With no federal rule in force, California's ARL governs renewals

The figure or the record

California's Automatic Renewal Law, codified at Business and Professions Code section 17602, picked up amendments under Assembly Bill 2863 that apply, by the statute's own terms, to a contract entered into, amended, or extended on or after 1 July 2025. The underlying law already required a business to get a consumer's affirmative consent before charging for an automatic renewal or continuous service, to disclose the renewal terms and cost, and to offer a cancellation method that, for anything sold online, works exclusively online without extra steps. The 2025 date marks when the newer disclosure and timing requirements start binding new and renewed contracts, separate from the amendment's own earlier enactment as law on 1 January 2025.

What the documents establish

The statute is specific about timing: a renewal notice must go out 3 to 21 days before a trial or promotional period ends, or 15 to 45 days before an annual renewal, and online cancellation must work at will and without engaging any further steps. None of that turns on federal law. A separate federal record matters here only by absence: the Federal Trade Commission's 2024 click-to-cancel rule, which would have imposed a similar federal disclosure-and-cancellation duty nationwide, was vacated by the Eighth Circuit on procedural grounds and, per the Commission's own February 2026 notice, replaced with a reversion to older, narrower federal text. That leaves California's own statute, not a federal backstop, doing the substantive work for a coin-subscription app selling to a California consumer.

Scope and caveats

Section 17602 governs automatic renewal and continuous-service offers; a recurring coin subscription fits that description directly, but a one-time coin pack purchase, with no renewal, does not, and this statute does not reach it. The law is state-specific: it binds a business offering the service to a California consumer, not an app's practices in every state, and this record does not establish what a different state requires. Nor does the federal vacatur mean no federal rule exists at all; the Commission's own account is that a pre-2024 negative-option rule remains in force, just a narrower one than the version that was set aside.

What to watch

Editorially, the point worth tracking is whether other states pass their own AB 2863-style amendments now that a federal backstop is absent, since state auto-renewal laws, not a uniform federal rule, are currently the operative check on a coin-subscription's renewal design.

• Does the app's cancellation flow, for a California user, work at will online without a phone call or retention offer first?
• Is the renewal reminder timed to the statute's 3–21 day or 15–45 day windows, depending on the offer type?
• Does the platform treat a one-time coin purchase and a recurring coin subscription differently in its renewal disclosures, as the statute's own distinction would suggest it should?

A federal rule was announced, then set aside on process grounds, then formally reverted; in the meantime, the operative consumer protection for a coin subscription sold in California has been a state statute that never depended on the federal rule surviving.