A · law.lis.virginia.gov/…/section59.1-207.46
|
High
consent moment absence |
automatic
phoneOnlyCancel |
| Not observable from outside the signup flow.
A post-transaction acknowledgment is summarized as needing to include the renewal terms and cancellation instructions in a form the consumer can retain.
ARL-POST-TRANSACTION-ACK
Rule summary last reviewed: 2026-08-03
Due again 2026-11-01.
|
Manual check
outside flow |
manual verification only
No signal can reach this. It is listed in every report and never counted as a finding. |
| Not observable from a checkout flow.
These frameworks are summarized as requiring notice ahead of a renewal in defined circumstances — in Virginia, where a renewal term runs longer than 30 days and extends the contract beyond 12 months.
ARL-RENEWAL-NOTICE
Rule summary last reviewed: 2026-08-03
Due again 2026-11-01.
Drafted from 10 sources:
www.cga.ct.gov/…/chap_742d.htm · code.dccouncil.gov/…/2 · delcode.delaware.gov/…/index.html · data.capitol.hawaii.gov/…/HRS_0481-0009_0005.htm · www.ilga.gov/…/Articles · www.mass.gov/…/940-CMR-3800-unfair-and-dece · ndlegis.gov/…/t51c37.pdf · www.nysenate.gov/…/527-A · law.lis.virginia.gov/…/section59.1-207.46 · legislature.vermont.gov/…/02454a
|
Manual check
outside flow |
manual verification only
No signal can reach this. It is listed in every report and never counted as a finding. |
North Dakota
- Statute
- N.D. Cent. Code ch. 51-37, §§51-37-01 to 51-37-06.
- Effective
- The source consulted carries no source notes and states no effective date. [medium confidence — flagged for counsel]
- Applies to
- Persons selling merchandise or a service for a specified period under a written agreement containing an automatic-renewal provision. Insurance, regulated utilities and financial institutions are described as excluded.
- Scope limit
- This framework is summarized as reaching contracts above a term threshold rather than every subscription, so an ordinary month-to-month plan may sit outside it. Only the checks that concern longer contracts relate to it here. This chapter is described as defining automatic renewal as renewal for a period of more than one month, which places month-to-month subscriptions outside it.
| Check | Severity | Detected by |
|---|---|---|
| Not observable from outside the signup flow.
A post-transaction acknowledgment is summarized as needing to include the renewal terms and cancellation instructions in a form the consumer can retain.
ARL-POST-TRANSACTION-ACK
Rule summary last reviewed: 2026-08-03
Due again 2026-11-01.
|
Manual check
outside flow |
manual verification only
No signal can reach this. It is listed in every report and never counted as a finding. |
| Not observable from a checkout flow.
These frameworks are summarized as requiring notice ahead of a renewal in defined circumstances — in Virginia, where a renewal term runs longer than 30 days and extends the contract beyond 12 months.
ARL-RENEWAL-NOTICE
Rule summary last reviewed: 2026-08-03
Due again 2026-11-01.
Drafted from 10 sources:
www.cga.ct.gov/…/chap_742d.htm · code.dccouncil.gov/…/2 · delcode.delaware.gov/…/index.html · data.capitol.hawaii.gov/…/HRS_0481-0009_0005.htm · www.ilga.gov/…/Articles · www.mass.gov/…/940-CMR-3800-unfair-and-dece · ndlegis.gov/…/t51c37.pdf · www.nysenate.gov/…/527-A · law.lis.virginia.gov/…/section59.1-207.46 · legislature.vermont.gov/…/02454a
|
Manual check
outside flow |
manual verification only
No signal can reach this. It is listed in every report and never counted as a finding. |
Vermont
- Statute
- 9 V.S.A. §2454a.
- Effective
- The section carries a credit line giving an effective date of July 1, 2019, with a later amendment.
- Applies to
- Sellers and lessors under a consumer contract whose initial term is one year or longer and that renews for a subsequent term longer than one month. Financial institutions, credit unions and insurance contracts are described as excluded.
