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Oregon's Automatic Renewal Law: What ORS 646A.295 Requires

Oregon's automatic renewal law, ORS 646A.295, requires businesses that sell subscriptions or continuous-service plans to disclose the recurring-charge terms clearly and conspicuously, obtain your affirmative consent before billing, send a retainable acknowledgment that includes how to cancel, and provide an easy cancellation method. A violation is an unlawful trade practice under ORS 646.608, enforceable by the Oregon Department of Justice.

What the law covers

Oregon regulates subscription auto-renewals and continuous-service plans through ORS 646A.295, with the key terms defined in ORS 646A.293. The definitions section describes an "automatic renewal" as a paid subscription or purchasing agreement that automatically renews at the end of a definite term, and a "continuous service" as a plan that continues until the consumer cancels. Both are covered by the same set of rules.

The law protects a "consumer," defined as an individual who buys or leases goods, services, money, or credit for personal, family, or household purposes. That framing means the statute is aimed at ordinary consumer subscriptions rather than purely business-to-business arrangements. It applies both at the moment you sign up and throughout the life of the recurring charge.

This page is general information about Oregon law, not legal advice. Statutes and their interpretation can change, so anyone dealing with a specific dispute should confirm the current text and consider speaking with a licensed Oregon attorney or the state's consumer-protection resources.

Clear disclosure and affirmative consent

Before a subscription or purchasing agreement is fulfilled, the business must present the automatic-renewal or continuous-service offer terms in a "clear and conspicuous" manner, and it must do so in visual proximity to the request for your consent (or, for a phone or audio offer, in temporal proximity). ORS 646A.293 says clear and conspicuous means the terms stand out through larger or contrasting type, distinct fonts or colors, or set-off symbols, and that audio disclosures must be readily audible and understandable.

The offer terms themselves must spell out that the plan continues until the consumer cancels, describe the cancellation policy, state the recurring charge amounts and any changes that are known at signup, give the length of the renewal term where the consumer did not choose it, and disclose any minimum purchase obligation.

Critically, the business cannot charge your credit card, debit card, or third-party payment account for an automatic renewal or continuous service without first obtaining your affirmative consent to the agreement that contains those terms. Consent has to be an actual, informed agreement to the recurring-billing terms, not something buried in fine print.

The acknowledgment and free-trial rule

After the transaction, the seller must provide an acknowledgment that includes the offer terms and information about how to cancel, delivered in a way the consumer is able to retain. The point is that you should be left with a durable record of both what you agreed to and how to get out of it.

When the offer includes a trial period, the statute adds a further protection: the acknowledgment must also disclose how to cancel and must allow the consumer to cancel before paying for the goods or services. In other words, a trial that converts to paid billing has to give you a genuine, disclosed opportunity to stop the charge before it hits.

How cancellation must work

ORS 646A.295 requires the business to give consumers a cost-effective, timely, and easy-to-use way to cancel. At a minimum that means a toll-free telephone number, an electronic mail address, a postal address (which is required only when the business directly bills the consumer), or another mechanism that meets the same easy-to-use standard.

The practical takeaway is that ending a subscription should not be dramatically harder than starting one. If you enrolled online in a couple of clicks but the company forces a lengthy phone-only retention process, that friction is exactly what the easy-cancellation requirement is meant to address. Keep a dated record of your cancellation request and any confirmation you receive.

Material changes, unauthorized shipments, and exemptions

If the terms of an accepted automatic-renewal or continuous-service offer materially change, the business must give the consumer a clear and conspicuous notice of the change along with information about how to cancel.

The statute also carries a strong remedy for improper billing: if a business sends goods, wares, merchandise, or products to a consumer under a continuous-service agreement or an automatic renewal without first obtaining the required affirmative consent, those items are deemed for all purposes an unconditional gift. The consumer may keep them with no obligation to pay or return them.

The requirements do not apply to certain regulated sectors. Exempt entities include services provided under a franchise or license or regulated by the Oregon Public Utility Commission, the Federal Communications Commission, or the Federal Energy Regulatory Commission; insurers regulated under the Insurance Code; banks, credit unions, and other financial institutions; sellers of service contracts under ORS 646A.150 to 646A.172; consumer finance companies licensed under ORS chapter 725; and direct-to-home satellite service providers regulated by the FCC.

Enforcement and where to get help

A violation of ORS 646A.295 is treated as an unlawful practice under ORS 646.608, which is part of Oregon's Unlawful Trade Practices Act (ORS 646.605 to 646.652). That connection means the Oregon Department of Justice can investigate and pursue enforcement, and it places subscription auto-renewal abuses in the same category as other deceptive trade practices.

The Unlawful Trade Practices Act also allows a consumer who suffers an ascertainable loss of money or property to bring a private lawsuit under ORS 646.638. Whether a particular situation supports a claim depends on the facts, so this is a point to raise with a licensed attorney.

If you believe a company charged you without proper consent, failed to disclose renewal terms, or made cancellation unreasonably difficult, you can document the sign-up terms and any acknowledgment you received, cancel through the company's stated method, and file a complaint with the Oregon Department of Justice's consumer-protection program at oregonconsumer.gov.

Sources

This page summarizes law and regulatory actions from primary sources and is general information, not legal advice.

FAQ

Does Oregon require businesses to let me cancel online?

ORS 646A.295 requires a cost-effective, timely, and easy-to-use cancellation mechanism, and it lists a toll-free number, an email address, or (for direct billing) a postal address as acceptable options. It does not spell out a single mandatory online click-to-cancel button the way some other states do, but whatever method is offered must be genuinely easy to use.

What happens if I was billed without agreeing to auto-renewal?

If a business sends you goods under a continuous-service or automatic-renewal arrangement without first getting your affirmative consent, the statute deems those items an unconditional gift, meaning you owe nothing and need not return them. Improper renewal billing may also be an unlawful trade practice under ORS 646.608, which you can report to the Oregon Department of Justice.

Does the law apply to my utility, bank, or insurance subscription?

Not necessarily. ORS 646A.295 exempts several regulated sectors, including utilities and services regulated by the Oregon PUC, FCC, or FERC, insurers under the Insurance Code, banks and other financial institutions, service-contract sellers, consumer finance companies, and direct-to-home satellite providers. Those relationships are governed by their own rules rather than this statute.

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