Virginia Subjects Auto-Renewal/Continuous Service Suppliers to Consumer Protection Laws

SB 184 signed by Virginia Gov. Spanberger on April 4, 2026, will subject shippers/suppliers of automatically renewing or continuous service offers for goods or services to Virginia Consumer Protection law unless they communicate with consumers in a timely electronic or other manner. The information required to be relayed to consumers is 1) shipping charges, if any; 2) whether returns are accepted and how to return the items; and 3) how to cancel an automatic renewal/continuous offer. With industry input, this bill was beneficially amended after being introduced with language creating per se violations of Virginia consumer protection laws. As passed into law, shippers/suppliers that provide such information about purchases in a timely electronic or other readily available means are exempt from the Virginia law. This new law is in line with the Federal Trade Commission’s Rule Concerning Recurring Subscriptions and Other Negative Options Programs which revised the FTC’s Negative Option Rule challenged in federal court. States like California and Virginia have begun adopting their own similar renewal notice/cancellation policies.