Unlawful Auto-Renewal Subscription Refund Demand Generator (ARL & ROSCA)
Generate a statutory refund demand when a SaaS app, streaming service, or membership auto-renewed you without mandatory reminder notices or 1-click cancellation.
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3. How the rule works
Who this is for
Subscribers charged for an automatic renewal they did not expect, especially an annual renewal, who want to ask for a refund citing the right statute.
It focuses on California's Automatic Renewal Law, New York's equivalent and the federal ROSCA.
What to have ready
- The sign-up confirmation and the date you subscribed.
- The renewal charge on your statement.
- A search of your inbox and spam folder for any reminder.
- Screenshots of the cancellation process if it was hard to find.
The rule
California's Automatic Renewal Law (Business and Professions Code §§ 17600–17606) requires businesses to disclose auto-renewal terms clearly before purchase, get affirmative consent, send an acknowledgement explaining how to cancel, and let consumers who signed up online cancel online. For renewals of a year or longer, the business must send a reminder 15 to 45 days before the renewal. Amendments in force from July 1, 2025 add requirements such as annual reminders and limits on retention offers. Under § 17603, goods or services provided without meeting these requirements are treated as an unconditional gift.
New York General Business Law § 527-a has similar disclosure, consent and online cancellation rules. The federal Restore Online Shoppers' Confidence Act, 15 U.S.C. § 8403, requires clear disclosure, express informed consent and a simple cancellation method for online negative-option subscriptions. The FTC's 2024 'click-to-cancel' rule was vacated by a federal appeals court in July 2025, so ROSCA and state laws remain the main rules.
Read the official text:
- California Business and Professions Code § 17602
- California Business and Professions Code § 17603
- New York General Business Law § 527-a
- 15 U.S.C. § 8403 (ROSCA)
Worked example: a $299 annual renewal
A Californian signed up online for a $299 annual software plan. It renewed on March 1 with no reminder email.
Reminder window for annual renewal = Jan 15 to Feb 14 (45 to 15 days before) Reminder received = none (search inbox and spam) Online cancellation available = required for online sign-ups Demand = full $299 refund, citing §§ 17602, 17603 If refused = card dispute and complaint to the state AG
Common mistakes
- Not checking spam folders before claiming no reminder was sent.
- Citing California law for a subscription bought in another state with no California connection.
- Cancelling without asking for the refund in the same message.
- Relying on the FTC click-to-cancel rule, which is not in force.
Limits of this tool
- Auto-renewal laws vary by state; many states have them, with different reminder windows.
- App store subscriptions may have to be cancelled and refunded through the store.
- The letter cannot force a refund; it puts the legal basis in writing.
Sources were last checked in October 2026. Statutes are amended often; if the official text differs from this page, the official text controls.
4. Clear Next Steps & Statutory Action Plan
- Find the sign-up confirmation and check for any reminder before the renewal.
- Cancel the subscription and request a refund in writing, citing the statute.
- If refused, dispute the charge with your card issuer within its time limits.
5. Frequently Asked Statutory Questions (Cal. Bus. & Prof. Code § 17602 (California ARL); N.Y. Gen. Bus. Law § 527-a; 15 U.S.C. § 8403 (ROSCA))
Must a company remind me before an annual renewal?
In California, yes, 15 to 45 days before a renewal of a term of one year or longer. Several other states have similar rules.
What does 'unconditional gift' mean?
Under § 17603, if a business sends goods or provides services under an auto-renewal without complying with the law, the consumer can keep them without paying, which supports a refund request.
Is the FTC click-to-cancel rule in effect?
No. The Eighth Circuit vacated it in July 2025. ROSCA and state laws still require simple cancellation for many online subscriptions.
What counts as clear disclosure before I subscribe?
California's law requires the auto-renewal terms to be presented clearly and conspicuously, close to the request for consent, including that the plan continues until cancelled, how to cancel, the amount charged and how often, and any minimum term. A line buried in the terms of service is unlikely to be enough.
Is a free trial that converts to a paid plan covered?
Yes. A free trial that rolls into a paid subscription is a type of automatic renewal or continuous service offer, and California requires disclosure of how to cancel before the trial ends and, for longer trials, a notice before the first charge.
Does this apply to app store subscriptions?
Apple and Google handle billing for many app subscriptions, so cancellation and refund requests usually go through the store. The developer may still be bound by auto-renewal disclosure laws.