Minnesota Automatic Renewal Law: Notice Requirements

Key Takeaways

• Minnesota’s automatic renewal law (Minnesota Statutes sections 325G.56 to 325G.62) took effect January 1, 2025.
• You must present the renewal or continuous-service terms clearly and conspicuously before the consumer signs up, then confirm them in a form the consumer can keep.
• For a service that continues until cancelled, you must send a written notice by mail or email at least once per calendar year.
• A free trial longer than 30 days requires a cancellation reminder no fewer than five days and no more than 30 days before the trial ends.
• If your website manages subscriptions, it must include a simple online termination election, and noncompliance can void terms, turn shipped goods into gifts, and let the consumer cancel for free.

What Minnesota’s Automatic Renewal Law Covers

Minnesota Statutes section 325G.56 defines the terms that control the entire statute. An “indefinite subscription agreement” is any subscription or purchasing agreement between a seller and a Minnesota consumer that is subject to automatic renewal or continuous service. A “consumer” is an individual who acquires goods or services for personal, family, or household purposes, so the statute is aimed at consumer subscriptions rather than purely commercial deals. If your customers are other businesses, analyze whether a given arrangement still reaches a consumer before assuming the statute does not apply. For a closer look at renewal terms between companies, see automatic renewal clauses in business-to-business contracts.

The law separates two arrangements, and the difference controls several later obligations:

Arrangement	Definition (Minn. Stat. 325G.56)	Practical example
Automatic renewal	Renews at the end of a definite term for a subsequent term unless the consumer cancels	An annual membership that rolls into another year
Continuous service	Continues until the consumer terminates it	A month-to-month streaming or software plan

Disclosures You Must Make Before the Customer Signs Up

Section 325G.57, subdivision 1, requires you to present the “offer terms” in a clear and conspicuous manner before the consumer accepts, positioned in visual proximity to the offer (or, for a voice offer, in temporal proximity). Section 325G.56, subdivision 7, defines exactly what those offer terms are, and all of them must appear up front:

Required offer term	What you must disclose (Minn. Stat. 325G.56, subd. 7)
Ongoing nature	That the agreement continues until the consumer terminates it
Cancellation policy	A description of the cancellation policy that applies
Recurring charges	The recurring amounts charged, that the amount may change, and the amount it will change to if known
Length or continuity	The length of the automatic renewal term, or that the service is continuous, unless the term is definite and chosen by the consumer
Minimum obligation	The minimum purchase obligation, if any

“Clear and conspicuous” is a defined standard under section 325G.56, subdivision 3: the disclosure must be in larger or contrasting type, or set off in a way that calls attention to the language. Burying these terms in dense boilerplate does not satisfy the law. For a deeper walkthrough of the disclosure mechanics, see Minnesota’s statutory requirements for automatic renewal notices.

Confirmation After the Customer Signs Up

Section 325G.57, subdivision 2, requires timely confirmation after the consumer accepts, provided in a form the consumer can retain. The confirmation must include the offer terms, information on how to cancel any free trial before payment where applicable, and termination options that are easy to use, cost-effective, and timely. If you sell through an online website, the confirmation must point to the online termination election described in section 325G.60. For agreements formed outside a website, you must offer a cancellation option that is at least as easy to use and as accessible as the method the consumer used to sign up. Email communication satisfies these confirmation requirements.

Free Trials Longer Than 30 Days

Section 325G.57, subdivision 4, sets a specific reminder for longer free trials. If your offer includes a free trial lasting more than 30 days, you must notify the consumer no fewer than five days and no more than 30 days before the trial ends of the option to cancel before the trial period closes, so the consumer can avoid an obligation to pay. There is no equivalent fixed reminder tied to each ordinary renewal term.

The Once-a-Year Notice for Continuous Service

For a service that simply continues until the consumer cancels, Minnesota adds a recurring reminder. Section 325G.57, subdivision 5(a), states:

“If an indefinite subscription agreement is subject to continuous service, the seller must give the consumer written notice of the continuous service at least once per calendar year via mail or email.”

In plain terms: if the subscription keeps going until the customer stops it, send at least one written reminder every calendar year, by mail or email. Under subdivision 5(b), that notice “must include the terms of the service and how to terminate or manage the service.” This annual notice is the closest thing Minnesota has to a standing renewal reminder, and it applies only to continuous-service arrangements, not to fixed-term automatic renewals.

