Washington State Automatic Renewal Law: Disclosures and Cancellation

Washington’s automatic renewal law is not a single dedicated statute. Instead, the state’s Consumer Protection Act (CPA) treats unfair or deceptive subscription practices as unlawful, and the Attorney General enforces that standard against businesses that hide renewal terms, make cancellation difficult, or charge you without genuine consent. Federal rules add a second layer of protection on top.

The Law Washington Actually Uses

RCW 19.86.020 declares unfair or deceptive acts in trade or commerce unlawful.1Washington State Legislature. RCW 19.86.020 Unfair Competition, Practices, Declared Unlawful That sentence is deliberately broad. It does not lay out a subscription checklist the way California and New York statutes do. The Attorney General applies it case by case, and hidden renewal terms, buried cancellation procedures, and surprise charges all fit within its reach.

The legislature has looked at passing something more specific. SB 5207, introduced in the 2025-2026 session, would have set detailed requirements for electronic media subscriptions and required refunds on early cancellation, but it did not clear committee.2Washington State Legislature. SB 5207 Bill Summary Until a targeted bill passes, the CPA is the tool.

What a Business Has to Disclose

Before you agree to a subscription, the material terms have to be presented clearly. They can’t be buried in fine print or hidden behind an obscure link. In practice, that means four pieces of information should be plain at the point of purchase:

  • That the subscription will keep renewing and charging you unless you cancel.
  • How to cancel, in enough detail that you could actually do it.
  • The amount you’ll be billed each cycle, including any post-promotional price.
  • How long each renewal term lasts.

Consent has to be affirmative. A pre-checked box doesn’t count. Neither does a passive notice saying that continuing to use the service means you agree. You have to take a clear, voluntary step, like checking an empty box next to a statement that spells out the renewal terms.

Long-term contracts get an extra expectation. When a renewal is a year out and involves a substantial charge, a signup disclosure alone isn’t enough to keep the deal fair. The Attorney General’s position is that businesses should send a reminder before the renewal date, restating the new term, the price, and how to cancel, with enough lead time that you can actually act on it.

Cancellation Has to Be as Easy as Signup

The cancellation process is where most complaints come from. A company that makes signing up effortless and canceling agonizing is doing exactly what the CPA targets. The principle is simple: canceling shouldn’t be harder than enrolling. If you signed up online in a minute, you should be able to cancel online in a minute. Forcing you to sit on hold with a retention agent or mail a certified letter for a service you started with two clicks would likely be treated as unfair.

The card networks add a backstop. Mastercard requires merchants to send you a written or electronic notice before a free trial converts to a paid subscription, at least three days before the trial ends when the trial runs longer than seven days. The confirmation has to include subscription terms, a receipt, and clear cancellation instructions. For subscriptions billed six or more months apart, such as annual plans, Mastercard requires an electronic payment reminder before the charge.

Federal Rules That Also Apply

Two federal frameworks bind businesses selling to Washington consumers, on top of the CPA.

The Restore Online Shoppers’ Confidence Act

ROSCA, codified at 15 U.S.C. 8403, covers any online sale with a negative option feature, meaning any setup where your silence is treated as consent to keep being charged. A seller cannot charge your card or bank account unless it has clearly disclosed all material terms before collecting your billing information, obtained your express informed consent, and provided a simple mechanism to stop recurring charges.3Office of the Law Revision Counsel. 15 USC 8403 – Negative Option Marketing on the Internet The Federal Trade Commission enforces it.

The FTC’s Click-to-Cancel Rule

In October 2024, the FTC finalized a rule that sharpens ROSCA. The rule requires sellers to make cancellation as easy as enrollment. If you signed up online, the seller cannot force you to call a phone number or mail a letter to cancel. It also bars misrepresentations of material facts during negative option marketing, requires clear disclosure before billing information is collected, and mandates express informed consent before any charge.4Federal Trade Commission. Federal Trade Commission Announces Final Click-to-Cancel Rule The FTC voted in 2025 to defer the compliance deadline by 60 days, so businesses are still adjusting.5Federal Trade Commission. FTC Votes on Negative Option Rule Deadline For Washington consumers, the federal rule sets a concrete floor even where the CPA’s language feels open-ended.

What You Can Do If You Were Charged Unfairly

You have three practical paths, and you can use more than one at the same time.

File a complaint with the Attorney General. The office accepts consumer complaints at atg.wa.gov. It will forward your complaint to the business and request a response. A single complaint doesn’t guarantee enforcement, but it creates a record, and patterns of similar complaints against the same company often trigger an investigation. Before filing, pull together your signup confirmation, any renewal notices you did or didn’t receive, screenshots of the cancellation process, and the charges on your statement. If canceling was itself difficult, that difficulty belongs in the complaint.

Dispute the charge with your bank or card issuer. Unauthorized recurring charges are a recognized basis for a chargeback under most card-network rules. You can do this while the AG complaint is pending.

Sue on your own. The CPA gives you a private right of action. If a deceptive auto-renewal injured you, you can file in superior court to recover your actual damages and the costs of the suit, including reasonable attorney fees. The court can also award up to three times your actual damages, capped at $25,000 for unfair-practices violations.6Washington State Legislature. RCW 19.86.090 Civil Action for Damages, Treble Damages, Attorney Fees Smaller claims can go to district court under the same provisions. The attorney-fee provision is what makes this realistic for a subscription case, because most of these disputes involve modest amounts that would otherwise cost more to litigate than to recover.

What a Business Faces

The Attorney General has broad authority under RCW 19.86.080 to sue for court orders that stop deceptive practices and restore money to consumers.7Washington State Legislature. RCW 19.86.080 Attorney General May Restrain Prohibited Acts That includes refunds and injunctions forcing changes to how the business handles renewals.

Civil penalties can climb quickly. Each violation of RCW 19.86.020 can draw up to $7,500. Violating a court injunction raises the ceiling to $125,000. And if the conduct targeted people based on age, race, disability, immigration status, or other protected characteristics, an additional $5,000 per violation applies.8Washington State Legislature. RCW 19.86.140 Civil Penalties Because each unauthorized charge to each consumer can count as a separate violation, the arithmetic against a large subscription service adds up fast.