Subscription and auto-renewing arrangements are regulated by federal rules and by an expanding set of state statutes.
Disclosure before purchase. The renewal terms, the recurring charge and its frequency, the cancellation deadline and the method, presented clearly and conspicuously in visual proximity to the consent mechanism.
Affirmative consent to the recurring charge, separate from consent to the transaction generally. Pre-checked boxes and bundled consents are the recurring violation.
Acknowledgement after purchase, retaining the terms and the cancellation information in a form the consumer can keep.
Cancellation. A mechanism at least as simple as the enrolment mechanism. Where enrolment was online, cancellation must be available online without speaking to a representative — the requirement generating the most enforcement.
Renewal reminders before renewal for longer terms, required by several statutes with specified timing.
Free trials and promotional pricing with additional notice before the price increases.
Remedies. Statutory damages, refunds, and in some statutes a provision that goods delivered without compliant consent are an unconditional gift.
Compliance practice. Test the cancellation path as a user, on every channel, and document it — because that is how enforcement tests it.