BC’s New Subscription Rules Took Effect August 1. Here Is What Has to Change on Your Checkout.

By Cody Wise, Founder, Wise Media. Published 16 September 2026.

If you sell a subscription to anyone in British Columbia, your checkout and your renewal emails are now governed by rules that came into force on 1 August 2026. The changes are concrete: auto-renewal clauses are void unless the customer can cancel at any time, renewal notices are mandatory on longer terms, and blanket “we may change these terms” clauses no longer work. Most of the work is a checkout disclosure block and one scheduled email.

Summary

Amendments to British Columbia’s Business Practices and Consumer Protection Act (BPCPA) took effect 1 August 2026. They create a new category called a subscription contract and attach three build-level requirements to it: a cancellation right that cannot be contracted away, a renewal notice window of 30 to 60 days on terms longer than 60 days, and strict limits on unilateral amendment. Separately, the existing pre-purchase disclosure duty under section 18.3 carries the real financial penalty exposure, up to $50,000 CAD for a corporation, and that is the part most businesses have not implemented.

This article is written for whoever has to change the website, not for a lawyer. It maps each statutory requirement to the field, screen or scheduled job that satisfies it.

Table of contents

• What counts as a subscription contract, and the $50 threshold
• The cancellation right, and why 60 days splits it into two regimes
• The renewal notice: timing, contents, and the proof-of-receipt problem
• Unilateral amendment clauses that are now void
• The disclosure duty that carries the actual fine
• Does this reach a business outside British Columbia?
• The legacy subscriber trap
• Build checklist: what actually changes on the site
• Common mistakes, including one rule that does not exist
• What this costs in Canada
• FAQ

This is not legal advice. It is an implementation guide written by an agency that builds checkouts. The BPCPA is a live statute with remedies attached, and whether any specific business or contract complies is a question for your own counsel. Nothing here asserts the compliance status of any particular company.

What counts as a subscription contract, and where the $50 actually comes from

A subscription contract is a future performance contract for the supply of goods or services on a continuing basis, excluding fitness and other personal services contracts, where the cumulative total price is $50 CAD or more before tax and shipping.

That last clause trips people up, because the $50 is not in the definition of “subscription contract” at all. Section 17 of the BPCPA defines it without any dollar figure. The threshold arrives indirectly, through the definition of future performance contract, which excludes contracts below a prescribed amount, and the prescribed amount lives in section 1.1 of the Consumer Contracts Regulation, B.C. Reg. 272/2004, added effective 1 August 2026.

The word that matters in that regulation is cumulative. The threshold is “the cumulative total amount of $50, before taxes, shipping or any other costs.” A $9 per month plan is not a $9 contract. Across a twelve-month term it is a $108 contract, and it clears the threshold comfortably. In practice, almost every recurring plan a Canadian SMB sells is caught.

Quick eligibility test

• Is it recurring or continuing supply? If yes, continue.
• Is it a gym membership, personal training, or similar personal services arrangement? If yes, different rules apply and this article is not your guide.
• Does the total amount payable over the term reach $50 CAD before tax? If yes, you are inside the subscription contract rules.

The cancellation right, and why 60 days splits it in two

An auto-renewal clause is void unless the contract lets the customer cancel the renewal at any time, before or after the renewal date. That is the headline. The detail that almost every summary flattens is that the consequences differ depending on the length of the renewal term.

Section 25.1(1) covers renewal terms of 60 days or less. The clause is void unless the contract says the customer may cancel at any time, before or after the renewal date, without charge or other penalty. There is no pro-rata refund obligation in that subsection. Consumer Protection BC’s own guidance confirms the customer does not get back the unused portion.

Section 25.1(2) covers renewal terms of more than 60 days, and it is stricter. The clause is void unless the contract provides all of the following: the customer may cancel at any time, before or after the renewal date; cancelling before the renewal date attracts no charge or penalty; and cancelling after the renewal date entitles the customer to the refund set out in subsection 25.1(5)(a).

