Michigan Bill Targets Auto-Renewal Disclosures in Consumer Contra

Subscriptions are like houseplants: if you forget about them long enough, something will still be draining your resources.
Except houseplants usually don’t charge your card every month and then pretend they “clearly disclosed” it in a font size
normally reserved for ant footprints.

That “set it and forget it” reality is exactly why lawmakers across the U.S. keep circling back to auto-renewal rules.
Michigan is now in that conversation with a proposed bill aimed at making automatic renewal terms harder to miss and easier
to escapeespecially when the contract starts online.

Why auto-renew disclosures are suddenly everyone’s business

Automatic renewal provisions (sometimes called “negative option” features) are common: streaming services, SaaS tools, gym
memberships, meal kits, news subscriptions, beauty boxes, tutoring platforms, and even that “free trial” you only started
because you wanted one specific template for a school project.

Auto-renew isn’t inherently shady. The problem is when a consumer agrees to something without genuinely understanding:
(1) it will renew, (2) how long it renews for, (3) what it costs now versus later, and (4) how to cancel without needing a
minor in customer-service archaeology.

Michigan’s proposal basically says: “If you’re going to renew people automatically, you need to say it plainly, say it loudly,
and give them a clean exit.”

The Michigan proposal in plain English

A Michigan House bill introduced in late 2025 would add a new section focused on “automatic renewal provisions” under the
Michigan Consumer Protection Act framework. The bill’s core theme is simple:
clear disclosures + timely reminders + no cancellation games.

1) Big, clear disclosures (yes, the bill literally cares about font size)

If a business sells or leases goods/services under a consumer contract with an automatic renewal provision, the renewal terms
must be disclosed clearly and conspicuously in not less than 14-point type.
And Michigan isn’t just asking for a vague “This may renew.” The disclosure is expected to cover specific items, including:

• That the contract will automatically renew if the consumer agrees.
• The length of the initial term and the length of each renewal period.
• Pricing for the initial term and renewal periods, including:
  • Any promotional or discounted price (and how long it lasts).
  • If there’s a free gift or free trial, what price will be charged after the trial ends (or how pricing changes).
• A list and explanation of any terms that change on renewal (price changes, features removed, billing frequency changes, etc.).
• The exact cancellation procedure at the end of the initial term or renewal period (and after a free trial, if applicable).
• A cancellation contact method: email, mailing address, toll-free number, or another easy-to-use mechanism
  (with an important online-cancellation rule discussed below).

Translation: if the business expects recurring revenue, it should be willing to show the rules in a size that doesn’t require
a microscope, a flashlight, and a supportive friend.

2) Renewal reminders for longer renewals

Some subscriptions renew monthly and are easy to notice on a bank statement. The bill targets longer renewals too.
Under the proposal, a business generally should not automatically renew a consumer contract for
more than two months unless it provides the consumer an electronic notice before the end of the term.

That notice must be delivered within a defined window:
not less than 30 days and not more than 60 days before the last day the consumer can give notice to cancel.
The notice must also be clear, in at least 14-point type, and include key info like:

• That the contract will renew unless the consumer cancels.
• Any terms that will change on renewal.
• The specific cancellation procedure.
• A cancellation mechanism (email/address/toll-free number or similar).

Beyond that, the proposal includes ongoing “you are subscribed” reminders:
generally every six months, and for certain services involving physical equipment used on-site or outside the
consumer’s principal residence, annually.

3) No “punishment fees,” and cancellations must be honored

The bill also takes a direct swing at the most common consumer complaints: “I canceled and they kept charging me” and
“They charged a fee just to stop the renewal.”

It would generally prohibit practices like:

• Not giving consumers at least 30 calendar days after the renewal notice to cancel (where the notice rule applies).
• Failing to honor a timely cancellation notice, even if the business receives it right before or after the notice window ends.
• Charging an additional cost or penalty to cancel at the end of the term, renewal period, or free trial period.

In other words: once a consumer follows the rules to exit, the business must follow the rules to let them go.

4) If the consumer signed up online, they can cancel online

One of the most consumer-friendly pieces is the online cancellation requirement. If a consumer accepts a contract with an
automatic renewal provision online, the business must allow the consumer to
cancel the contract exclusively online.

That’s aimed at the classic mismatch: sign up in 12 seconds on a phone, cancel by phone only (during business hours),
with a hold time long enough to qualify as a short documentary.

5) If the contract violates the rules, the consumer may be able to void it

The bill states that a consumer contract that is contrary to the new section would be
voidable by the consumer. “Voidable” generally means the consumer can elect to treat the contract as invalid,
which may strengthen cancellation rights and potential remedies in a dispute.

