What Does Minnesota's Automatic Renewal Law Require?

Key Takeaways

• Minnesota’s automatic renewal law, Minn. Stat. §§ 325G.56 to 325G.62, applies only to sales to consumers, meaning individuals buying for personal, family, or household purposes. It does not create a business-to-business notice regime.
• The core disclosure happens at the offer stage: the seller must present the “offer terms” clearly and conspicuously before the consumer accepts, under Minn. Stat. § 325G.57.
• After purchase, the seller must give a retainable confirmation of the terms, and email is expressly sufficient.
• There is no statutory pre-renewal reminder that must be sent within a set number of days before each renewal. A continuous-service arrangement instead requires an annual notice, and a long free trial requires a notice before the trial ends.
• Cancellation must be easy at any time, and the law prohibits abusive retention tactics under Minn. Stat. § 325G.58.

Who the Law Covers

The law regulates “indefinite subscription agreements,” which are subscription or purchasing agreements between a seller and a Minnesota consumer that are subject to automatic renewal or continuous service, under Minn. Stat. § 325G.56. An “automatic renewal” is an arrangement that renews at the end of a definite term for a further term. A “continuous service” arrangement is one that simply continues until the consumer cancels.

The statute reaches only consumer transactions. It defines a “consumer” as “any individual who seeks or acquires, by purchase or lease, any goods, services, money, or credit for personal, family, or household purposes.” A purchase by a business for business purposes falls outside this definition. Minnesota has no separate automatic renewal notice statute directed at business-to-business subscriptions, so a company selling a subscription service to other businesses is not subject to these particular requirements, though its general contract and disclosure obligations still apply.

Offer-Stage Disclosure

The central requirement is disclosure before the sale. Under Minn. Stat. § 325G.57, subdivision 1, a seller offering an indefinite subscription agreement must, before the consumer accepts the offer, present the “offer terms” in a clear and conspicuous manner and in visual proximity to the offer, or in temporal proximity when the offer is conveyed by voice.

The “offer terms” are defined in Minn. Stat. § 325G.56, subdivision 7, and include that the agreement continues until the consumer cancels, the cancellation policy that applies, the recurring charges and whether they may change, the length of any automatic renewal term or that the service is continuous, and any minimum purchase obligation. “Clear and conspicuous” means larger, contrasting, or set-off type that calls attention to the language, or an audible and understandable disclosure for audio.

Post-Purchase Confirmation

After the consumer accepts, the seller must provide a confirmation that the consumer can retain, under Minn. Stat. § 325G.57, subdivision 2. The confirmation must include the offer terms, information on how to cancel any free trial before charges begin, and the options for terminating the agreement. The statute states that communicating this information “through email is sufficient to meet the requirements of this subdivision,” so a retained email confirmation satisfies the obligation.

Advance Notice of Material Changes

If the terms of the agreement materially change, the seller must give the consumer clear and conspicuous notice before the change takes effect, along with information on how to cancel, under Minn. Stat. § 325G.57, subdivision 3. The consequence for skipping this step is significant. The statute provides that “a material change in the terms of an indefinite subscription agreement in violation of this subdivision is void and unenforceable.” A price increase or other material change imposed without the required advance notice cannot be enforced against the consumer.

Free Trial and Annual Notices

The statute has two timing-based notice requirements, and neither is a general pre-renewal reminder.

For a free trial that lasts more than 30 days, the seller must notify the consumer of the option to cancel before the trial ends. Under Minn. Stat. § 325G.57, subdivision 4, that notice must be sent “no fewer than five days and no more than 30 days before the end of any such free trial.”

For a continuous-service arrangement, the seller must give written notice of the continuous service “at least once per calendar year via mail or email,” and the notice must state the terms of the service and how to terminate or manage it, under Minn. Stat. § 325G.57, subdivision 5. This is an annual obligation, not a notice tied to each renewal date.

Easy Cancellation and No Abusive Tactics

The law requires that canceling be at least as easy as signing up. A consumer may terminate an agreement subject to automatic renewal at any time by following the procedure in the confirmation, under Minn. Stat. § 325G.59, subdivision 1. For a continuous-service arrangement, termination “must take effect no later than 31 days” from the consumer’s verified notice, under subdivision 2.

If the seller offers the subscription through a website with profile or subscription-management features, that website must include a clear and conspicuous “termination election,” a simple mechanism such as a checkbox or submission button that lets the consumer cancel online, under Minn. Stat. § 325G.60. If the seller fails to provide the required confirmation or annual notice, the consumer may cancel by any reasonable means at no cost, under Minn. Stat. § 325G.59, subdivision 3.

The statute also bars retention abuse. Under Minn. Stat. § 325G.58, a seller that receives a cancellation notice cannot use unfair or abusive tactics to delay or avoid the cancellation, and cannot push additional offers or contract modifications without the consumer’s permission, which the seller may request only once per cancellation attempt. The seller may still ask the reason for canceling, verify the consumer’s identity, explain the consequences of canceling, and describe options such as pausing or downgrading, provided the consumer is not required to answer as a condition of canceling.

Goods Sent Without Consent

If a seller ships goods under an indefinite subscription agreement without first obtaining the consumer’s affirmative consent, the goods are an unconditional gift. Under Minn. Stat. § 325G.61, the consumer “may use or dispose of the good in any manner without any obligation to the seller, including but not limited to any obligation relating to shipping of the good.”

Exemptions

Several categories of business are exempt. Under Minn. Stat. § 325G.62, sections 325G.56 to 325G.61 do not apply to contracts governed by another state or federal automatic renewal statute or regulation, insurance licensees and their affiliates, technology system contractors and power limited technicians licensed by the Department of Labor and Industry, businesses or affiliates regulated by the Public Utilities Commission, the Federal Communications Commission, or the Federal Energy Regulatory Commission, and persons or entities registered with FINRA, the SEC, or under the Minnesota Securities Act. There is no general “emergency service” exemption in the statute.

