Connecticut Creates a Private Right of Action for Automatic Renewals

In June of 2025, the governor of Connecticut signed Senate Bill 3, known as “An Act Concerning Consumer Protection and Safety.” The bill revisions will go into effect on July 1, 2026. For sellers that utilize autorenewals, the main focus of this bill is Section 7, which allows for a private right of action against businesses for violations of automatic renewal laws, now considered an unfair trade practice. A key sentence is being removed from the bill that significantly changes the legal landscape for enforcement: “Nothing in this section shall be construed to create a private right of action.” By striking this language, the legislation opens the door for consumers to pursue private lawsuits against companies that engage in unfair or deceptive telemarketing practices.

Connecticut SB 3 also introduces an annual reminder provision to automatic renewal laws. The bill states, “Beginning on July 1, 2026, 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 concerning the automatic renewal provision or continuous services provision.” The annual reminder must be sent the same way the automatic renewal provision was activated, or by the means in which the consumer is accustomed to interacting with the business. The annual reminders must include:

1. A statement identifying (i) the consumer goods or consumer services that are subject to the automatic renewal provision or continuous services provision, and (ii) the means by which the consumer may prevent automatic renewal or prevent or terminate continuous consumer services; and
2. The frequency and amount of charges associated with automatic renewal of, or provision of continuous consumer services under, the consumer agreement.

Businesses must allow consumers to cancel their automatic renewal subscriptions, and it is unlawful to make it more difficult than the means of signing up. Each business that enters into automatic renewal agreements with consumers must enable a consumer to terminate the renewal via three main avenues:

1. A prominently displayed link located in the consumers profile or user settings
2. An email message from the business to the consumer, to which the consumer may reply without obtaining any additional information; or
3. A telephone number that is clearly and conspicuously displayed on the web site maintained by such business.

Businesses must promptly answer all calls made to such telephone number during normal business hours. If any consumer leaves a voicemail, businesses have one business day to either process the requested termination or return the consumer’s telephone call.

Connecticut continues the trend of states imposing more restrictive auto-renewal rules to deter misleading marketing practices. Staying up to date on developments in federal and state regulations can be a complex and time-consuming task. CompliancePoint has a team of marketing compliance professionals that can take compliance monitoring off your plate. Reach out to us at connect@compliancepoint.com to learn more about our services.