Checkout disclosure and consent would pass in all eight states reviewed. Every finding is post-sale: cancellation, renewal notice, and retention sequencing. The two that matter most, California and Virginia, share a single root cause and a single fix. Nothing here requires leaving Shopify or Recharge.
Of eight states, California and Virginia hold both high-severity findings. Fix those and the risk profile changes materially.
Disclosure and consent are the parts most merchants get wrong. Yours are compliant. The gaps are all after the customer has paid.
Four of five gaps close with three Recharge settings and one Shopify template edit. No platform change, no engineering project.
| Jurisdiction | California. Cancellation mechanism. |
|---|---|
| Observed | Customers enroll online in under a minute. The account page has no cancel control; the FAQ tells them to email support to cancel, confirmed within one business day. |
| Requirement | A consumer who accepted an automatic renewal online must be able to cancel online, without steps that obstruct or delay termination. Cal. Bus. & Prof. Code § 17602(c) |
| Fix | Enable the one-click cancel control in the Recharge customer portal (native setting) and remove the email instruction. Confirm on screen and by email. |
| Owner | Product Engineering · Under one day |
Same root cause as CC-CA-004. One fix resolves both.
| Jurisdiction | Virginia. Cancellation parity. |
|---|---|
| Observed | Enrollment is one screen. Cancellation is the support-email path plus a reply plus a three-question exit survey before the change is processed. |
| Requirement | Cancellation must be at least as easy as the method used to enroll. Va. Code Ann. § 59.1-207.45 et seq., as amended by SB 361 (2025) |
| Fix | Resolved by the CC-CA-004 portal fix. Move the survey to after cancellation is confirmed and make it optional. |
| Owner | Product · Included in CC-CA-004 |
| Jurisdiction | California, New York, Illinois, Colorado. Renewal reminder for terms of one year or longer. |
|---|---|
| Observed | The $220 annual plan renews on the anniversary date with no reminder email beforehand. The monthly plan is unaffected. |
| Requirement | Terms of a year or longer require a clear renewal notice, including how to cancel, within a statutory window before the charge. Cal. Bus. & Prof. Code § 17602(b); N.Y. Gen. Bus. Law § 527-a; 815 ILCS 601/10; Colo. Rev. Stat. § 6-1-732 |
| Fix | Enable Recharge's upcoming-charge notification for the annual plan at 30 days out (satisfies the tightest window in scope). Include price, date, and a cancel link. |
| Owner | Retention Engineering · Under one day |
| Jurisdiction | California, New York, and most states with an acknowledgment requirement. |
|---|---|
| Observed | The Shopify order confirmation lists items and price but does not restate renewal terms, the cancellation policy, or how to cancel. No separate subscription confirmation is sent. |
| Requirement | After acceptance, provide an acknowledgment with the renewal terms, cancellation policy, and how to cancel, in a form the consumer can retain. Cal. Bus. & Prof. Code § 17602(a)(3); N.Y. Gen. Bus. Law § 527-a(2) |
| Fix | Add a "Your subscription terms" block to the Shopify confirmation template, or enable Recharge's subscription confirmation email. Retain a copy per customer. |
| Owner | Engineering · Under one day |
| Jurisdiction | Minnesota. Retention and save-offer restrictions. |
|---|---|
| Observed | Selecting "pause or cancel" triggers a 20% discount screen that must be dismissed before the cancel option appears. |
| Requirement | Retention offers may not gate cancellation unless the consumer agreed to receive them; the cancel option must remain immediately available. Minn. Stat. ch. 325G, automatic renewal provisions (2025) |
| Fix | Show cancel and pause first. Present the discount as optional on the same screen, or ask whether the customer wants to see an offer, with cancel available either way. |
| Owner | Retention Product · One to two days |
Price, billing frequency, renewal, and cancel policy sit in a bordered block directly above the payment button, and consent is a separate unchecked box with its own label. This meets the clear-and-conspicuous and affirmative-consent standards everywhere in scope. Preserve this pattern if you redesign checkout. Reviewed against the pre-purchase disclosure and consent requirements in all eight in-scope states.
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