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State law matrix - May 2026

State Auto-Renewal Laws for Streaming Subscriptions in 2026

With the FTC Click to Cancel rule in procedural limbo, state auto-renewal laws are the binding constraint on streaming cancel-flow design. California, New York and Vermont are the strongest. Here is the per-state matrix plus enforcement examples.

State law summary

StateStatuteKey requirements
CaliforniaBus & Prof Code § 17602 + SB-313 (2024)Clear disclosure, affirmative consent, online cancel, annual reminder
New YorkGBL § 527-a (2021)Explicit consent, online cancel matching signup mechanism
Vermont9 V.S.A. § 2454a (2019)Disclosure, consent, cancel without speaking to representative
IllinoisAutomatic Contract Renewal Act (2011)Disclosure of auto-renewal at signup
ConnecticutGen Stat § 42-126bCancellation no more burdensome than signup
OregonORS 646A.293 (2019)Online cancel, disclosure
FloridaHB-457 (introduced 2025, not enacted)Pending; not yet effective
TexasNo specific auto-renewal lawRelies on federal FTC enforcement

Why state law matters more than ever

The FTC's federal Click to Cancel Rule was vacated in part by the 5th Circuit in July 2025, leaving federal-level streaming cancel-flow requirements in procedural limbo. State auto-renewal laws fill that gap. As of May 2026, more than a dozen US states have their own auto-renewal statutes with varying strength. The most stringent are California, New York and Vermont. The states without specific auto-renewal laws rely on general consumer-protection statutes and the federal FTC Act Section 5 enforcement.

For a streaming consumer, the practical implication is that your legal protections depend significantly on where you live. A California resident has substantially more enforceable rights against deceptive auto-renewal than a Texas resident. A New York resident can rely on the New York Attorney General's track record of consumer-protection enforcement. A Florida resident relies on federal FTC enforcement and the streaming services' own commercial reasons for compliance. Coverage of the federal FTC situation is on the FTC Click to Cancel streaming page.

California: the most consumer-protective state

California's Auto-Renewal Law (Business and Professions Code Section 17602, often shorthanded as the ARL) was originally enacted in 2010. The 2024 amendments via Senate Bill 313 (SB-313) substantially strengthened the law and made it the most consumer-protective auto-renewal statute in the United States. The current California ARL requires: clear-and-conspicuous disclosure of all auto-renewal terms at signup; affirmative consent before billing the negative-option features (the consumer must take a specific action acknowledging the auto-renewal, not merely a continued-use implication); annual reminder notices for subscriptions that have been active for 12 months or more; and online cancellation through the same medium as signup with comparable simplicity.

SB-313 also added explicit civil penalties for violations: up to $2,500 per violation under the Unfair Competition Law, or up to $10,000 per willful violation. The California Attorney General can bring enforcement actions, and private parties can bring class-action lawsuits under the ARL. The full text of the current ARL is available at leginfo.legislature.ca.gov.

California enforcement examples

The most prominent recent enforcement was the California Attorney General's $3.8 million settlement with Sirius XM in 2023 over auto-renewal disclosure violations. While Sirius XM is satellite radio rather than streaming video, the settlement is illustrative of the enforcement posture and the specific compliance issues (disclosure clarity, cancellation flow, consent capture) that apply equally to streaming services. Coverage of the Sirius XM settlement is publicly available through California Attorney General press releases at oag.ca.gov.

Class-action lawsuits under California ARL have been filed against multiple streaming services. The plaintiffs typically allege that the signup flow did not provide adequate disclosure of the auto-renewal terms or that cancellation was made unreasonably difficult. Several have settled in the multi-million-dollar range. Streaming services have responded by simplifying signup flow disclosures and cancellation paths, which is the primary reason most major US streamers have clean cancel flows in 2026 even with the federal FTC rule in limbo.

New York General Business Law Section 527-a

New York's General Business Law Section 527-a took effect February 2021. The requirements are similar to California's ARL: clear-and-conspicuous disclosure of auto-renewal terms, affirmative consent before automatic charging, and online cancellation through the same mechanism as signup. The specific language requires that "any business that sells products or services to consumers in this state through an automatic renewal program shall provide an option for the consumer to cancel the subscription online".

The New York Attorney General has enforced GBL Section 527-a against various subscription businesses. The full statute is available at nysenate.gov. For New York residents, complaints about streaming auto-renewal practices should be filed with the Attorney General's Bureau of Consumer Frauds and Protection at ag.ny.gov.

Vermont and the cancel-without-speaking-to-representative requirement

Vermont's 9 V.S.A. Section 2454a, effective 2019, has a specific provision that is unusual in US law: cancellation must be possible without speaking to a customer service representative. This addresses the cable-industry pattern (still applied in some sectors) of requiring a phone call to a "retention specialist" who attempts to dissuade cancellation. Vermont's law explicitly prohibits this pattern. The full statute is at legislature.vermont.gov.

