2025 Brings Significant Developments to Federal and State Automatic Renewal Laws

Litigation partner Michael Daly and counsel Matthew Adler co-authored an article for the American Bar Association’s Litigation Section that discusses significant developments in federal and state automatic renewal laws (ARLs) coming in 2025. As subscriptions and memberships have become more common, 35 states and Washington, D.C., have enacted or amended ARLs, creating complex compliance challenges for businesses with nationwide operations. 

The article examines the scheduled changes, including the Federal Trade Commission's amended Rule Concerning Recurring Subscriptions and Other Negative Option Programs (NOR) effective May 14, amendments to California's ARL effective July 1, and new ARLs in Minnesota and Utah effective January 1. 

Daly and Adler also explored the implications of these changes and the importance of businesses staying updated on ARL developments to ensure compliance and mitigate legal risks, as legislative activity and enforcement actions in this area continue.