Staying Ahead Of Enforcement: Practical Compliance With Automatic Renewal Laws

Automatic renewals, more commonly referred to as subscription services, have become a household topic (or maybe just in ours?) of advertising law enforcement. Subscription services – from streaming platforms to meal kits – offer undeniable convenience, but that ease comes with legal complexity and scrutiny, both at the federal and state levels.

At the recent ANA Masters of Advertising Law conference, then-FTC Commissioner Melissa Holyoak (who was just appointed the interim U.S. attorney for the District of Utah) highlighted in our very own Amy Mudge and Daniel Kaufman's mainstage presentation that she believes ROSCA will continue to be an FTC enforcement priority. We also heard about automatic renewal enforcement priorities from the Massachusetts Attorney General's Office (which now has one of the strictest new Automatic Renewal laws that went into effect in Sept. 2025). As we close out 2025, businesses and legal practitioners must stay alert to the rapidly