How the Law Is Enforced

The automatic renewal law does not contain its own schedule of fines. Instead, several consequences are built directly into the statute: an unnoticed material change is void and unenforceable, a prohibited right-of-first-refusal provision is void and unenforceable, and goods shipped without consent become an unconditional gift.

Beyond those self-executing consequences, the statute sits within Minnesota’s broader consumer-protection framework, which the Attorney General enforces under Minn. Stat. § 8.31. That statute authorizes the state to seek injunctive relief and civil penalties for unlawful business practices, and its private-remedies provision allows a person injured by a covered violation to bring a civil action for damages, costs, and attorney fees. Whether a particular automatic renewal violation falls within the Attorney General’s enumerated enforcement authority is a fact-specific legal question, so a business facing a claim, or weighing its exposure, should obtain advice on the specific conduct at issue. What the statute clearly does not create is a per-day or proportional fine schedule scaled to the length of a missed notice.

Residential Leases Are Governed Separately

Minnesota does have an automatic renewal notice rule with a fixed pre-renewal window, but it applies to residential leases, not to the general subscription law. Under Minn. Stat. § 504B.145, before a landlord can enforce an automatic renewal clause in a residential lease with an original term of two months or more, the landlord must give the tenant written notice directing attention to the renewal provision, served personally or by certified mail “at least 15 days, but not more than 30 days prior to the time that the tenant is required to furnish notice of an intention to quit.”

This lease rule is a common source of confusion. Its 15-to-30-day window applies to landlords and tenants, not to businesses selling subscriptions or services to consumers. The subscription statute in chapter 325G contains no comparable fixed reminder window.

The Myth: What Minnesota’s Subscription Law Does Not Require

A number of widely repeated claims about Minnesota’s automatic renewal requirements are not in the statute. A business relying on them may spend effort on obligations that do not exist while missing the ones that do.

• No fixed pre-renewal reminder window. The subscription law does not require a reminder sent within a set number of days before each renewal date. The only timing-specific notices are the free-trial notice before a long trial ends and the annual continuous-service notice. The 15-to-30-day figure belongs to the residential lease statute, not the subscription law.
• No mandatory menu of delivery channels. The statute does not prescribe hand delivery, fax, or an online portal as required channels. Email is expressly sufficient for the confirmation, and mail or email satisfies the annual continuous-service notice.
• No proportional civil fine schedule. The statute does not set graduated fines scaled to the severity or frequency of a violation. Its consequences are the void-and-unenforceable terms and the unconditional-gift remedy, alongside the general consumer-protection enforcement framework.
• No general nonprofit-membership or business-to-business coverage. The law reaches consumer purchases for personal, family, or household purposes. It is not a general nonprofit or business-to-business notice regime, though a nonprofit selling to individual consumers can still fall within the consumer definition.

Practical Compliance Steps for Businesses

A business selling subscriptions or other renewing agreements to Minnesota consumers can align with the statute through a focused set of practices:

• Present the required offer terms clearly and conspicuously on the checkout or sign-up screen, before the consumer commits.
• Send a retainable confirmation, which can be an email, that repeats the offer terms and explains how to cancel.
• Give advance notice of any material change before it takes effect, and keep records of that notice, since an unnoticed change is unenforceable.
• Send the free-trial notice for any trial longer than 30 days, and the annual notice for continuous-service arrangements.
• Build a simple online cancellation path if the service is sold through a subscription-management website, and train staff not to use retention scripts that delay or obstruct a cancellation.

These steps track the statute’s actual requirements. For a business whose agreements sit near the edge of the consumer definition, or that operates across multiple states with differing automatic renewal laws, a review of the specific terms and sign-up flow is worthwhile before launch.

Frequently Asked Questions

Does Minnesota require a reminder notice before every subscription renewal?

No. Minnesota’s automatic renewal law does not require a reminder sent within a set number of days before each renewal date. The only date-specific notices are a notice before a free trial longer than 30 days ends, sent no fewer than five and no more than 30 days beforehand, and an annual notice for continuous-service arrangements. The 15-to-30-day pre-renewal window that some sources describe comes from the separate residential lease statute, Minn. Stat. § 504B.145.

Does the law apply to business-to-business subscriptions?

The statute applies to consumer transactions, meaning purchases by an individual for personal, family, or household purposes, under Minn. Stat. § 325G.56. A subscription sold to a business for business use is not covered by these particular requirements. General contract and disclosure principles still govern the agreement.

Is email a sufficient way to send the required notices?

Yes for the notices the statute addresses. Email is expressly sufficient for the post-purchase confirmation under Minn. Stat. § 325G.57, subdivision 2, and the annual continuous-service notice may be sent by mail or email under subdivision 5. The statute does not require hand delivery, fax, or a portal.

What happens if a business raises the price without proper notice?

A material change made without the required advance notice is void and unenforceable under Minn. Stat. § 325G.57, subdivision 3. That means the seller cannot enforce the changed term against the consumer. Giving clear and conspicuous notice before the change takes effect, and keeping proof of it, avoids this outcome.

Are there exemptions for regulated industries?

Yes. Under Minn. Stat. § 325G.62, the requirements do not apply to insurance licensees and their affiliates, certain technology system contractors and power limited technicians, businesses regulated by the Public Utilities Commission, the Federal Communications Commission, or the Federal Energy Regulatory Commission, securities registrants, and contracts governed by another automatic renewal statute. There is no general emergency-service exemption.