The Consumer Online Payment Transparency and Integrity Act aims to protect consumers from deceptive practices related to automatic renewal contracts and free trials. It requires sellers to clearly and conspicuously disclose automatic renewal features and cancellation procedures in contracts, ensuring consumers are fully aware of ongoing commitments. For automatically renewing contracts, sellers must notify consumers at least seven days before each renewal, providing clear instructions for cancellation, including an online mechanism and other accessible methods. Furthermore, sellers must obtain the consumer's express informed consent annually before charging for renewals. If a consumer has not used the service for six consecutive months after their last consent, new consent is required, and they must be informed of their right to terminate and receive a prorated refund. Regarding free trials, the bill mandates that consumers be notified at least seven days before the trial ends that they will be charged, along with cancellation instructions. Sellers must also obtain the consumer's express informed consent before charging them after the free trial period concludes. Crucially, consent obtained through "dark patterns," which subvert user autonomy, is explicitly deemed invalid. Violations of these provisions render the automatic renewal void, terminate the contract, and obligate the seller to refund all amounts paid due to the violation. The Federal Trade Commission (FTC) is tasked with enforcing this Act, treating violations as unfair or deceptive acts or practices under existing law and having the authority to promulgate necessary rules.
Consumer Online Payment Transparency and Integrity Act
USA119th CongressS-2266| Senate
| Updated: 7/14/2025
The Consumer Online Payment Transparency and Integrity Act aims to protect consumers from deceptive practices related to automatic renewal contracts and free trials. It requires sellers to clearly and conspicuously disclose automatic renewal features and cancellation procedures in contracts, ensuring consumers are fully aware of ongoing commitments. For automatically renewing contracts, sellers must notify consumers at least seven days before each renewal, providing clear instructions for cancellation, including an online mechanism and other accessible methods. Furthermore, sellers must obtain the consumer's express informed consent annually before charging for renewals. If a consumer has not used the service for six consecutive months after their last consent, new consent is required, and they must be informed of their right to terminate and receive a prorated refund. Regarding free trials, the bill mandates that consumers be notified at least seven days before the trial ends that they will be charged, along with cancellation instructions. Sellers must also obtain the consumer's express informed consent before charging them after the free trial period concludes. Crucially, consent obtained through "dark patterns," which subvert user autonomy, is explicitly deemed invalid. Violations of these provisions render the automatic renewal void, terminate the contract, and obligate the seller to refund all amounts paid due to the violation. The Federal Trade Commission (FTC) is tasked with enforcing this Act, treating violations as unfair or deceptive acts or practices under existing law and having the authority to promulgate necessary rules.