Two regimes, side by side

Renewal term	Cancel any time?	Pro-rata refund after renewal?	Refund deadline
60 days or less (monthly, weekly)	Yes, before or after	No	Not applicable
More than 60 days (annual, quarterly)	Yes, before or after	Yes	15 days for money, 30 days to return or cancel cheques and pre-authorized debits

The refund formula is set in section 3(1) of the Consumer Contracts Regulation: unused services divided by total services, multiplied by all money paid, measured in days remaining. The 30 percent supplier-cost deduction that appears elsewhere in that regulation applies only to fitness and personal services contracts. It does not apply to subscriptions, so do not build a deduction into your refund logic.

What this means for billing code

If you sell an annual plan, your cancellation endpoint needs a branch that did not previously exist. A customer who cancels on day 40 of a renewed annual term is owed roughly 325 over 365 of what they paid for that term, and you have 15 days to send it. In Stripe terms this is a prorated credit and refund rather than a simple cancel_at_period_end flag. In WooCommerce Subscriptions it is a manual refund calculation unless you extend the cancellation hook.

Monthly plans are easier. Cancel at any time, no penalty, no refund of the current period. Most stacks already behave that way.

The renewal notice: 30 to 60 days, and a proof standard most teams miss

On renewal terms longer than 60 days, section 25.1(2)(b) requires the supplier to give notice not more than 60 days and not less than 30 days before the renewal date. Miss the window and the auto-renewal provision is void. No notice, no valid renewal.

The notice must contain four things:

1. The renewal date.
2. A statement of the customer’s right to cancel the renewal.
3. Instructions on how to cancel the renewal.
4. A statement that the contract will renew if the customer does not respond.

Then comes the part that is a genuine engineering requirement rather than a copywriting one. Section 25.1(3) says notice may be given “by any manner that enables the supplier to prove that the consumer has received the notice.”

Read that again. The standard is proof of receipt, not proof of sending. Elsewhere in the same Act, section 48(4) creates a deemed-receipt rule for distance sales contracts sent by email. No equivalent deeming provision attaches to section 25.1. So “we sent it from Mailchimp” is evidence that you sent it. It is not, on the face of the statute, evidence that the customer received it.

Practical ways to build toward a receipt record

• Log the delivery webhook from your email provider, not just the send event, and retain it against the customer record.
• Mirror the notice as an in-app banner or account-area message with a logged acknowledgement click.
• Retain open-tracking data where you have consent to collect it, understanding it is imperfect.
• For high-value annual contracts, consider a second channel such as SMS with a delivery receipt.

None of these is stated in the Act as sufficient. The point is that a send log alone is the weakest position available, and improving on it costs a webhook handler and a database column.

Unilateral amendment clauses that are now void

Section 25.2 kills the standard “we may update these terms at any time” clause. A unilateral amendment clause is void unless the provisions that may be amended are identified in the contract at the time it is entered into. A general reservation of right is no longer enforceable.

It goes further. A clause allowing unilateral amendment of the cancellation, return, exchange or refund provisions is void unless it specifically states that such an amendment may be made only if it does not increase a consumer obligation or reduce a supplier obligation.

And when you do amend, section 25.2(3) requires notice not less than 30 and not more than 60 days before the change takes effect, by a means you can prove was received, containing the text of the provision as it will read after the amendment, a clear explanation, and, if the change worsens the customer’s position, a statement of their right to cancel. Fail to give that notice and you may not amend at all. The amendment is void.

If the amendment increases a consumer obligation or reduces a supplier obligation, the customer may cancel at any time without charge or penalty. That is a real revenue consideration for any SaaS business planning a price increase.

The disclosure duty that carries the actual fine

Here is the finding that should reorder your priorities if you have a limited development budget.

