What Changed and When It Took Effect in Maine
Maine’s Legislature passed S.P. 650, L.D. 1642 in 2025, and the Governor signed it into law on June 20, 2025. The changes apply to any subscription offer or agreement entered into or renewed on or after January 1, 2026.1
The law amends Maine’s existing automatic subscription renewal statute, 10 M.R.S. § 1210-C, in two significant ways. First, it tightens the disclosure and consent requirements that already applied to digital subscriptions. Second, it brings health club memberships fully under the same rules, which previously applied only to online services like streaming platforms, mobile apps, and software.
If you run a gym, fitness studio, yoga practice, or any facility that offers recurring access to equipment, classes, pools, saunas, or courts, this law applies to you directly.
The Three Core Requirements Your Business Must Meet
The statute lays out specific obligations for any Maine seller making an automatic renewal offer. Here’s what the law now requires.
Clear disclosure before enrollment. Before a customer agrees to a subscription or membership, you must give them a clear, conspicuous, and easily accessible disclosure of all material terms, including the amount and frequency of charges, how the renewal works, and how they can cancel. Burying this in a scroll-past terms of service is not enough.2
Express consent before charging. You must get affirmative consent from the customer before enrolling them in automatic renewal. A pre-checked checkbox isn’t enough. The customer must actively check a box, sign electronically, or take some other affirmative action agreeing to the renewal terms.
Same-method cancellation. This is the provision that will require the most operational work for many businesses. If a customer signed up online, they must be able to cancel online, through the same method and in the same manner they used to sign up. You can also offer a toll-free phone number, but if online sign-up is available, online cancellation is required.
The Health Club Addition: What It Means for Maine Gyms and Studios
Before this law, health clubs in Maine operated under a separate statutory framework that focused primarily on written contract requirements.3 The 2025 amendments bring gyms, fitness centers, health studios, and similar facilities into the subscription renewal framework for the first time.
The law defines “health club” broadly to include fitness centers, gyms, health studios, exercise clubs, and any facility offering access to equipment, classes, pools, saunas, or courts. Nonprofits, government facilities, schools, and healthcare facilities are excluded. If you’re a for-profit fitness operation, assume you’re covered.
A “health club membership” under the statute means any agreement where a consumer pays for ongoing access to health club services, whether on a recurring monthly basis or for a longer fixed term. This includes agreements made online, through an app, or over the internet.
The Extra Notice Rule for Annual and Long-Term Memberships
If your subscription or membership has a term of 12 months or more and automatically renews, you’re dealing with what the statute calls an “extended automatic subscription or health club membership renewal.”4 These carry an extra requirement on top of the standard disclosure and consent rules.
You must send the customer a renewal notice no fewer than 30 days and no more than 60 days before the renewal date. The notice must clearly state that the subscription or membership will automatically renew unless the customer cancels, and it must tell them where to find details on the renewal terms and how to cancel.
What You Should Do Before Your Next Renewal Cycle
If your business operates in Maine and uses any form of recurring billing, the time to review your sign-up and cancellation process is now, before your next renewal cycle runs.
Start with your enrollment flow. Document how customers sign up and confirm that affirmative consent for automatic renewal is captured at that step. If you use a third-party platform for sign-ups, check whether that platform’s consent flow meets Maine’s requirements. You own the compliance obligation regardless of who built the checkout.
Next, review your cancellation options. If customers can sign up on your website or app, they must be able to cancel by the same method. If your current process requires a phone call or an in-person visit to cancel an online enrollment, that process must change.
Finally, look at your annual and long-term memberships. Build a calendar alert into your billing system to trigger the required 30-to-60-day renewal notices automatically.
Your membership agreements and terms of service should be reviewed and updated to reflect the new disclosure requirements. Contracts that were written before January 1, 2026, and that renew after that date, are now subject to these rules on renewal.
Frequently Asked Questions
Does Maine’s new subscription cancellation law apply to my gym or fitness studio?
Yes, if you operate a for-profit gym, fitness center, health studio, or similar facility in Maine, the law applies to any membership that automatically renews. Nonprofits, government facilities, schools, and healthcare facilities are exempt. All other health clubs are covered as of January 1, 2026.
What does “same-method cancellation” mean for my online sign-up process?
It means if a customer can sign up for your subscription or membership on your website or through an app, you must give them a way to cancel using that same online method. You cannot require customers to call or visit in person to cancel an online enrollment. The cancellation process must be as accessible as the sign-up process was.
What’s the penalty for violating Maine’s subscription renewal law?
A violation is treated as a violation of the Maine Unfair Trade Practices Act, which carries its own damages and penalties. On top of that, a business that bills a customer for unauthorized subscription charges must refund three times the unauthorized amount billed. There is a safe harbor if the violation was an error and you issue a full refund promptly.
When must I send a renewal notice for an annual membership?
For any subscription or membership with a term of 12 months or more that automatically renews, you must send a renewal notice no fewer than 30 days and no more than 60 days before the renewal date. The notice must clearly state that renewal is coming and explain how the customer can cancel.
Does this law apply to memberships entered before January 1, 2026?
The law applies to offers or agreements entered into or renewed on or after January 1, 2026. If a pre-existing membership renews after that date, the renewal is subject to the new requirements. Memberships that were entered before that date and have not yet come up for renewal may be subject to prior law until they renew. [CITE-CHECK: confirm application of transition provision to pre-existing memberships on first renewal date]
If you run a subscription-based business or operate a health club in Maine, this is a good time to review your sign-up flow, your cancellation options, and your membership agreements. Nick at ioLiberum Law Firm, P.C. works with Maine businesses on compliance reviews and contract updates at flat-rate pricing, so there are no billing surprises. Reach out at www.ioliberum.com or call 401-300-4439.
Footnotes
- P.L. 2025, c. 376 (Me. 2025) (amending 10 M.R.S. §§ 1210-C, 1210-D to expand automatic renewal requirements to health club memberships and to clarify consent and cancellation obligations); effective for offers or agreements entered into or renewed on or after January 1, 2026. 10 M.R.S. § 1210-C. ↩
- 10 M.R.S. § 1210-C(2) (as amended by P.L. 2025, c. 376) (requiring sellers to present consumers with a clear, conspicuous, and easily accessible disclosure of all material terms before enrollment, and to obtain express consent through a checkbox, electronic signature, or other affirmative action prior to charging for automatic renewal). ↩
- [CITATION NEEDED: Prior Maine health club contract statute, likely 10 M.R.S. § 1211 et seq. (health club services contracts); verify current citation and whether provisions remain in effect alongside new amendment.] ↩
- 10 M.R.S. § 1210-C(1)(B) (as amended by P.L. 2025, c. 376) (defining “extended automatic subscription or health club membership renewal” as an automatic renewal with a term of 12 months or more that automatically renews for a term exceeding one month); 10 M.R.S. § 1210-C(3) (requiring notice to consumer no fewer than 30 days and no more than 60 days before the renewal date). ↩
- 10 M.R.S. § 1210-D(1) (as amended by P.L. 2025, c. 376) (providing that a violation of the subscription renewal chapter constitutes a violation of the Maine Unfair Trade Practices Act, and that a person found to have billed unauthorized subscription or membership charges must provide a refund or credit of three times the unauthorized amounts billed or paid). ↩
