United States of America: Consumer Online Payment Transparency and Integrity Act (SB 2266) was introduced to Senate

On 14 July 2025, the Consumer Online Payment Transparency and Integrity Act (SB 2266) was introduced in the United States Senate. The Act would establish requirements for disclosure and consent in contracts that involve automatic renewal, free-to-pay conversion, or negative option features. Sellers must inform consumers about renewal terms and provide accessible cancellation mechanisms, including online options and other cost-effective means such as toll-free phone numbers or email. They are required to obtain express informed consent before charging for renewals, particularly on an annual basis or when the consumer has not used the product or service for six consecutive months. In cases involving free trials, sellers must notify consumers before the trial ends and obtain explicit consent before charging. Furthermore, the Act establishes that consent obtained through dark patterns, defined as a user interface designed to subvert or impair user autonomy, is invalid. Finally, the Act empowers the Federal Trade Commission to enforce the obligations and issue rules to address unfair or deceptive practices related to automatic renewals.