6) A carve-out for certain regulated telecom services

The proposal includes an exemption: it would not apply to certain businesses offering telephone, wireless, or broadband
services regulated by the Michigan Public Service Commission. This mirrors a broader pattern in consumer protection law:
regulated industries are often handled through specialized rules and oversight rather than one-size-fits-all consumer statutes.

How Michigan’s bill fits into the national auto-renew trend

Michigan isn’t writing this story in a vacuum. Over the last few years, the U.S. has seen a steady escalation of
auto-renewal rules at both the federal and state level.

The FTC tried to modernize “negative option” rulesthen a court hit pause

In October 2024, the Federal Trade Commission finalized a sweeping “Negative Option Rule,” often nicknamed
“click-to-cancel.” The idea was to standardize basic protections such as clearer disclosures, express consent, and
cancellation methods that are as easy as signing up.

But the rule became tangled in legal challenges, and in mid-2025 a federal appeals court vacated it due to procedural
issues. That didn’t erase the broader enforcement reality. It mainly meant:
the federal “one rule to rule them all” approach slowed down, while state laws became even more important.

ROSCA still matters, and so do “dark pattern” enforcement theories

Even without the FTC’s modernized rule fully in effect, subscription companies still face risks under older federal law
and enforcement standardsespecially online.

The Restore Online Shoppers’ Confidence Act (ROSCA) is one of the best-known federal tools addressing deceptive online
billing and negative option features. In broad terms, it focuses on material disclosures, informed consent, and simple
ways to stop recurring charges.

Meanwhile, regulators have also called out “dark patterns”interfaces designed to nudge, confuse, or trap people into
purchases they don’t actually intend. When a cancellation flow is buried, confusing, or artificially slow, it becomes
harder for a company to argue it acted fairly and transparently.

How Michigan’s approach compares to other states

If you’ve ever wondered why subscription compliance teams look permanently tired, it’s because state automatic renewal
laws don’t just existthey multiply. Michigan’s approach lines up with several common themes:

California: “same-channel” cancellation and robust renewal disclosures

California has long been one of the most influential states in this space. Recent updates emphasize clear, near-the-button
disclosures, renewal/price-change notices, and straightforward cancellationespecially for online sign-ups. Many companies
use California as their “highest bar” template because it’s easier to run one compliant system than 50 different ones.

New York and Colorado: one-step links and online cancellation as a baseline

Other states have sharpened the “make canceling as easy as enrolling” standard.
A growing pattern is to require a simple online processsometimes even a one-step linkrather than forcing consumers to
call, mail letters, or navigate a maze of chatbots.

Michigan’s bill fits that direction by insisting that if the consumer entered the relationship online, they can exit online.

What this could mean for Michigan consumers

If Michigan’s proposal (or a similar version) becomes law, consumers would likely get clearer information up front and fewer
last-minute surprises. Practically, that could show up as:

• More obvious renewal terms at checkout and inside contracts.
• Better “free trial” transparencyespecially the “what happens after” price.
• Reminder emails before longer renewals lock in.
• Online cancellation for online sign-ups without being rerouted to phone-only support.
• Fewer cancellation fees tacked on as a final “goodbye gift.”

Consumer tip: if you’re signing up for something that renews, take screenshots of the sign-up page and the cancellation
confirmation. It’s not paranoiait’s documentation.

What this could mean for businesses and subscription operators

For businesses, this is less about “adding annoying disclosures” and more about building a subscription experience that
won’t trigger complaints, chargebacks, or enforcement attention. A practical compliance mindset would include:

Design the sign-up flow like a judge will read it later

• Put renewal terms near the “Buy” or “Start trial” buttonnot in a footer scavenger hunt.
• Spell out the renewal cadence and price in normal language (monthly? annual? what’s the exact amount?).
• If there’s a promo, say when it ends and what the post-promo price is.
• Avoid pre-checked boxes or confusing toggles that can be framed as “not real consent.”

Automate renewal notices and reminders

• Build a system that triggers renewal notices in the required window (think: 30–60 days before the relevant deadline).
• Include the cancellation steps in the noticenot just a “manage your account” shrug.
• Keep proof of sending notices (logs matter when disputes happen).

Make cancellation frictionless, especially online

• If sign-up happens online, cancellation should be doable onlinecleanly.
• Don’t require “talk to us first” unless the consumer wants that.
• Stop billing promptly after cancellation and provide confirmation.

