Ask people what they spend on subscriptions and they'll guess about $86 a month. When researchers had them actually add it up, the real number was $219 — a blind spot of roughly $1,600 a year. And 42 percent admitted they were still paying for something they'd stopped using and forgotten about.
That gap is not an accident of human forgetfulness. It's the business model. Auto-renewal is a machine for converting your inertia into somebody's revenue, and the whole game is friction: sign-up takes one click, cancellation takes a phone tree, a "are you sure," a "here's 30% off to stay," and a chat window that opens only during business hours in a time zone that isn't yours. The industry even has a name for it — the "roach motel." Easy in, engineered to be hard out.
Here's the good news most Minnesotans missed: as of January 1, 2025, that's illegal in Minnesota. And the story of how we got there is a small master class in why state law matters.
The federal rule died — in the court that covers us
In October 2024, the Federal Trade Commission finalized a national "click to cancel" rule: if you could subscribe online, you had to be able to cancel online, just as easily. It was set to take effect in the spring of 2025.
It never did. The Eighth Circuit Court of Appeals — the federal court whose jurisdiction includes Minnesota — struck the rule down on July 8, 2025, six days before its compliance date. The court didn't rule that click-to-cancel is bad policy; it vacated the rule on a procedural defect, finding the FTC had skipped a required economic analysis. But the effect was the same. Federal protection reverted to a 1973 regulation written for mail-order book-and-record clubs — which is to say, no meaningful federal click-to-cancel rule exists today.
So the very court that covers Minnesota killed the national rule. Which is exactly why it matters that Minnesota had already passed its own — and ours is still standing.
What Minnesota's law actually requires
Minnesota's automatic-renewal law (Minn. Stat. §§ 325G.56–325G.63) is modeled on California's, the country's strongest, and it is far more specific than most people realize. If a company auto-renews you or runs a continuous subscription, here is what it now owes you:
- The terms have to be in your face before you agree — clear, conspicuous, right next to the button you click, not buried in a linked agreement nobody reads.
- Cancellation has to be as easy as sign-up. If you subscribed online, the law requires a "termination election" on the website — a checkbox or button, plain language, asking only for the information actually needed to cancel. No phone-only cancellation for a service you joined with a click.
- The retention gauntlet is capped. This is my favorite provision, because it targets the exact tactic that enrages people. Once you say you want to cancel, a company may not use "unfair or abusive tactics to delay or avoid the cancellation," and it may pitch you a save-offer or a discount only once per cancellation attempt. The endless "wait, before you go —" wall is now against Minnesota law.
- Free trials over 30 days must warn you before they bill you — a reminder no fewer than five and no more than 30 days before the trial ends.
- Long subscriptions get an annual reminder — once a year, in writing, telling you the terms and how to cancel.
- And if they didn't get your real consent, the stuff is a gift. Goods shipped under a subscription you never affirmatively agreed to are, by statute, an "unconditional gift" — keep them, owe nothing, not even return shipping.
Every one of those maps to a tactic you've personally been subjected to. That's what makes it a good law: it was written by people who had actually tried to cancel something.
The tactics it bans are real, and measured
This isn't theoretical annoyance. A Princeton study that crawled 11,000 shopping websites found dark patterns on 11.6 percent of them — 1,818 instances of manipulative design — and identified companies selling those manipulations as a turnkey service. The Norwegian Consumer Council documented the asymmetry precisely: accept is one click; opt out is buried menus deep.
And the enforcers have started treating it as fraud, not friction. The FTC took Amazon to a jury trial in 2025 over a Prime cancellation flow the company internally code-named "Iliad" — after the long war — and Amazon settled mid-trial for a reported $2.5 billion, including $1.5 billion in refunds to consumers. The Justice Department sued Adobe over a cancellation obstacle course that hid a steep early-termination fee. There are live federal cases against Uber, and others, over the same thing. The tide of complaints is what drove the (doomed) federal rule in the first place — the FTC logged roughly 70 negative-option complaints a day in 2024, up from 42 a day in 2021.
The honest weakness — and why I'd fix it
Now the part this series requires me to tell you, because a law you can't enforce is the fine-print problem wearing a friendlier face.
Minnesota's statute has a soft spot. Its enforcement section does just one thing: it gives sellers a "good-faith" safe harbor — no civil penalties if the company "made a good faith effort to comply." It does not, inside the chapter itself, create a clear penalty, name the Attorney General, or spell out a private right of action. Enforcement has to ride on Minnesota's general consumer-fraud enforcement law — and that statute's list of covered laws does not specifically name this one, which makes a private lawsuit under it a live legal question rather than a sure thing.
