Subscription and cancellation laws in Canada: what SaaS and app founders need to know
Written by For Founders Law, a Toronto firm licensed by the Law Society of Ontario. About Us From an idea by Simran Virk, Legal Assistant.
In short
Quebec now requires merchants to let consumers cancel online subscriptions with a readily identifiable online button, and British Columbia has added auto-renewal notice and cancellation rules. Ontario's Consumer Protection Act, 2023 has passed but isn't in force. If you sell subscriptions to Canadian consumers, make cancelling as easy as signing up, disclose renewals clearly, and keep your terms in line with what your checkout actually does.
Canadian subscription rules are tightening province by province. If individuals can sign up for your product with a credit card for personal use, these rules probably reach you.
Quebec: an online cancel button
Quebec amended its Consumer Protection Act in 2026 through Bill 10, and most of the changes came into force on September 12, 2026. Under the new section 187.28, a merchant that enters into an online contract involving sequential performance that the consumer may cancel without cause must let the consumer cancel easily, by means of a button accessible online and readily identifiable. For SaaS and app companies with Quebec consumers, “email support to cancel” is no longer enough.
British Columbia: auto-renewal and change notices
BC’s Business Practices and Consumer Protection Act has had specific rules for subscription contracts since August 1, 2026, in sections 25.1 and 25.2.
- Renewal terms of 60 days or less. An auto-renewal clause is void unless the consumer can cancel the renewal at any time, before or after the renewal date, without charge or penalty.
- Renewal terms longer than 60 days. The consumer must be able to cancel at any time, with no charge if they cancel before renewal and a prescribed partial refund (paid within 15 days) if they cancel after. You must also send a notice 30 to 60 days before renewal with the renewal date, the right to cancel, how to cancel, and a statement that the contract renews if they don’t respond.
- Changing your terms. You can only unilaterally amend provisions the contract identified as changeable at the start, with 30 to 60 days’ notice. If a change increases the consumer’s obligations or reduces yours, they can cancel without penalty.
Ontario: passed, not yet in force
Ontario’s Consumer Protection Act, 2023 will modernize the rules for consumer contracts, but it comes into force on a day to be named by proclamation and, as of this writing, isn’t in force. Ontario’s current Consumer Protection Act, 2002 still applies. Building a clean cancellation flow now avoids a scramble later.
Selling to US consumers
US federal and state auto-renewal rules apply separately. If you have meaningful US consumer revenue, get advice under the law of the states you sell into.
Does any of this apply to B2B SaaS?
Consumer protection laws protect consumers, not businesses, so a product sold only to companies is usually outside them. Many startups sell to both. Keep business SaaS agreements separate from your consumer terms of service.
A checklist for subscription businesses
- Show the full recurring price, billing frequency and mandatory fees before purchase. Advertising a price that can’t be obtained because of mandatory added fees is drip pricing, which the Competition Act treats as misleading.
- 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.
- Tell people before they start a free trial when it ends, what they’ll be charged and how to cancel.
- 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.
Renewal reminders and trial nudges can also be commercial messages under anti-spam law. See CASL for SaaS and the contract stack for software startups.
Sources
- Consumer Protection Act (Quebec), CQLR c. P-40.1, s. 187.28
- Business Practices and Consumer Protection Act (BC), ss. 25.1 and 25.2
- BC Gov News: Strengthening consumer protection in B.C. (August 2026)
- Consumer Protection Act, 2023 (Ontario), not yet in force
- Consumer Protection Act, 2002 (Ontario)
- Competition Act, s. 52 (false or misleading representations, including drip pricing)