Consumer Online Payment Transparency and Integrity Act
The Consumer Online Payment Transparency and Integrity Act establishes comprehensive federal protections for consumers enrolled in automatic renewal subscriptions and free trial offers. The bill requires businesses to provide clear disclosure of automatic renewal terms, send advance notifications before charging consumers, obtain annual express consent for renewals, and offer simple cancellation mechanisms that are as easy to use as the sign-up process. Notably, the bill addresses "subscription traps" by requiring businesses to obtain new consent if a consumer hasn't used a service for six consecutive months and voids automatic renewals obtained through deceptive "dark patterns." Enforcement is delegated to the Federal Trade Commission, with violations treated as unfair or deceptive trade practices, and the requirements take effect one year after enactment.
Key Points
- 1Advance Notification Requirement: Businesses must notify consumers at least 7 days before any automatic renewal or the end of a free trial period, using the same communication method used for the original sign-up
- 2Annual Consent Mandate: Companies must obtain fresh express informed consent from consumers on an annual basis before charging for automatic renewals, regardless of initial agreement
- 3Inactive Account Protection: If a consumer hasn't used a service for 6 consecutive months, businesses must obtain new consent before charging and inform consumers of their right to terminate with a prorated refund
- 4Simple Cancellation Standard: Cancellation mechanisms must be "at least as easy to use" as the sign-up process and include online options plus at least one additional method (phone, email, or postal mail)
- 5Dark Pattern Prohibition: Consent obtained through manipulative user interface designs that undermine consumer decision-making is explicitly invalidated, with violations resulting in contract termination and full refunds