Under the Business Practices and Consumer Protection Regulation, B.C. Reg. 294/2004, the provisions prescribed for administrative penalties are listed in sections 3 through 6. Section 18.2 is prescribed. Section 18.3 is prescribed indirectly. Sections 25.1 and 25.2, the new subscription rules everyone is writing about, are not in that prescribed list.

What that means in practice: the auto-renewal and amendment rules are enforced by voidness, compliance orders, undertakings and private claims. The rules that carry a direct administrative penalty are the disclosure rules. So if you can only fix one thing this quarter, fix the checkout disclosure, because that is where the money is.

Section 18.3: disclose before, not after

The statute is direct: “Before a supplier enters into a contract with a consumer, the supplier must, if the total price under the contract is more than the prescribed amount, disclose … the information referred to in section 18.2 (a) and (d) to (t).”

Section 18.3(2) adds that it must be provided without charge and without conditions, in a clear and comprehensible manner. Section 18.3(3) requires an express opportunity to view the entire contract at the time of disclosure, with a copy provided promptly on request.

Three consequences for a build:

• Pre-purchase, not post-purchase. A confirmation email containing all the terms does not discharge section 18.3. The information has to be visible before the customer commits.
• Not gated. “Without conditions” means you cannot require account creation, an email address, or a paywall before showing it.
• Clear and comprehensible. A link to a 4,000-word terms of service is arguable at best. A short summary block on the checkout page with the material terms, plus a link to the full contract, is the defensible pattern.

One caveat worth stating honestly. The “prescribed amount” for section 18.3 is not prescribed anywhere I could locate in the live regulations, whose only prescribed amounts are the $50 future performance threshold and the direct sales threshold. Consumer Protection BC’s published guidance treats the number as $50. Treat $50 as the working figure, attributed to regulator guidance rather than to a prescribing regulation.

The section 18.2 items that change a checkout page

Provision	What it requires	Where it lives on the site
18.2(o)	Promotional offers, qualifying conditions, duration, and the terms that apply when the offer expires	The intro-pricing or free-trial block. “$1 for the first month, then $49 CAD per month thereafter” stated at the same visual weight as the $1.
18.2(q)	Return, exchange, cancellation and refund policies	Checkout summary block plus the account area.
18.2(r)	Renewal terms, how the contract may be renewed, and any automatic renewal provisions	Checkout summary block. State the renewal date logic and the term length.
18.2(a), (d) to (t) generally	Supplier identity, contact details, description, total price, payment terms, delivery	Standard checkout fields plus a visible business address and contact method.

Does this reach a business outside British Columbia?

This is the question behind the question for every Alberta, Ontario or Nova Scotia business reading this, and the honest answer has two halves.

The statute is drafted to reach you. Section 1 of the BPCPA defines “consumer” as an individual “whether in British Columbia or not,” and defines “supplier” as a person “whether in British Columbia or not” who participates in a consumer transaction by supplying goods or services or by “soliciting, offering, advertising or promoting” with respect to such a transaction, “whether or not privity of contract exists.” Section 3 then makes any waiver or release of rights under the Act void except where the Act expressly permits it. Since March 2025, arbitration clauses and class action waivers in consumer contracts have also been void under sections 14.1 to 14.3. You cannot contract out by choice-of-law, forum selection or arbitration clause.

But no court has ruled on it for subscription sellers. The BPCPA has no express territorial application section. Section 2 addresses subject matter scope, not geography. I could not find any Consumer Protection BC guidance page addressing out-of-province sellers, and no published case interpreting the Act’s territorial reach against a non-BC subscription business. Constitutionally, provincial regulatory legislation reaches out-of-province parties on a real and substantial connection test, and marketing into BC, taking BC payments and billing BC residents recurringly would ordinarily satisfy it. That is a reasoned inference, not a decided point.

The practical read: the cost of complying is one scheduled email and a checkout disclosure block. The cost of being wrong is void renewals across your BC customer base plus penalty exposure on the disclosure side. That asymmetry answers the question for most businesses without needing the legal one resolved.