- Scope limit
- This framework is summarized as reaching contracts above a term threshold rather than every subscription, so an ordinary month-to-month plan may sit outside it. Only the checks that concern longer contracts relate to it here. This section is described as reaching only contracts with an initial term of a year or longer, which places an ordinary monthly subscription outside it.
| Check | Severity | Detected by |
|---|---|---|
| Not observable from a checkout flow.
These frameworks are summarized as requiring notice ahead of a renewal in defined circumstances — in Virginia, where a renewal term runs longer than 30 days and extends the contract beyond 12 months.
ARL-RENEWAL-NOTICE
Rule summary last reviewed: 2026-08-03
Due again 2026-11-01.
Drafted from 10 sources:
www.cga.ct.gov/…/chap_742d.htm · code.dccouncil.gov/…/2 · delcode.delaware.gov/…/index.html · data.capitol.hawaii.gov/…/HRS_0481-0009_0005.htm · www.ilga.gov/…/Articles · www.mass.gov/…/940-CMR-3800-unfair-and-dece · ndlegis.gov/…/t51c37.pdf · www.nysenate.gov/…/527-A · law.lis.virginia.gov/…/section59.1-207.46 · legislature.vermont.gov/…/02454a
|
Manual check
outside flow |
manual verification only
No signal can reach this. It is listed in every report and never counted as a finding. |
Virginia
- Statute
- Va. Code §59.1-207.46, in Title 59.1, ch. 17.8 (§§59.1-207.45 to 59.1-207.49).
- Effective
- The section carries a history line running 2018, 2022, 2023, 2024 and 2026. The 2026 chapters may have changed the operative duties. [low confidence — flagged for counsel]
- Applies to
- Any seller making an automatic-renewal or continuous-service offer to a consumer in the Commonwealth. A general consumer framework; discrete exemptions sit in §59.1-207.48.
| Check | Severity | Detected by |
|---|---|---|
| Automatic-renewal terms were not detected in the visible text presented alongside the consent action.
These frameworks are summarized as requiring the automatic-renewal terms to be presented clearly and conspicuously before the consumer agrees, in visual proximity to the request for consent.
ARL-DISCLOSURE-AT-CONSENT
Rule summary last reviewed: 2026-08-03
Due again 2026-11-01.
Drafted from 9 sources:
leginfo.legislature.ca.gov/…/codes_displayText.xhtml · content.leg.colorado.gov/…/2025a_sl_368.pdf · www.cga.ct.gov/…/chap_742d.htm · www.ilga.gov/…/Articles · www.mass.gov/…/940-CMR-3800-unfair-and-dece · legislature.maine.gov/…/title10sec1210-C.html · www.revisor.mn.gov/…/325G.57 · www.nysenate.gov/…/527-A · law.lis.virginia.gov/…/section59.1-207.46
|
High
consent moment absence |
automatic
proximityToConsentAction renewalTermsProminence renewalTextOnlyInLinkedTermsIncludes a signal from the visual pass, which caps this check at medium severity. |
| No link or control matching an online cancellation route was found on the pages this scan could reach.
These frameworks are summarized as requiring a subscription entered into online to be cancellable through the same online medium, without additional obstruction.
ARL-CANCEL-ONLINE-ROUTE
Rule summary last reviewed: 2026-08-03
Due again 2026-11-01.
Drafted from 9 sources:
leginfo.legislature.ca.gov/…/codes_displayText.xhtml · content.leg.colorado.gov/…/2025a_sl_368.pdf · www.cga.ct.gov/…/chap_742d.htm · www.ilga.gov/…/Articles · www.mass.gov/…/940-CMR-3800-unfair-and-dece · legislature.maine.gov/…/title10sec1210-C.html · www.revisor.mn.gov/…/325G.57 · www.nysenate.gov/…/527-A · law.lis.virginia.gov/…/section59.1-207.46
|
Medium
non appearance |
automatic
onlineCancelPath |
| The fetched terms text describes cancelling by telephone.
Where a subscription was entered into online, these frameworks are summarized as requiring an online route to cancel, so a route available only by telephone is described as not meeting that requirement on its own.
ARL-CANCEL-TELEPHONE-ONLY
Rule summary last reviewed: 2026-08-03
Due again 2026-11-01.
