Virginia's Automatic Renewal Law: a subscription cancellation guide

Part of: US state automatic renewal laws

Virginia has required affirmative consent and clear disclosures for auto-renewals since 2019. Amendments taking effect July 1, 2026 go further, adding a conspicuous online cancel option and a rule that cancelling be as easy as signing up.

A checklist to comply with Virginia's law

Audit your signup and cancel flow against these obligations.

What Virginia's Automatic Renewal Law requires

The rules live in Virginia Code Chapter 17.8.

1. Affirmative consent and disclosures

Before charging, present the auto-renewal terms clearly and get the customer's affirmative consent to them. This has applied since the law took effect in 2019.

2. A conspicuous online cancel option

From July 1, 2026, failing to offer a conspicuous online way to cancel a recurring purchase is prohibited.

3. Cancelling as easy as signing up

Cancellation must be at least as easy as the method used to subscribe, and available through every channel you offer for signup, except offers made in person. You cannot force customers through a live or virtual agent unless that was the only way they could sign up.

In practice, if a customer signed up online in two clicks, they should be able to cancel online just as fast.

Enforcement and the good-faith safe harbor

A violation is a prohibited practice under the Virginia Consumer Protection Act, which the Attorney General and individual consumers can enforce, with civil penalties for willful violations.

The law also builds in a safe harbor. A supplier that makes a good-faith effort to comply is not subject to the Act's civil penalties or damages for these provisions.

Put simply, if you make an honest effort to follow the rules, a mistake is unlikely to cost you a fine.

Who does it apply to?

It applies to businesses making automatic renewal or continuous service offers to consumers in Virginia, wherever the business is based.

How Churnkey helps you stay compliant and reduce churn

Churnkey offers a Cancel Flow that is compliant and retains customers, two outcomes that are hard to balance at once.

Getting started is easy, with an SDK, an embedded option, or a self-serve hosted page.

Churnkey's automatic compliance detects each customer's location and shows a conspicuous online cancel, as easy as signup, that Virginia requires.

We work with businesses across many states and countries, each with its own evolving rules, so we can help you configure flows that support compliance. Review the rules with your legal team and meet with ours to set up your flows.

Before a customer confirms, Churnkey can offer a pause or discount they are free to decline, and you can A/B test flows to find what saves revenue. On average, companies using Churnkey save 20 to 40% of the revenue they would otherwise lose to churn.

Churnkey is GDPR compliant and SOC 2 Type II certified.

FAQ

What is Virginia's Automatic Renewal Law?

A consumer protection law (Virginia Code Chapter 17.8) requiring affirmative consent and clear disclosures for auto-renewals since 2019. Amendments effective July 1, 2026 add an online cancel option and symmetrical cancellation.

What changes on July 1, 2026?

Businesses must offer a conspicuous online way to cancel, make cancellation at least as easy as signup, provide it through every signup channel except in-person, and not force customers through a live or virtual agent unless that was the only signup path.

Does it apply to my business?

If you make automatic renewal or continuous service offers to consumers in Virginia, yes, wherever your business is based.

How is it enforced?

A violation is a prohibited practice under the Virginia Consumer Protection Act, enforceable by the Attorney General and by individual consumers, with civil penalties for willful violations.

Is there a safe harbor if I make a mistake?

Yes. A supplier that makes a good-faith effort to comply is not subject to the Virginia Consumer Protection Act's civil penalties or damages for these auto-renewal provisions. You may still need to fix the issue.

Does a confirmation step or retention offer break the rules?

No. Virginia requires easy, symmetrical cancellation. It does not forbid a confirmation step or a relevant offer the customer can decline. Avoid anything that hides, blocks, or complicates completing the cancellation.

How can Churnkey help my business?

Churnkey provides a Cancel Flow that is as easy as signup, with a conspicuous online cancel and automatic compliance by location. You can present a fair offer before the customer confirms while leaving them free to cancel. We can help you configure flows that support compliance, but review the rules with your legal team.