What the rest of Canada looks like

Jurisdiction	Status	Notes
British Columbia	In force 1 August 2026	The regime described in this article.
Quebec	Long-standing	Stricter on timing. Auto-renewal of a term over 60 days is prohibited unless the renewal is for an indeterminate term, and notice of expiry must be sent between the 90th and 60th day before it. Consumers may refuse a unilateral amendment and cancel within 30 days where it increases their obligations.
Ontario	Passed, not yet in force	The Consumer Protection Act, 2023 received royal assent in December 2023 and, as of writing, has not been proclaimed. The CPA 2002 still governs. Treat circulating Ontario renewal-notice numbers as not yet law.
Federal	Indirect	No general negative-option billing prohibition in the Competition Act. The live hooks are drip pricing and general deceptive marketing provisions.

If you build once for BC and Quebec together, you have effectively built for the strictest Canadian position available today. That is the sensible engineering call rather than maintaining per-province logic.

The legacy subscriber trap

Section 203.002 of the BPCPA contains a transitional rule that almost every summary omits. The old Part 4 continues to apply to contracts entered into before 1 August 2026 except contracts renewed after that date.

Consumer Protection BC restates it plainly: contracts signed or renewed on or after 1 August 2026 must follow the updated law, and the contract date is what matters, not when services are provided, payments are made, or a complaint is filed.

So your 2023 annual subscriber is not grandfathered. At their next renewal they are pulled into the new regime, which means the 30-to-60-day renewal notice job is retroactive across your entire existing base, not just new signups. If you run annual plans, some of those customers have renewal dates inside the next 60 days right now.

Build checklist: what actually changes on the site

Checkout page

• Add a visible pre-purchase disclosure block above the pay button, not behind a link.
• State the full renewal price at the same visual weight as any intro price.
• State the term length and the renewal date logic in plain language.
• State the cancellation and refund policy, matched to the correct 60-day regime.
• Provide an express “view the full agreement” link that opens without account creation or email capture.
• Show supplier identity, business address and a working contact method.

Contract and terms

• Rewrite the auto-renewal clause for the correct regime, including the pro-rata refund entitlement on terms over 60 days.
• Replace any blanket amendment clause with a specific list of the provisions you may amend.
• Add the constraint language on amending cancellation, return, exchange and refund terms.
• Remove arbitration clauses and class action waivers from consumer-facing terms.

Scheduled jobs and billing logic

• Build a renewal notice job that fires between 60 and 30 days before renewal on every term longer than 60 days.
• Include all four mandatory notice contents, including cancellation instructions.
• Log delivery webhooks, not just sends, and retain them.
• Add a post-renewal cancellation branch that calculates the pro-rata refund and pays it within 15 days.
• Cancel any future authorized payments on cancellation, and return or cancel cheques and pre-authorized debits within 30 days.
• Run the notice job across legacy subscribers, not just new ones.

Amendment workflow

• Build a 30-to-60-day amendment notice template that includes the post-amendment text of the clause verbatim.
• Add a conditional cancellation-right statement for amendments that worsen the customer’s position.
• Gate any price increase behind that workflow.

Common mistakes, including one rule that does not exist

1. Assuming there is a “cancel must be as easy as signup” rule

There is not one in the BPCPA as amended. Reading the full amended Part 4, sections 25.1 and 25.2, and both regulations turns up no click-to-cancel provision, no same-medium requirement, and no “as easy to cancel as to subscribe” language anywhere. At least one page currently ranking for this topic states otherwise.

What does exist: the renewal notice must contain cancellation instructions (25.1(2)(b)(iii)); the cancellation policy must be in the contract (18.2(q)); a consumer may cancel by any method that produces evidence of the date (section 54); and on cancellation you must stop future authorized charges (section 56).