Translated: the rights are strong, but the teeth are modest, and there is no visible record of anyone enforcing this law in its first year and a half. That's the same pattern I keep finding across Minnesota government — a good statute passed, then left to sit. A right nobody enforces is a suggestion.
What we can do
Use your rights — they're better than you think. If you subscribed to something in Minnesota online and the only way to cancel is a phone call during business hours, that likely violates state law now. If a cancellation flow throws three retention offers at you, that's the tactic the statute caps at one. Push back, in writing, and cite the law.
Do a subscription audit this week. The average person is losing $133 a month to services they've forgotten. That's not the company's cleverness; it's a checkup you haven't done. Pull your card statement, find the ghosts, and cancel them — the law now says you're allowed to do it the easy way.
And give the law teeth. The Legislature should amend the statute to name it in the consumer-fraud enforcement chapter, create a clear penalty, and confirm a private right of action so an ordinary Minnesotan — not just the Attorney General — can enforce it. The good-faith safe harbor can stay; honest sellers deserve it. But "good faith" shouldn't be a synonym for "no one's watching." The People's Lawyer should bring the first case, and publish it, so every subscription company in Minnesota knows the law is real.
Minnesota did the hard part — it wrote one of the best click-to-cancel laws in the country while the federal version was dying in our own appeals court. Now let's make it bite, and in the meantime, go cancel the thing you forgot you're paying for.
First the facts. Then the fix.
Sources
Minnesota's automatic-renewal law, Minn. Stat. §§ 325G.56–325G.63, verified verbatim against raw text at revisor.mn.gov — including the up-front clear-and-conspicuous disclosure and affirmative-consent requirements (§ 325G.57), the prohibition on abusive tactics to delay cancellation and the once-per-attempt limit on retention offers (§ 325G.58, subd. 4), the online "termination election" requirement and its checkbox/button standard (§ 325G.60), the requirement that cancellation be as easy and accessible as sign-up (§ 325G.57, subd. 2), the free-trial reminder window and the annual continuous-service notice, the unconditional-gift remedy (§ 325G.61), the exemptions (§ 325G.62, which do not cover streaming, gyms, software, or subscription boxes), and the good-faith safe harbor that is the chapter's only internal enforcement provision (§ 325G.63); the January 1, 2025 effective date per 2024 Minn. Laws ch. 114, art. 3; and Minn. Stat. § 8.31, subds. 1 and 3a, which do not specifically enumerate chapter 325G, making a private-attorney-general action under it an open interpretive question. Custom Communications, Inc. v. FTC, Nos. 24-3137 and 24-3388 (8th Cir.), argued June 10 and decided July 8, 2025, vacating the FTC's Negative Option "Click-to-Cancel" Rule on Administrative Procedure Act grounds six days before its deferred July 14, 2025 compliance date, returning the field to the 1973 negative-option regulation — verified via CourtListener (the exact Federal Reporter page cite was not yet populated and is treated as unconfirmed). California Automatic Renewal Law, Cal. Bus. & Prof. Code §§ 17600–17606, and its 2024 amendment (AB 2863), the model Minnesota's law follows, verified via the California legislature's site. FTC v. Amazon.com (W.D. Wash. No. 2:23-cv-00932), the "Iliad" Prime cancellation case that went to jury trial and settled in September 2025 (the reported $2.5 billion structure is from the FTC's public announcement); United States v. Adobe (N.D. Cal. No. 5:24-cv-03630) — dockets verified via CourtListener; related pending FTC subscription cases against Uber and others. Princeton "Dark Patterns at Scale" (Mathur et al., 2019) — dark patterns found on 11.6 percent of 11,000 shopping sites; Norwegian Consumer Council, "Deceived by Design" (2018). C+R Research subscription survey (2022) — the $86 estimated versus $219 actual monthly spend and the 42 percent forgotten-subscription figure. FTC negative-option complaint volume (roughly 70 per day in 2024 versus 42 per day in 2021) from the FTC's rulemaking record.
No public Minnesota enforcement action under §§ 325G.56–.63 could be located in its first year and a half, and none is asserted; several settlement dollar figures are from agency announcements rather than pulled from the primary orders and are flagged as such. Corrections: campaign@madgettformn.com.