S 2266119th CongressIn Committee

Consumer Online Payment Transparency and Integrity Act

Introduced: Jul 14, 2025

Sponsor: Sen. Van Hollen, Chris [D-MD] (D-Maryland)

Financial Services

Standard Summary

Comprehensive overview in 1-2 paragraphs

The Consumer Online Payment Transparency and Integrity Act establishes comprehensive federal protections for consumers enrolled in automatic renewal subscriptions and free trial services. The bill requires businesses to provide clear disclosures, send advance notifications before charging consumers, obtain annual consent for renewals, and make cancellation as easy as signing up. It addresses the growing problem of consumers being unknowingly charged for subscriptions they forgot about or didn't realize would auto-renew. The Federal Trade Commission would enforce these requirements, treating violations as unfair or deceptive practices with penalties including voiding the contract and requiring full refunds to affected consumers.

Key Points

1Advance Notification Required: Businesses must notify consumers at least 7 days before any automatic renewal or before a free trial converts to a paid subscription, using the same method the consumer used to sign up
2Annual Consent Mandate: Companies must obtain fresh express consent from consumers on an annual basis before charging for automatic renewals, regardless of initial agreement
3Inactivity Protections: If a business knows a consumer hasn't used a service for 6 consecutive months, they must obtain new consent before charging and inform the consumer of their right to a prorated refund
4Easy Cancellation Requirement: Cancellation must be "simply" accomplished—at least as easy as signing up—through online mechanisms plus at least one additional method (phone, email, or mail)
5Dark Pattern Prohibition: Consent obtained through manipulative user interface designs ("dark patterns") that undermine consumer decision-making is not considered valid consent

Impact Areas

Consumers: Primary beneficiaries who gain stronger protections against unwanted charges, forgotten subscriptions, and difficult cancellation processesSubscription-Based Businesses: Must implement new notification systems, consent mechanisms, and simplified cancellation processes; face potential penalties for non-complianceFederal Trade Commission: Gains expanded enforcement authority and rulemaking power over automatic renewal practices across all industriesService Contract Providers: May receive exemptions from certain requirements as determined by the FTC, particularly for vehicle and property maintenance contracts

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