So a retention gauntlet or a phone-only cancellation queue is a reputational risk and arguably an unfair practice under the Act’s deceptive acts provisions. It is not a standalone breach of the 2026 amendments. Build the easy cancel flow anyway, because it is the right product decision, but do not let a vendor sell it to you on a legal basis that is not there.

2. Treating the $50 as a per-payment figure

It is cumulative across the term. Low-ticket monthly plans are almost always caught.

3. Applying the monthly rule to annual plans

Annual plans carry a pro-rata refund obligation on post-renewal cancellation. Monthly plans do not. Getting this backwards either exposes you or costs you revenue you did not owe.

4. Sending the renewal notice too early

The window is bounded on both sides. A notice at 90 days is as non-compliant as one at 10 days. If you already run a Quebec-compliant 90-to-60 day notice, you need a second BC-timed send, or a single send inside the overlap.

5. Grandfathering existing subscribers

Covered above. Renewal pulls them in.

6. Relying on a send log as proof of receipt

The statute asks you to prove the consumer received it. Log delivery, not dispatch.

What is the exposure, and what does the fix cost?

Exposure

Mechanism	Exposure
Voidness (ss. 25.1, 25.2)	The offending clause is void. No enforceable renewal, refund exposure, revenue reversal.
Consumer cancellation (s. 18.4)	Where required contract information is missing or pre-sale disclosure was breached, the consumer may cancel within one year on a future performance contract.
Administrative penalty (ss. 164-165)	Up to $5,000 CAD for an individual, $50,000 CAD for a corporation. Daily penalties are available for continuing contraventions.
Offence (ss. 189-191)	Breach of s. 18.3 is an offence. Up to $10,000 CAD and 12 months for an individual, $100,000 CAD for a corporation, with the court able to increase the fine by up to three times the monetary benefit obtained.
Private action (s. 171)	Damages in Supreme Court, Provincial Court, or the Civil Resolution Tribunal.

Worth noting what Consumer Protection BC says about how it enforces: “We are a risk-based regulator. We typically focus first on education and voluntary compliance. Generally, when we receive a complaint or identify an issue, we will start by working with the business to explain the requirements and give them an opportunity to fix the problem. If a business does not come into compliance, we may take further enforcement action depending on the situation.”

That is a grace-period signal, not an amnesty. As of mid-September 2026, no published Consumer Protection BC enforcement action references the new subscription sections. The two enforcement entries published since 1 August 2026 are unrelated on their face.

Cost of the fix, in CAD

These are the ranges we quote for this class of work in Canada. Every figure is CAD. Your own stack and contract complexity move them.

Scope	Typical range (CAD)	What is included
Checkout disclosure block only	$800 – $1,800	Pre-purchase disclosure component, intro-pricing display fix, ungated contract link, deployment and QA.
Disclosure plus renewal notice automation	$2,500 – $5,000	Above, plus the 30-to-60 day scheduled job, notice template, delivery webhook logging, backfill across legacy subscribers.
Full subscription compliance build	$6,000 – $12,000	Above, plus pro-rata refund logic, amendment notice workflow, account-area cancellation flow, audit documentation.
Legal review of contract wording	Quoted by counsel	Not agency work. Budget separately.

The checkout disclosure block is the highest return line in that table, because it is cheap and it is the piece carrying the direct administrative penalty. If budget forces a sequence, do it first.

Frequently asked questions

When did BC’s new subscription contract rules take effect?

1 August 2026. The enabling legislation was the Business Practices and Consumer Protection Amendment Act, 2025, which received royal assent on 31 March 2025. Some provisions, including the bans on arbitration clauses and class action waivers in consumer contracts, came into force at royal assent rather than on 1 August 2026. At least one page currently ranking on this topic states the date as 2 August 2026. That is wrong.

Does the $50 threshold mean my $9 per month plan is exempt?

No. The regulation sets the threshold as the cumulative total amount of $50 CAD before taxes, shipping and other costs. A $9 monthly plan crosses $50 within six months and clears it easily across an annual term.

