Subscriptions Renewal Transparency Act

Summary#

This bill would set new rules for contracts that automatically renew or convert a free trial into a paid subscription. It requires clear disclosure, regular notice, and explicit consumer consent before charging. It also bars consent gained through “dark patterns” (manipulative user interfaces) and lets the Federal Trade Commission (FTC) enforce the rules.

• Main change: Sellers must give clear notice of automatic renewals and free-to-pay conversions, provide an easy cancellation method, and get annual express informed consent before charging.
• Notice timing: At least 7 days (or longer if the FTC decides) before a renewal or before a free trial ends.
• Non-use rule: If a consumer hasn’t used a service for 6 months, the seller must get fresh consent before charging and offer a prorated refund option.
• Enforcement: Violations void the automatic renewal and require refunds; the FTC enforces the law and must write rules to implement it.
• Effective date: The rules start 1 year after the law is enacted.

What it means for you#

• Consumers

  • You should get clear warnings before a trial ends or a subscription renews.
  • You must be given a simple online way to cancel and at least one other easy option (toll-free number, email, or mail).
  • If you stop using a service for 6 months, the company must ask you to agree again before charging and tell you about prorated refunds.
  • Consent given through manipulative website or app designs (dark patterns) will not count.

• Businesses that sell subscriptions or offer free trials

  • You must add clear disclosures in contracts and change billing systems to send renewal and trial-end notices.
  • You must provide an easy online cancellation tool and another easy contact method.
  • You must obtain annual express informed consent to renew subscriptions and track customer use to detect 6-month non-use.
  • If you violate the rules, automatic renewal terms are void and you must refund affected consumers.

• Companies selling “service contracts” for repairs or similar services

  • These contracts are exempt from the main requirements unless the FTC specifically decides otherwise.

• FTC / regulators

  • The FTC will write detailed rules, enforce the law, and treat violations as unfair or deceptive practices under its existing authority.

Expenses#

No publicly available information.

• Possible business costs (inferred from the bill): updating websites and contracts, building or maintaining online cancellation and notice systems, customer service staffing (toll-free lines), and tracking consumer usage.
• Possible government costs (inferred): FTC rulemaking and enforcement effort, though no estimate is provided in the bill text.
• Possible financial impact on sellers: refunds and lost renewal revenue if consumers opt out or if renewals are voided for violations.

Proponents' View#

• The bill appears intended to stop surprise charges and make subscription terms clearer.
• Supporters may argue it gives consumers greater control by requiring clear notice and easy cancellation.
• It could reduce manipulative website designs by excluding “dark patterns” from valid consent.
• The annual consent and non-use protections could prevent long-running unwanted charges.
• Treating violations as unfair or deceptive practice gives the FTC a known enforcement path.

Opponents' View#

• One concern is increased compliance costs and technical work for businesses, especially small companies.
• The bill does not define “express informed consent” in detail; that could create uncertainty until the FTC issues rules.
• The FTC’s discretion to set longer notice periods and to exempt classes of contracts may create regulatory uncertainty.
• Voiding automatic renewal provisions and requiring full refunds for violations could be a heavy penalty for minor or accidental errors.
• It is unclear how some rules will apply where the consumer entered the contract offline or in mixed ways, since notices must be given “in the same manner” as entry.