Illinois Automatic Contract Renewal Act for Foreign Owners
Learn how the Illinois Automatic Contract Renewal Act treats subscriptions and free trials, and what foreign-owned and cross-border sellers should check.
Last reviewed October 27, 2026 · 3 min read · General information, not legal advice
General information only, not legal advice. CPA Tax Payroll and Accounting Corp is a CPA firm, not a law firm. Laws change: confirm with the official source or a licensed attorney before you act. Read the full notice.
Contracts that renew on their own unless the customer cancels fall under 815 ILCS 601, the Illinois Automatic Contract Renewal Act. Examples are a monthly software plan or a free trial that becomes a paid plan. It has no penalty clause of its own; violations are enforced through the Consumer Fraud Act. This page is for owners of U.S. businesses with ties to Canada or India that sell to Illinois individuals, such as an app built in Pune or a coaching service run from Toronto.
Slide show: The Illinois renewal law in seven slides
What it is
Illinois rules for contracts that renew unless the customer cancels (815 ILCS 601).
Who is in scope
Any size of seller dealing with consumers. Contracts between businesses, banks and some regulated providers are left out.
Consent first
Place the renewal terms beside the consent request, and obtain the customer's consent before any charge.
Long terms
For terms of 12 months or more, the seller sends written notice 30 to 60 days ahead of the cancellation deadline.
Trials and promotions
Trials and promotions of 15 days or longer need a reminder 3 or more days before the cancellation deadline.
What a breach costs
Breaking the Act is a Consumer Fraud Act violation, with a court penalty up to $50,000 (more in some cases). Private suits are also possible, within 3 years.
Practical tip
Online sign-up means online cancellation, so build the cancel link when you build the sign-up page.
Who does the Illinois Automatic Contract Renewal Act cover?
Question
Answer
Who must comply?
Any person or firm selling to a consumer under an auto-renewing contract. The text has no employee, revenue or size test.
Who is a "consumer"?
The Act does not define the word.
What is excluded?
Business-to-business contracts; banks, credit unions and their affiliates; insurance-regulated parties; Public Utilities Act Article XXII providers; extensions the consumer asked for to change terms; contracts made before the Act.
What it means for a foreign-owned or cross-border business
Situation
What the law says
What to check
App or membership sold from Canada or India to Illinois individuals
The Act covers any person or firm selling to a consumer under an auto-renewing contract.
Whether it reaches a seller based abroad is a legal question for an attorney.
Customers who are businesses
Business-to-business contracts are excluded, but the phrase is undefined.
If you sell to freelancers, have an attorney review how you classify buyers.
Customers who sign up online
A consumer who signs up online must be able to cancel exclusively online, such as by a ready-made email or website link.
Test the cancel path end to end.
A billing error refunded
The safe harbor needs written procedures, an error and full refunds or credits.
A refund adjusts revenue already recorded; tell your bookkeeper.