Do I have to send a renewal notice for a monthly subscription?

The 30-to-60 day renewal notice requirement in section 25.1(2)(b) attaches to renewal terms of more than 60 days. A standard monthly plan falls under section 25.1(1), which requires the cancel-any-time right but not the advance notice. Annual and quarterly plans need the notice.

Does BC’s law apply to my Alberta or Ontario business?

The Act defines both “consumer” and “supplier” as including persons “whether in British Columbia or not,” captures anyone soliciting or advertising into a consumer transaction, and voids waivers of its protections. That drafting is designed to reach out-of-province sellers. However, the BPCPA contains no express territorial application section, and no published case has decided the point for subscription sellers. Given that compliance costs a scheduled email and a checkout block, most businesses selling into BC comply rather than test it.

Do the new rules require that cancelling be as easy as signing up?

No. There is no click-to-cancel or same-medium requirement in the BPCPA as amended. The Act requires that cancellation instructions appear in the renewal notice, that the cancellation policy be in the contract, and that a consumer may cancel by any method producing evidence of the date. A deliberately obstructive cancellation flow is a reputational and unfair-practice risk rather than a breach of the 2026 subscription amendments.

Are my existing subscribers grandfathered under the old rules?

Only until they renew. The transitional rule in section 203.002 keeps the old Part 4 for contracts entered into before 1 August 2026, except contracts renewed after that date. Every legacy subscriber enters the new regime at their next renewal, so the renewal notice job has to run across your existing base.

What is the maximum penalty for getting this wrong?

Administrative penalties reach $5,000 CAD for an individual and $50,000 CAD for a corporation, with daily penalties available for continuing contraventions. On the offence track, breach of section 18.3 can reach $10,000 CAD and twelve months for an individual or $100,000 CAD for a corporation, and a court may increase a fine by up to three times any monetary benefit obtained. Note that the new subscription sections 25.1 and 25.2 are not on the prescribed list for administrative penalties. The disclosure sections are.

Can I still raise prices on an existing subscription?

Yes, but only if the contract identified price as an amendable provision when it was entered into, and only after giving notice between 30 and 60 days before the change takes effect, containing the post-amendment text and a clear explanation. Because a price increase increases a consumer obligation, the notice must also state the customer’s right to cancel, and they may cancel at any time without charge or penalty.

The bottom line

Most coverage of these amendments has been written by lawyers for other lawyers, or by journalists for consumers. Almost nothing has been written for the person who has to open the checkout template and change it.

The work is smaller than the statute makes it look. One disclosure component above the pay button. One scheduled job between 60 and 30 days out. One refund branch on annual plans. One list of amendable provisions in the contract. One backfill across legacy subscribers.

Do the disclosure block first, because that is the piece with a $50,000 CAD ceiling attached to it. Everything else is enforced by voidness, which is expensive but slower.

Get your checkout audited

Wise Media builds and maintains subscription checkouts for Canadian businesses. If you sell recurring plans into British Columbia and have not touched your checkout since July, we will audit the disclosure block, the renewal notice timing and the cancellation logic against the sections above, and quote the remediation in CAD before any work starts.

Start a scoped audit here, or read more about our website build packages and ongoing website growth and maintenance packages.

Related reading on Canadian compliance for websites: Law 25 cookie consent, CASL compliance for forms and emails, Quebec’s French-language website rules, and website accessibility law in Canada and Alberta.

Sources

• Business Practices and Consumer Protection Act, SBC 2004, c 2 (official consolidation)
• Consumer Contracts Regulation, B.C. Reg. 272/2004
• Business Practices and Consumer Protection Regulation, B.C. Reg. 294/2004
• Government of British Columbia, news release on the 1 August 2026 amendments
• Consumer Protection BC, guidance for businesses on the 2026 law changes
• Consumer Protection BC, recent enforcement actions register
• Quebec Consumer Protection Act, CQLR c P-40.1