Subscription auto-renewal terms and online cancellation: what ROSCA and California's law ask of your checkout

Updated Oct 27, 2026 · Pewterkit Guides

If your app sells a subscription that renews automatically, US federal law (ROSCA) asks you to show the key terms before you take card details, get express consent, and give a simple way to stop the charges. California's automatic renewal law adds that the terms sit close to the consent, and that people who signed up online can cancel online. In practice: one short renewal line next to your subscribe button, and a "Cancel subscription" path in the account area.

What ROSCA asks

The Restore Online Shoppers' Confidence Act (15 U.S.C. section 8403) covers online sales with a negative option feature, such as a subscription that renews unless the customer cancels. The seller must:

  1. provide text that "clearly and conspicuously discloses all material terms of the transaction" before obtaining billing information;
  2. obtain "express informed consent" before charging; and
  3. provide "simple mechanisms for a consumer to stop recurring charges".

What California's automatic renewal law adds

California Business and Professions Code section 17602, as amended by AB 2863 for agreements made, amended or extended on or after July 1, 2025:

  • Terms near the consent. Renewal terms must be presented "in a clear and conspicuous manner before the subscription or purchasing agreement is fulfilled" and in visual proximity to the request for consent.
  • Affirmative consent to the agreement containing the renewal terms before you charge.
  • An acknowledgment the customer can keep (an email works) with the terms, the cancellation policy and how to cancel.
  • Cancel online. Someone who signed up online can cancel "exclusively online, at will", through "a prominently located direct link or button" or an immediately accessible termination email.
  • Retention offers. If you show a save offer during cancellation, a link or button "entitled 'click to cancel'" has to appear alongside it.

Template: the renewal line by the subscribe button

[Plan name]: [price] per [month/year]. Renews automatically every
[month/year] until you cancel. Cancel anytime in Account > Billing;
your access continues to the end of the paid period.
[ ] I agree to the renewal terms above.        [ Subscribe ]

Put the real price and period from your pricing page into the line, directly above or beside the button, in normal-size text.

Template: the online cancel path

  • A "Manage subscription" or "Cancel subscription" link in your account or settings page.
  • With Stripe, the hosted customer portal (on billing.stripe.com) lets customers "cancel subscriptions immediately or at the end of the current billing period"; switch it on in the Dashboard and link to it from that page.
  • A confirmation email after cancellation stating the end date.

These are plain-English starting points you can adapt; for anything specific to your business, a lawyer's quick review is worth it.

What Pewterkit Check looks for

A free check reads your public pages and scripts for subscription signs (Stripe subscription mode, "/mo", "per month", "billed annually", "free trial", "renews"). It then looks for the renewal terms (price, how often, how to cancel) on the pricing or checkout page and for an online cancel path such as a Stripe customer portal link, /billing, /account or "Cancel subscription" in your app code.

FAQ

Does California's law apply if my company isn't in California?

It is written to protect California consumers, so if Californians can subscribe, plan for it. The same setup also covers ROSCA's federal requirements.

Is a link to my terms of service enough?

ROSCA asks for clear and conspicuous disclosure of material terms before billing details, and California asks for them in visual proximity to the consent. A one-line summary next to the button, with the full terms linked, does both.

Can I show a discount when someone tries to cancel?

California's law allows a retention offer during online cancellation when a "click to cancel" link or button is shown alongside it.

What counts as a simple way to cancel?

A cancel button or link in the account area that works online, without a phone call or chat. California names "a prominently located direct link or button" or an immediately accessible termination email.

Sources

  1. 15 U.S.C. section 8403, negative option marketing on the Internet (govinfo, U.S. Government Publishing Office) — read 27 Oct 2026: ROSCA's three requirements
  2. Cal. Bus. & Prof. Code section 17602, 2025 California Code (Justia) — read 27 Oct 2026: clear and conspicuous terms, consent, acknowledgment, online cancellation, "click to cancel", July 1, 2025 application
  3. Stripe: Provide a customer portal to your customers — read 27 Oct 2026: customers cancel subscriptions themselves, no-code activation in the Dashboard

How this page was made: drafted with AI from the sources listed, reviewed by Pewterkit. Docs checked Oct 27, 2026. Spotted something out of date? Tell us.

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