Quick answer: Canadian subscription rules are tightening province by province. Québec now requires an easily identifiable way to cancel online subscriptions, British Columbia added auto-renewal and notice rules in August, and Ontario's new Consumer Protection Act has passed but is not yet in force. If you sell subscriptions to Canadian consumers, cancellation should be as easy as sign-up, renewals should be disclosed clearly, and your terms of service should match what your checkout actually does.
Key takeaways: Map which provinces your customers are in, put a working online cancellation path in the account settings, send renewal notices before charging, show the full recurring price up front, and keep business-to-business subscriptions on separate terms.
What changed in Québec?
Québec adopted Bill 10, amending its Consumer Protection Act, on June 12, 2026, and most of it came into force on September 12, 2026, with certain exceptions. Merchants that offer online subscriptions must now provide an easily identifiable way to cancel them. For SaaS and app companies with Québec consumers, a "contact support to cancel" process is no longer enough (Torys).
What changed in British Columbia?
Most of BC's Bill 4 amendments to the Business Practices and Consumer Protection Act took effect on August 1, 2026. For consumer contracts that renew automatically for a term longer than 60 days, customers must be able to cancel at any time without penalty, must get a refund for a renewal they cancel within 15 days, and must receive clear notice 30 to 60 days before the renewal. Shorter auto-renewing terms must also be cancellable at any time without charge. Suppliers can only change contract terms that the contract clearly identifies as changeable, and must give 30 to 60 days' notice (Torys).
What about Ontario?
Ontario passed the Consumer Protection Act, 2023, which will modernize the rules for consumer contracts, including subscriptions and unfair practices. It is not yet in force. Ontario's current consumer protection law still applies in the meantime. Building a clean cancellation flow now avoids a scramble later.
What is happening in the U.S.?
The U.S. FTC's "click-to-cancel" rule was vacated by a federal appeals court in July 2025, but enforcement did not stop. On September 25, 2025, the FTC announced a $2.5 billion settlement with Amazon over Prime sign-up and cancellation practices. If you sell to U.S. consumers, existing U.S. law and state auto-renewal laws still apply.
Do these rules apply to B2B SaaS?
Consumer protection laws generally protect consumers, not businesses, so a SaaS platform sold only to companies is usually outside them. Many startups sell to both. If individuals can sign up with a credit card for personal use, you likely have consumer customers and should treat them that way. Separate B2B subscription terms from consumer terms of service if you serve both.
Checklist for Canadian subscription businesses
- Show the full recurring price, billing frequency and any mandatory fees before purchase. Hidden fees can amount to drip pricing under the Competition Act.
- Let customers cancel online, in the same channel they signed up in.
- Send a renewal reminder before charging for annual plans and free-trial conversions.
- Avoid dark patterns such as repeated retention screens or hidden cancel buttons.
- Make sure your terms of service, checkout text and confirmation emails say the same thing.
- Keep records of the consent and disclosures each customer saw.
FAQ
Do I need a cancel button in my app?
For Québec consumers with online subscriptions, you need an easily identifiable cancellation mechanism. A clear cancel option in account settings is the simplest way to meet that and the expectations elsewhere.
Can I charge a cancellation fee?
It depends on the province and the contract type. In BC, auto-renewing consumer contracts must now be cancellable without penalty, and other provinces restrict fees too, so check before adding one.
Do free trials need special disclosure?
Yes, in practice. Tell customers before they sign up when the trial ends, what they will be charged and how to cancel, and remind them before the first charge.
Launching or fixing a subscription product? For Founders Law drafts terms of service, privacy policies and cookie consent, SaaS subscription agreements and reviews checkout and cancellation flows for a flat fee agreed before work starts. Book a free consultation.
Sources: Torys LLP, provincial consumer protection update (July 2026).
By Brooke Ash, BA, JD, founder of For Founders Law PC, licensed by the Law Society of Ontario. Last reviewed October 27, 2026. General information only, not legal advice. Related reading: AI and privacy law tracker, algorithmic and dynamic pricing in Canada and our startup, AI and tech law glossary.

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