Vermont's Automatic Renewal Law: The Opt-In Rules Explained

Vermont's automatic renewal statute, 9 V.S.A. § 2454a, sits inside the state's Consumer Protection Act (Title 9, Chapter 63). Enacted in 2018 through H.593 and effective July 1, 2019, it is widely described by consumer-law practitioners as one of the strictest automatic renewal laws in the country. As of 2026 it remains in force, and its core requirements are unchanged. Its defining feature is that a covered contract cannot roll over automatically unless the consumer knowingly agreed to that rollover and later receives a reminder before it happens.

The law addresses a familiar frustration: a subscription or service quietly continuing after an introductory term, with the next charge landing before the customer remembers to cancel. Section 2454a responds by layering three protections onto the contracts it covers — a conspicuous disclosure, a separate opt-in, and an advance renewal notice.

Section 2454a applies to a contract between a consumer and a seller or lessor that has an initial term of one year or longer and that renews for a subsequent term longer than one month. Both conditions must be met. A plan whose renewal term is a month or shorter generally falls outside the statute's renewal-notice machinery, as do contracts whose initial term is under a year.

The statute also carves out certain regulated relationships. Contracts with financial institutions and credit unions (as defined under Vermont law) and insurance policies are generally exempt. Because coverage turns on the exact term lengths and the type of seller, whether any particular subscription is covered depends on that subscription's specific written terms.

What makes Vermont notable is that accepting the contract is not, by itself, enough to authorize automatic renewal. Under § 2454a, the automatic renewal terms must be stated clearly and conspicuously in plain, unambiguous language in bold-face type, and the consumer must take a separate affirmative action to opt in to the automatic renewal provision specifically — in addition to agreeing to the contract as a whole.

Commentators often call this a "double opt-in." At the point of sale, a covered seller cannot bury renewal in the fine print or rely on a pre-checked box; the customer has to take a distinct, affirmative step — such as separately checking an unchecked box — that signals agreement to the rollover itself. Vermont was the first state to require both bold-face type and this second, standalone opt-in beyond acceptance of the contract.

If a consumer opts in to automatic renewal, the seller must send a written or electronic notice not less than 30 days and not more than 60 days before the earliest of the automatic renewal date, the termination date, or the date by which the consumer must give notice to cancel. This advance-reminder window is the second half of the statute's protection and is the part most consumers actually see.

The reminder is meant to arrive while there is still time to act. It generally must tell the consumer the date the contract will terminate and that it will renew automatically unless canceled, the length and any additional terms of the renewal period, and how to cancel. In practice, this gives a Vermont consumer a clearly timed opportunity to decide whether to keep the subscription or end it before the next term begins.

Section 2454a also addresses the exit. A covered seller or lessor must provide a toll-free telephone number, an email address, a postal address (if it bills the consumer directly), or another cost-effective, timely, and easy-to-use mechanism for canceling the contract. The intent is that ending a covered subscription should not be materially harder than starting it.

Where a consumer entered into the contract online, the statute contemplates that the consumer can cancel online as well, rather than being forced onto the phone or into the mail. If you are a Vermont consumer, the specific cancellation steps that apply to you should appear in your own contract and in the seller's renewal notice, so reviewing those documents is the practical starting point when you want to end a subscription.

A violation of § 2454a is treated as an unfair and deceptive act in commerce in violation of 9 V.S.A. § 2453, the central prohibition of Vermont's Consumer Protection Act. That link matters because it brings the Act's full enforcement toolkit into play rather than leaving § 2454a as a stand-alone rule with no teeth.

The Vermont Attorney General can enforce § 2453 violations, and the Consumer Protection Act also provides a private right of action under 9 V.S.A. § 2461. Remedies available under that framework can include actual damages, exemplary damages of up to three times actual damages, and reasonable attorney's fees. Since the law took effect, § 2454a has been a notable source of consumer class-action litigation in Vermont.

This page is general information about Vermont law, not legal advice. Statutes and their interpretation can change, and how § 2454a applies to any particular subscription depends on the facts. For a specific situation, consult the current statutory text or a licensed Vermont attorney.