For streaming services, this provision is generally compliant by default because online cancellation through a website or app does not require speaking to a representative. The Vermont law is more impactful for sectors (cable, gym memberships, magazine subscriptions) that historically used phone-based retention flows. For streaming consumers in Vermont, the law provides strong backup if a service ever tries to route cancellation through a phone call.

Other state laws worth knowing

Illinois: The Automatic Contract Renewal Act (enacted 2011, effective 2012) requires disclosure of auto-renewal terms at signup. Illinois's law is less detailed than California, New York or Vermont but provides a baseline consumer protection.

Connecticut: General Statutes Section 42-126b requires that cancellation be "no more burdensome than" the signup mechanism. Similar in spirit to the FTC Click to Cancel rule.

Oregon: ORS 646A.293 (2019) requires online cancellation for subscriptions sold online and clear disclosure of auto-renewal terms. Notable for being one of the most explicit online-cancellation requirements outside California.

Massachusetts, New Jersey, Hawaii, Maryland, Washington DC: Each has consumer-protection statutes that include some level of auto-renewal disclosure requirements, though typically less detailed than the California-New York-Vermont tier.

Florida: HB-457 was introduced in the 2025 legislative session to create a Florida auto-renewal law. As of May 2026 the bill has not been enacted. Florida residents currently rely on federal FTC enforcement.

Texas: No specific auto-renewal statute. Texas consumers rely on the Texas Deceptive Trade Practices Act for general consumer protection and on federal FTC enforcement.

Choice-of-law and forum-selection clauses

Streaming services' terms of service typically include a choice-of-law clause specifying which state's law governs disputes (often California because most major streamers are California-based) and a forum-selection clause requiring arbitration or specific court jurisdiction. These clauses generally do not override state auto-renewal laws because consumer-protection statutes are typically held to be public policy that cannot be contractually waived.

Most state auto-renewal laws explicitly state that they cannot be waived by contract. California's ARL contains language to this effect. New York's GBL Section 527-a similarly cannot be waived. The practical implication: a streaming service's terms cannot legally require you to give up your state-law consumer protections by clicking "I agree" at signup.

Filing a state-law complaint

The complaint pathway varies by state. In California, file with the Attorney General's Public Inquiry Unit at oag.ca.gov. In New York, file with the Attorney General's Bureau of Consumer Frauds at ag.ny.gov. In Vermont, file with the Consumer Assistance Program at ago.vermont.gov. Most state attorneys general have online complaint forms specifically for consumer-protection complaints.

For maximum impact, file with multiple authorities in parallel: state attorney general, federal FTC (reportfraud.ftc.gov), and the Better Business Bureau (which does not have enforcement power but maintains public records). Also pursue private remedies (refund request to the streaming service, chargeback with card issuer) in parallel. The combined documentation and pressure typically resolves individual disputes faster than waiting for any single authority to act. Coverage of the broader complaint pathway is on the CFPB streaming billing disputes page.

Class actions as the systemic remedy

Individual auto-renewal disputes typically involve small dollar amounts (one or two months of streaming charges). The economics do not support individual litigation. Class-action lawsuits aggregate the claims across thousands or millions of consumers and have been the primary mechanism for systemic enforcement of state auto-renewal laws against streaming services. Several major streamers have settled class actions in recent years for amounts ranging from low single-digit millions to substantially more.

Class actions typically resolve through settlement rather than trial. The settlements include monetary compensation to class members (typically nominal per-person amounts after legal fees), required changes to the streaming service's signup and cancel flows, and ongoing monitoring requirements. The cumulative effect of these settlements has been to standardise cancel flows across major US streamers at roughly the requirements of California's ARL, which is why most major services have similar cancel flows regardless of where the consumer resides.

Frequently asked questions

Do I need to live in California to use California's ARL?
You need to be a California resident for the California Attorney General to enforce on your behalf. The law applies to subscriptions sold to California residents. For non-California residents, file with your home state's attorney general using your state's law.
Does the law apply if I signed up while in California but moved away?
Generally the law of your current residence applies for ongoing protection. The law of California applies for the signup-disclosure moment. Practically, file with whichever state's law is most consumer-protective.
Can a streaming service charge me extra to use ARL-required features like online cancel?
No. The state laws explicitly require that the consumer-protective features be free. A streaming service cannot charge for the ability to cancel online or for the annual reminder notice.
What about the 5th Circuit decision: does it affect state laws?
No. The 5th Circuit vacated the federal FTC Click to Cancel rule. State auto-renewal laws are separate statutes enacted by state legislatures and are not affected by the federal court decision.

Related guides

State auto-renewal law status verified as of May 2026. State legislation can change with each annual legislative session; verify your specific state's current law before relying on it for a dispute. This page is informational, not legal advice.

Updated 2026-05-11