California has passed AB 2683, a new law regulating automatic renewals and subscription-based services. The law, which takes effect on July 1, 2025, introduces stricter requirements for businesses, including many adult websites that operate on subscription models, to ensure transparency and protect users from unauthorized charges.

The new legislation adds a significant layer of protection for consumers, requiring businesses to follow specific guidelines for automatic renewal and continuous service offers.

1. Express Affirmative Consent: Businesses must obtain clear and affirmative consent from consumers before initiating any automatic renewal or continuous service. This includes providing clear and conspicuous information regarding the terms of the subscription, recurring charges, and the cancellation policy.
2. Annual Reminders: Businesses are required to send annual reminders to subscribers that include a full summary of the services, associated charges, and instructions on how to cancel. This ensures consumers are consistently informed about their subscriptions and fees, preventing hidden charges.
3. Simplified Cancellation: Businesses must provide a straightforward process for consumers to cancel their subscriptions. The method of cancellation must be as easy as the medium used to initiate the subscription, such as offering a “Click to Cancel” button on websites for subscriptions made online.
4. Record-Keeping: The law requires businesses to maintain records of consumer consent for at least three years or one year after the contract is terminated. This provision ensures accountability and allows businesses to demonstrate compliance if challenged.
5. Fee Changes and Notifications: Any changes to subscription fees must be communicated to consumers between seven and 30 days before the changes take effect, along with instructions on how to cancel if the customer chooses not to continue with the new pricing.

Adult websites, which often operate on subscription models with free-to-pay conversions (where a free trial leads to paid services unless canceled), will be particularly affected by this new law. The law introduces several important requirements that these businesses must now address:

• Subscription Transparency: Terms related to subscription renewals and charges must be clearly communicated to users. Websites will need to ensure that users are fully aware of what they are signing up for, particularly in cases where free trials transition into paid subscriptions.
• User-Friendly Cancellation: Many adult websites have faced criticism for making it difficult for users to cancel subscriptions. Under the new law, businesses will be required to provide a simple and accessible cancellation process, significantly reducing the chances of users getting trapped in recurring billing cycles they cannot easily exit.
• Administrative and Compliance Challenges: Maintaining proper records of user consent and sending annual reminders introduces an administrative burden for adult websites. However, this also offers them protection against claims of hidden fees or unauthorized charges.

Attorney Corey D. Silverstein, a legal expert in the adult industry, emphasized the importance of businesses in this sector taking steps now to comply with AB 2683 before it takes effect in mid-2025.

“This law is especially critical for businesses that rely on subscription models,” Silverstein noted. “Failure to comply could lead to legal liabilities and a loss of consumer trust.”

AB 2683 is part of California’s broader effort to address consumer complaints about automatic renewals and subscription services. The state’s Business and Professions Code already regulates these practices, but the new law strengthens these protections by introducing stricter consent, notification, and cancellation requirements.

The legislation reflects growing concerns nationwide about predatory subscription practices. Other states are likely to follow California’s lead, and federal action may also be on the horizon as consumer advocacy groups push for greater transparency in subscription-based services.

Businesses that rely on subscriptions, particularly in the adult entertainment industry, should begin preparing for the new law by reviewing and updating their processes. Key compliance steps include:

• Reviewing Subscription Processes: Ensure that terms of service and automatic renewal terms are clearly presented to users before they agree to a subscription.
• Updating Cancellation Procedures: Provide a clear and direct method for users to cancel subscriptions, especially for services initiated online.
• Establishing Record-Keeping Systems: Maintain proof of consumer consent and ensure that records are kept for the required duration to avoid future legal complications.
• Preparing Notifications: Set up systems to automatically send the required annual reminders to subscribers and ensure that notifications for fee changes meet the law’s timing and clarity requirements.

By taking proactive steps, businesses can avoid penalties and enhance customer trust while complying with California’s new law.

As the July 2025 deadline approaches, it is crucial for these businesses to adjust their practices to meet the new legal requirements.