Drafted from 9 sources:
leginfo.legislature.ca.gov/…/codes_displayText.xhtml · content.leg.colorado.gov/…/2025a_sl_368.pdf · www.cga.ct.gov/…/chap_742d.htm · www.ilga.gov/…/Articles · www.mass.gov/…/940-CMR-3800-unfair-and-dece · legislature.maine.gov/…/title10sec1210-C.html · www.revisor.mn.gov/…/325G.57 · www.nysenate.gov/…/527-A · law.lis.virginia.gov/…/section59.1-207.46
|
High
consent moment absence |
automatic
phoneOnlyCancel |
| Not observable from outside the signup flow.
A post-transaction acknowledgment is summarized as needing to include the renewal terms and cancellation instructions in a form the consumer can retain.
ARL-POST-TRANSACTION-ACK
Rule summary last reviewed: 2026-08-03
Due again 2026-11-01.
|
Manual check
outside flow |
manual verification only
No signal can reach this. It is listed in every report and never counted as a finding. |
| Not observable from a checkout flow.
These frameworks are summarized as requiring notice ahead of a renewal in defined circumstances — in Virginia, where a renewal term runs longer than 30 days and extends the contract beyond 12 months.
ARL-RENEWAL-NOTICE
Rule summary last reviewed: 2026-08-03
Due again 2026-11-01.
Drafted from 10 sources:
www.cga.ct.gov/…/chap_742d.htm · code.dccouncil.gov/…/2 · delcode.delaware.gov/…/index.html · data.capitol.hawaii.gov/…/HRS_0481-0009_0005.htm · www.ilga.gov/…/Articles · www.mass.gov/…/940-CMR-3800-unfair-and-dece · ndlegis.gov/…/t51c37.pdf · www.nysenate.gov/…/527-A · law.lis.virginia.gov/…/section59.1-207.46 · legislature.vermont.gov/…/02454a
|
Manual check
outside flow |
manual verification only
No signal can reach this. It is listed in every report and never counted as a finding. |
Tracked for legislative change — informational only
These jurisdictions are tracked so a scan can be re-run if something takes effect. They carry no rules in the matrix, so they cannot produce a finding: there is nothing in force for a finding to relate to.
- Michigan
bill live
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. [medium confidence — flagged for counsel]
- Pennsylvania
bills live
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
no framework, nothing pending
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.
Enacted, but in force on a date this tool could not confirm
These carry no rules, so no finding can cite them. They are listed rather than dropped, because a reader scoping a scan to one of them should be able to see that it is tracked and that nothing is being reported for it.
- Georgia
in force unconfirmed
Georgia is reported to have two automatic-renewal frameworks already in force: a service-contract provision at O.C.G.A. §§13-12-1 to 13-12-5, and the Georgia Online Automatic Renewal Transparency Act at O.C.G.A. §10-1-439.5 et seq., described as effective January 1, 2024 and as covering online offers, offer-term disclosure, affirmative consent, acknowledgment and online cancellation. [low confidence — flagged for counsel]The online framework is described as effective January 1, 2024. This tool could not confirm that against an official code page. [low confidence — flagged for counsel]
- Maryland
in force unconfirmed
Md. Code, Com. Law §14-1329.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. [low confidence — flagged for counsel]
Sector-specific — listed for context, never scanned against
These jurisdictions have real automatic-renewal provisions that do not reach a general online subscription checkout — they are limited to health clubs, alarm contracts, telecoms, buyers' clubs or business-to-business contracts. No rule relates to them, because a finding citing one against an ordinary subscription flow would not be defensible.
- Utah
Utah Code §§15-10-201 and 15-10-202, within the Service Contracts Act at Title 15, ch. 10.
Checkout health — a separate category
Alongside the legal observations, every walk records whether the checkout was mechanically working that day. These checks carry no statute references and no state names — they describe the checkout as a mechanism, not anything about a legal framework — and their reports use their own status words (issue observed, nothing observed, could not be determined) rather than the severity levels above.
The signals are gathered during every walk at no extra request. Every report shows the real count of issues observed; the itemised detail is included with the paid monitoring plans, and on any scan — scheduled or manual — of a domain covered by a monitor. The same three-valued logic applies: a walk that never reached the consent step reports mobile rendering as could-not-be-determined, never as passing.
| Check | What it observes |
|---|---|
Console errors
console-errorsDescription last reviewed:
2026-08-05
Due again 2026-11-03. |
A JavaScript error or uncaught exception fired on a step the walk loaded.