Train customer support like they’re part of compliance (because they are)

The best-designed cancellation button won’t save a company if customer support keeps “forgetting” to process requests or
invents new hoops. Support scripts, escalation protocols, and refund practices should match the legal expectations.

Concrete examples: what changes could look like

Example 1: The “free trial” that isn’t really free

A consumer starts a 7-day free trial for a language-learning app. Today, many services mention renewal somewhere, but the
“after trial” price is vague (“standard rate applies”). Under Michigan’s approach, the post-trial price (or how pricing
changes) should be spelled out clearly, along with how to cancel at the end of the trial.

Example 2: A yearly renewal that sneaks up

A student signs up for a discounted annual plan for design software. Eleven months later, the renewal hits at full price and
the student swears the calendar moved without permission. Under the bill’s notice approach for longer renewals, the company
would generally need to send an electronic notice in a specific window before the consumer’s cancellation deadline.

Example 3: Online sign-up, phone-only cancellation

A consumer joins a membership online in two minutes. Canceling requires calling during business hours and waiting on hold.
Michigan’s proposed rule would push toward online cancellation for online sign-ups, reducing that mismatch.

Bottom line

Michigan’s proposed auto-renew disclosure bill is part of a broader shift:
subscriptions aren’t going away, but “subscription traps” are losing their legal oxygen.

For consumers, it promises clearer terms, better reminders, and simpler exits.
For businesses, it’s a strong nudge toward transparent design and clean cancellationbecause the “confuse them into staying”
strategy is becoming less defensible (and more expensive).

Real-World Experiences Related to Michigan’s Auto-Renewal Push (Extra Section)

To understand why bills like this keep popping up, you don’t need a law degreeyou just need a debit card and a life.
Here are some common experiences that show what auto-renew confusion looks like in the real world (and why lawmakers are
trying to turn the lights on).

1) The “I only wanted it for one month” gym situation

Someone signs up for a “one-month special” at a gym because it’s cheaper than buying a yoga mat they won’t use anyway.
The front desk is friendly, the contract is… not. Months later, the member notices recurring charges and tries to cancel.
But cancellation requires an in-person visit or a mailed letterbecause apparently it’s 1997.
The consumer feels blindsided because the auto-renew terms weren’t obvious at sign-up, and the cancellation method doesn’t
match how they enrolled. A bill requiring big disclosures and online cancellation would directly target this mismatch.

2) The “free trial” that turns into a surprise bill

A consumer starts a free trial for a homework help platform, thinking, “I’ll cancel after finals.”
Finals end, the brain powers down, and suddenly the credit card statement has a charge that looks like it came from a
company name printed in invisible ink. The consumer digs through emails and finds a trial confirmation, but the post-trial
price was never clearly statedor it was stated in a way that felt more like a riddle than a disclosure.
Clear “after trial” pricing and cancellation steps in plain sight wouldn’t eliminate forgetfulness, but it would eliminate
the “you never told me” argument that fuels a lot of disputes.

3) The small business that accidentally annoys customers

Not every auto-renew mess is a villain story. Sometimes a small business offers a subscription box (coffee, candles, snacks,
art suppliespick your joy) and uses a standard e-commerce plugin.
The plugin is great at billing and terrible at communication. Customers don’t get renewal reminders, the cancellation link
is buried, and the “manage subscription” button only appears after logging into an account many customers never created.
Complaints pile up, chargebacks happen, and now the business is spending more time doing customer support than packing boxes.
Rules that force clear disclosures and simple cancellation can actually protect businesses from the silent revenue killer:
angry customers.

4) The “I canceled… I think?” email chain

One of the most frustrating experiences is the cancellation limbo:
the consumer clicks something, gets redirected, fills out a form, receives no confirmation, and then gets billed again.
Now it’s an email chain: “I canceled.” “Our records show you didn’t.” “I did.” “Please provide proof.”
It’s a mess for everyone. Clear cancellation procedures, online cancellation for online enrollments, and expectations to
honor timely cancellation notices are designed to prevent this exact scenario.

5) The renewal notice that arrives after the renewal

Some consumers get a notice like: “Your subscription renewed!” which is about as helpful as a smoke alarm that beeps after
the fire department leaves.
When renewal notices are sent too late (or not at all), consumers feel trickedeven if the company didn’t intend it.
A defined notice window (like 30–60 days before a key cancellation deadline for longer renewals) pushes businesses to warn
people while there’s still time to make an informed decision.

These experiences are why “auto-renew” rules keep evolving: the subscription economy runs on trust, and trust collapses when
the rules feel hidden or the exit feels locked.