Notice Before a Material Change

Section 325G.57, subdivision 3, governs changes you make after the consumer is already enrolled. Before you implement any material change to the terms, you must give the consumer clear and conspicuous notice of the change and explain how to terminate the agreement, in a form the consumer can keep. The statute enforces this with a blunt consequence: “A material change in the terms of an indefinite subscription agreement in violation of this subdivision is void and unenforceable.” A price increase or term change pushed through without proper notice does not bind the consumer. For related enforceability risks, see when auto-renewal clauses become unenforceable in Minnesota.

Making Cancellation Easy: The Termination Election

Minnesota puts real weight on frictionless cancellation. Under section 325G.60, if you operate a website with profile or subscription management capabilities, that website must include a termination election. The statute defines a termination election as “a simple and easily accessible means for a consumer to quickly provide notice of termination,” free of “undue complexity, confusion, or misrepresentation.” In practice, that means a checkbox, a submission button, or a similarly common and simple mechanism, presented in straightforward language, that lets the consumer end the agreement at any time. You may only request the information actually necessary to process the termination.

Section 325G.59 sets when a cancellation takes effect. A consumer may terminate an automatic-renewal agreement at any time, and the termination becomes effective at the end of the current term, unless the consumer chooses a later date and you offer that option. For a continuous-service agreement, termination must take effect within 31 days of the consumer’s verified notice, or on a future date the consumer specifies.

Conduct the Law Prohibits

Section 325G.58 bars several retention and billing tactics:

• You must not charge the consumer’s card or third-party payment account before the agreement is authorized by both parties and made effective.
• You must not require the consumer to let you match a competing offer as a condition of the agreement. Any right-of-first-refusal clause that does so is void and unenforceable.
• Once a consumer gives notice to cancel, you must not use any misrepresentation or unfair or abusive tactic to delay or avoid the cancellation, and you must not present save offers, modifications, or gifts unless the consumer agrees to hear them after giving notice. You may ask for that permission only once per cancellation attempt.

The statute expressly still allows you to ask why the consumer is leaving (without requiring an answer), explain the consequences of cancelling, verify the consumer’s identity, or describe options to downgrade, pause, or suspend the service.

What Happens If You Do Not Comply

Minnesota built the consequences directly into the statute, and several of them fall on the business automatically:

• A material change made without the notice required by section 325G.57, subdivision 3, is void and unenforceable, so you cannot collect on it.
• Under section 325G.61, any good you send under an indefinite subscription agreement without first obtaining the consumer’s affirmative consent becomes an unconditional gift. The consumer may keep or dispose of it with no obligation to you, including no obligation to pay for shipping.
• Under section 325G.59, subdivision 3, if you never provided the required confirmation or the annual continuous-service notice, the consumer may terminate by any reasonable means at any time, at no cost, including by mail, email, telephone, an online option, or the same method used to enter the agreement.

Because these remedies make noncompliant terms unenforceable and hand consumers a free exit, the practical cost of skipping the disclosures usually exceeds the effort of building them in.

Who Is Exempt

Section 325G.62 exempts several categories from sections 325G.56 to 325G.61:

• Contracts already governed by another state or federal statute or regulation specifically intended to regulate automatic renewal or continuous service.
• Insurance licensees under section 60A.985, subdivision 8, and their affiliates.
• Individuals or businesses licensed by the Department of Labor and Industry as a technology system contractor or power limited technician under section 326B.31.
• Services provided by a business or affiliate licensed or regulated by the Public Utilities Commission, the Federal Communications Commission, or the Federal Energy Regulatory Commission.
• Persons or entities registered or licensed with the Financial Industry Regulatory Authority, the Securities and Exchange Commission, or under the Minnesota Securities Act.

If you fall into one of these categories for a given product, confirm the scope carefully. An exemption for one line of business does not automatically cover every subscription you sell.

Building a Compliant Subscription Flow

If you sell recurring services to Minnesota consumers, a short compliance checklist keeps you inside the statute:

• Put the five offer terms in front of the customer, clearly and conspicuously, before checkout.
• Send a retainable confirmation (email is fine) that repeats the terms and explains how to cancel.
• Build a plain online termination election if your site manages subscriptions.
• Calendar the annual continuous-service notice and any free-trial reminder so they actually go out.
• Give advance notice before any price or term change, and keep records of every disclosure you send.

Aaron Hall advises Minnesota business owners on subscription and contract compliance, and a short review of your sign-up and cancellation flow is far cheaper than defending an unenforceable renewal.