Whether the checkout’s own code is erroring for a customer arriving today — the kind of defect that silently drops conversions. |
Failed network requests
failed-requestsDescription last reviewed:
2026-08-05
Due again 2026-11-03. |
A request during the walk answered 4xx or 5xx, or never completed.
Whether the resources and calls the checkout depends on are answering. |
Broken links to terms and cancellation documents
linked-documentsDescription last reviewed:
2026-08-05
Due again 2026-11-03. |
A linked terms, refund or cancellation document did not answer with a readable page.
Whether the documents the checkout points customers at actually resolve — a 404 on a linked Terms page is a real defect whatever else is true. |
Dead-end call-to-action
dead-end-ctaDescription last reviewed:
2026-08-05
Due again 2026-11-03. |
The primary plan call-to-action was clicked and the page did not change, or the click errored.
Whether the button a customer must press to buy actually leads anywhere. |
Price mismatch between plans page and consent step
price-mismatchDescription last reviewed:
2026-08-05
Due again 2026-11-03. |
The price-with-interval shown at the consent step never appeared on the earlier steps.
Whether the amount a customer agreed to at the end is the amount they were shown when they chose. |
Mobile consent rendering
mobile-consentDescription last reviewed:
2026-08-05
Due again 2026-11-03. |
At 390px wide, the consent control or the submit control did not fit without horizontal scroll.
Whether a customer on a phone can reach the consent moment without scrolling sideways — the majority of checkout traffic renders at widths like this. |
How each one is computed, and its known failure modes, is on the methodology page.
The signals
Every check above is built from these. The deterministic pass is ordinary code running over captured text and geometry. The visual pass is a model describing a screenshot; it is prompted to describe rather than judge, and any check that depends on it is capped at medium severity.
| Signal | Pass | What it means |
|---|---|---|
subscriptionFlowReached | deterministic | At least one captured step showed something that only a subscription signup flow has. |
renewalTextOnPage | deterministic | Wording matching the renewal pattern was found in the visible text of the step carrying the consent control. |
renewalTextInLinkedTerms | deterministic | Wording matching the renewal pattern was found in the text of a terms page the scan fetched. |
renewalTextOnlyInLinkedTerms | deterministic | Renewal wording was absent from the consent step but present in a linked terms document. |
separateConsentCheckbox | deterministic | A checkbox exists whose label references the renewal terms distinctly from a terms-of-service or privacy-policy checkbox. |
prechecked | deterministic | At least one checkbox was already ticked when its page loaded. Hidden checkboxes count, because a hidden ticked box still governs consent. |
priceAndIntervalNearCTA | deterministic | Text combining a price and a billing interval was found within 400px of a submit control. |
trialLanguage | deterministic | Trial or promotional-offer wording was found in the captured page text. |
trialConversionTerms | deterministic | Wording describing what is charged when a trial or promotional period ends was found in the captured page text. |
trialConversionInLinkedTermsOnly | deterministic | Conversion wording was absent from the pages but present in a fetched terms document. |
disclosureFontSize | deterministic | The computed font size, in pixels, of the smallest visible element whose text matches the renewal pattern. 12px is the threshold this tool checks against; no statute in the matrix states a pixel size. |
onlineCancelPath | deterministic | A link or control label matching an online cancellation route was found on a captured page or in fetched terms. |
phoneOnlyCancel | deterministic | Fetched terms text describes cancelling by telephone. |
renewalTermsVisible | visual | The screenshot review reported whether renewal terms are visible on the consent screen. |
renewalTermsProminence | visual | The screenshot review described the renewal terms as prominent, present but subdued, or absent. |
proximityToConsentAction | visual | The screenshot review described how close the renewal terms are to the consent control: adjacent, on the same screen, requiring a scroll, or not present. |
consentMechanism | visual | The screenshot review described the visible consent control as dedicated to renewal, bundled with general terms, or not visible. |
How the scan produces these signals · What none of these checks can see