California's renewal law survives the FTC rule's vacatur

The workload

Any business selling a subscription to a California consumer, regardless of what a federal rule currently requires, must separately satisfy California's Automatic Renewal Law. The statute's own text, Business and Professions Code section 17602, states, verified from the current codified text retrieved 16 September 2026, that before charging a consumer a business must clearly disclose that the service 'will automatically renew unless the consumer cancels,' the renewal period and price, and one or more methods to cancel. For an online sign-up, the statute requires a business to let the consumer 'terminate the automatic renewal or continuous service exclusively online,' through either 'a prominently located direct link or button' or an immediately accessible termination email, and requires that cancellation be available 'in the same medium that the consumer used' to enroll, a same-medium online cancel path, built once, not a support-ticket queue.

What the documents show

Section 17602 as currently codified was amended by Stats. 2024, Ch. 515 (AB 2863), effective 1 January 2025, applying to contracts entered into, amended or extended on or after 1 July 2025, verified from the section's own amendment history. A companion section, section 17600, states the law's original purpose, enacted 2009 and operative 1 December 2010: 'to end the practice of ongoing charging of consumer credit or debit cards or third party payment accounts without the consumers' explicit consent.' Neither section states that California's law is subordinate to, or preempted by, federal rulemaking; the two operate as independent obligations, and this entry does not assert one supersedes the other.

The operating cost

California's statute states no fee of its own; section 17604 states, verified, that a violation 'shall not be a crime' but that 'all available civil remedies' remain available, and that a business complying 'in good faith' is not subject to civil remedies, a stated safe harbor, not a fixed penalty amount. The operating cost is the one-time build of a same-medium online cancellation path and disclosure text, plus the legal-review labor of confirming good-faith compliance, not a per-violation fine named in the statute itself.

The stop condition

The statute names no sunset; it is a standing state obligation independent of the federal rule's status covered elsewhere in this pack. This is verified, not editorial. The practical stop condition is jurisdictional: the obligation applies only to consumers billed from California, a targeting question a solo operator answers with billing-address data, not a date.

• Does the cancellation path work in the same medium the customer used to sign up, as California's text requires, or does it downgrade to a phone line?
• Was the disclosure and cancellation flow updated for the 2025 AB 2863 amendment, or does it still reflect the pre-2025 text?
• Is the good-faith compliance safe harbor in section 17604 actually documented internally, in case a dispute ever tests it?

California's law predates the federal rulemaking covered elsewhere in this pack, was amended most recently for 2025, and states its own civil-remedy structure independent of whatever the FTC currently has in force; a founder billing California consumers answers to this statute regardless of the federal docket's status.