The 'Cancel' Button is Getting Easier: New Bill Demands Annual Consent and 7-Day Warning for Auto-Renewals

We’ve all been there: signing up for a “free trial,” forgetting about it, and then spotting a surprise charge on the bank statement a month later. The Consumer Online Payment Transparency and Integrity Act is designed to put an end to that specific headache, making it much harder for companies to sneak those automatic renewal charges past you.

This bill requires any business selling a subscription or service with an automatic renewal feature (what the bill calls a “negative option”) to be crystal clear about the terms and, crucially, how to cancel. If a company messes up the required disclosure or consent rules, the automatic renewal part of the contract is immediately void, and they have to refund all the money you paid because of that violation (SEC. 2).

No More Subscription Sneak Attacks

For anyone juggling multiple streaming services, software licenses, or monthly boxes, this is a major policy shift toward convenience. Currently, some companies make the sign-up process a breeze but bury the cancellation button deep within their website or force you to call a support line during business hours. This bill mandates that if you can sign up online, you must be able to “simply cancel”—meaning the cancellation process must be just as easy to use as the enrollment process. This includes requiring an online cancellation method, plus a toll-free number or email (SEC. 4, SEC. 2).

Even more impactful are the new rules around consent. If you have an auto-renewing subscription, the company can’t just keep charging you forever based on your initial agreement. They must get your express, informed consent again before billing you, and they have to do this annually. Think of it as a mandatory yearly check-in: “Are you sure you still want this?” (SEC. 2).

The Free Trial Countdown Clock

The bill also tackles the notorious “free-to-pay conversion.” If you start a free trial that automatically rolls into a paid subscription, the seller must notify you at least seven days before the trial ends. This notice has to include those easy cancellation options. But here’s the kicker: they can’t just start charging you after the trial ends; they must get your express, informed consent for the charge at least seven days before the trial expires (SEC. 2).

For businesses, especially those in the subscription economy, this means a significant administrative overhaul. They will need systems to track annual consent deadlines and send out mandatory 7-day advance notices for both renewals and trial conversions. While this increases compliance costs, it forces a more honest relationship with the consumer, potentially reducing customer disputes and chargebacks in the long run.

Banning the Digital Shell Game

Perhaps the most modern provision involves “Dark Patterns.” The bill defines these as any online design or interface that is intentionally tricky and “substantially messes with your ability to make your own decisions or choose freely.” The legislation explicitly states that if a company uses these tricky design elements to get you to agree to an auto-renewal or a free-to-pay conversion, that agreement doesn't count as valid consent (SEC. 4, SEC. 2).

This is a direct shot at websites that hide the downgrade button, use confusing double negatives, or make the “No thanks” option nearly invisible. The Federal Trade Commission (FTC) is tasked with enforcing this entire act, treating violations as “unfair or deceptive acts or practices,” which gives them strong existing authority to fine companies that try to game the system (SEC. 3). While the definition of “Dark Patterns” is broad—relying on whether the design “substantially messes” with consumer choice—it gives the FTC the necessary flexibility to adapt to new online tricks as they emerge. All these new rules are set to take effect one year after the bill is signed, giving businesses time to adjust their systems.