Your subscription stack sends a notice when it charges. Connecticut now wants one when nothing is happening.
Since July 1, 2026, Connecticut General Statutes 42-158ff(d) has required this: "each business that enters into a consumer agreement that includes an automatic renewal provision or a continuous services provision shall send to the consumer an annual reminder". Public Act 25-44 added it, and the Attorney General announced it on July 16.
Subscription stacks are built around events: an upcoming charge, a failed card, a shipped box, a price change. An annual reminder is not tied to any of those. It is a send on a calendar, per subscriber, for as long as the subscription lives. If nobody built that trigger, it does not exist.
This post reads the amended section as Connecticut prints it, sets it beside California's version, and ends on what to build. Nothing here is legal advice.
What does the reminder have to contain?
Subsection (d)(2) asks for three things:
- a statement identifying "the consumer goods or consumer services that are subject to the automatic renewal provision or continuous services provision";
- "the means by which the consumer may prevent automatic renewal or prevent or terminate continuous consumer services, as set forth in subsection (e)";
- "the frequency and amount of charges".
Subsection (d)(1) sets the channel. The reminder goes out "in the same manner in which such automatic renewal provision or continuous services provision was activated" when activation was not in person, or by the means the customer "is accustomed to interacting with such business" by email, mail or telephone. A membership sold at a front desk gets its reminder by email, mail or telephone.
The statute does not say which day of the year the reminder goes out, or whether the year counts from signup or from July 1, 2026. It says "annual" and "beginning on July 1, 2026". Pick a rule you can defend, write it down and apply it to every Connecticut subscriber.
Doesn't California already require this?
It does, and the two are close. California Business and Professions Code 17602(h) requires "an annual reminder" disclosing the product or service, "the frequency and amount of charges", and "the means to cancel", sent in the same medium that activated the subscription or the one the customer is accustomed to. It applies to contracts entered into, amended or extended on or after July 1, 2025.
The difference is who gets it. California's duty is to send it "to a consumer under an annual automatic renewal agreement or continuous service agreement". The statute does not define an annual automatic renewal agreement. Read narrowly, the subdivision is an annual plan rule, and a reminder built to that reading goes to the yearly subscribers and skips the monthly ones.
Connecticut's version has no "annual" in front of the agreement. It reaches every consumer agreement with an automatic renewal provision or a continuous services provision. An automatic renewal provision is one under which the business "may renew such agreement without any action on the part of a consumer", and a continuous services provision is one under which it "may continue to provide consumer services" until the consumer acts. A monthly subscribe and save plan carries one or the other, whatever your app calls it.
Who counts as a Connecticut customer?
The statute defines a consumer as "any individual who is a resident of this state". Your stack does not know residence. It knows a billing address and a shipping address, so you will be using one of them as a proxy. Choose which, and remember the subscriber who moves.
The section also only reaches agreements "initially entered into or amended on or after October 1, 2023". A subscriber from 2022 whose agreement has never been amended may sit outside it. Whether a price change or a swapped product counts as an amendment is a question for counsel. Sending the reminder to every Connecticut subscriber is simpler than proving who did not need it.
The exclusions in subsection (a)(4) cover municipal franchises, businesses regulated by PURA, the FCC or FERC, insurance entities, banks and credit unions, and "any global or national service largely or predominately consisting of audiovisual content". A supplement box, a skincare refill or a GLP-1 program is none of those.
What else changed on July 1?
Cancellation moved to subsection (e) and grew. A business that contracts online must let the consumer cancel "online and without requiring such consumer to take any offline action", by at least one of "a prominently displayed direct link or button" in the account, profile or device settings, or an email "to which the consumer may reply without obtaining any additional information". A telephone number "clearly and conspicuously displayed" on your website is a third permitted method under (e)(2)(C), but for an online contract it sits alongside the online route rather than replacing it. The history note records that "toll-free" was deleted from the list of contact methods in (b)(1)(A).
The phone line comes with duties. If you keep a number for cancellation, (e)(3)(A) says you "shall promptly answer all calls made to such telephone number during normal business hours", and a voicemail has to be processed or returned "not later than one business day" after it is left.
The save offer on the phone is allowed, on a condition. Subsection (e)(3)(B) lets you present "a discounted offer, retention benefit or information regarding the effect of the requested prevention or termination", provided you first tell the caller, "clearly and conspicuously", that they can finish at any time by saying "cancel". The statute says nothing that specific about a save offer on a web cancel page. What covers the web is (e)(4): no business "shall take any action to obstruct or delay" a cancellation. New York City wrote a save offer clause of its own into its rule. Connecticut wrote one for the phone and left the web to the general obstruction duty.
Login before cancelling is still allowed, under (e)(5), but a customer who will not or cannot authenticate online may not be stopped from cancelling offline. That is the same shape as Georgia's 10-1-439.8(b).
The Attorney General's release summarises the cancellation rules as: "If the business does not have an online platform, it must provide a phone number". The statute is broader than that sentence. Read (e) itself.
What happens if you get it wrong?
Until July 1, the section ended with subsection (e): "Nothing in this section shall be construed to create a private right of action." Public Act 25-44 deleted it. In its place is a new subsection (f): "Any violation of the provisions of this section shall constitute an unfair trade practice under subsection (a) of section 42-110b."
That routes the section into the Connecticut Unfair Trade Practices Act. Under 42-110g(a), "any person who suffers any ascertainable loss of money or property, real or personal" from a practice prohibited by 42-110b may sue "to recover actual damages", and "the court may, in its discretion, award punitive damages". Costs and reasonable attorneys' fees are in 42-110g(d). On the state's side, in an enforcement action under 42-110m, 42-110o(b) lets the Attorney General recover a civil penalty of up to $5,000 for each wilful violation.
Whether a missing reminder alone produces an ascertainable loss is a question for counsel, not for a blog. The direction of travel is not.
What to build
- A Connecticut flag on every subscriber. Decide whether billing or shipping address is your proxy for residence and store it where the email platform can read it.
- A scheduled annual send, not an event send. Store a reminder due date on each subscriber profile, trigger the send from that date, and roll it forward a year each time the reminder goes out.
- A template with the three statutory items. The product or service by name, the frequency and the amount of the charge as it stands today, and the cancellation method you actually offer under (e), with the link.
- Channel matching. The reminder goes "in the same manner" the subscription was activated, so record how each one was activated. Subscriptions sold in person get email, mail or a call.
- A log. Keep a record of each reminder sent, to whom, when and with what content. Under CUTPA, the evidence you have is the defence you have.
- A cancel path that matches (e). If your California and New York flows already put a direct link or button in the account, you are most of the way there. If you list a phone number for cancellation, staff it to the one business day voicemail rule.
If you already send California's reminder, widen it rather than building a second one. The contents are near identical, so one template keyed to state and plan type can carry both, and it should not exclude monthly plans in Connecticut.
The work sits between the subscription app, the email or SMS platform and the customer account. It is the kind of pass we do in CPG and ecommerce website development and in Shopify and WordPress development. For the baseline rules most stacks were built to, start with what a subscription flow still needs after click-to-cancel was vacated.
This is operational guidance, not legal advice. Automatic renewal law differs by state and city and keeps changing. Have qualified counsel review your notices, your consent capture and your cancellation flow before you change them.
Common questions
What does Connecticut's annual reminder have to say?
Conn. Gen. Stat. 42-158ff(d)(2), as amended by Public Act 25-44 and in force since July 1, 2026, requires the reminder to identify the goods or services subject to the automatic renewal or continuous services provision, the means by which the consumer may cancel as set out in subsection (e), and the frequency and amount of charges. It must go out in the same manner in which the subscription was activated, unless the subscription was activated in person, in which case it goes by email, mail or telephone.
Does Connecticut's annual reminder apply to monthly subscriptions?
Yes. Subsection (d)(1) applies to each business that enters into a consumer agreement that includes an automatic renewal provision or a continuous services provision. It does not limit the duty to annual terms. A monthly subscribe and save plan carries either an automatic renewal provision or a continuous services provision under the statute's definitions, so its Connecticut subscribers are owed a reminder once a year like everyone else.
If my stack already sends California's annual reminder, am I covered in Connecticut?
Possibly for content, not necessarily for scope. California Business and Professions Code 17602(h) asks for the same three items, the product or service, the frequency and amount of charges, and the means to cancel. But it applies to a consumer under an annual automatic renewal agreement or continuous service agreement, a phrase the statute does not define, and a reminder built to the narrow reading covers annual plans only. Connecticut's text carries no annual qualifier. If your California reminder only fires for annual plans, Connecticut's monthly subscribers are not getting one.
Can a customer sue under Connecticut's automatic renewal law now?
The section used to say it created no private right of action. Public Act 25-44 deleted that subsection and added subsection (f), under which any violation is an unfair trade practice under section 42-110b. The Connecticut Unfair Trade Practices Act, at 42-110g(a), lets a person who suffers an ascertainable loss of money or property from a prohibited practice sue for actual damages, and the court may award punitive damages and equitable relief. Costs and reasonable attorneys' fees are available separately under 42-110g(d). This is not legal advice; have counsel read it against your facts.
Do I need a cancellation phone line for Connecticut customers?
Not necessarily. A business that contracts online must let the customer cancel online, by a prominently displayed direct link or button or by a reply-able email. A telephone number is a third permitted method. If you choose to offer one for cancellation, 42-158ff(e)(3) requires you to answer calls promptly during normal business hours and to act on a voicemail within one business day, and it lets you present a save offer on that call only after telling the caller they can finish by saying cancel.
Sources
- Connecticut General Statutes, 2026 Supplement, chapter 742d, section 42-158ff as amended by P.A. 25-44 section 7, effective July 1, 2026, including the history note checked 2026-10-26
- Connecticut General Statutes, chapter 735a, CUTPA, sections 42-110b, 42-110g and 42-110o checked 2026-10-26
- Connecticut Attorney General, Attorney General Tong Highlights New Click to Cancel Consumer Protections Now in Effect, July 16, 2026 checked 2026-10-26
- California Business and Professions Code 17602, including subdivision (h), the annual reminder, and subdivision (j) checked 2026-10-26
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