Most software founders assume subscription laws are about consumers: gym memberships, streaming services, meal kits. Their buyers are businesses, so the rules don't apply. That's partly right and partly a costly guess. Some state auto-renewal laws protect small businesses too, a federal law has been used against companies that sold to merchants, and Google's own ad policy covers free trials whoever the buyer is.
This last chapter covers the rules around the moment a free trial turns into a bill, and around the ratings and reviews software companies love to put in their ads. It's not legal advice. It's a side-by-side of what the laws and platform rules say, so a founder knows which questions to bring to a lawyer before the ads go live. The guide closes with a map of all sixteen chapters.
Virginia and Wisconsin Write Small Businesses Into Their Auto-Renewal Laws. A B2B Trial Isn't Automatically Exempt.
State automatic renewal laws differ most on one point: who counts as protected. We read the most recent text we could find for nine of them, eight on official legislature sites and one, Colorado, through a public law library. Side by side:
- Virginia protects individuals and also small businesses, defined as 250 or fewer employees or annual gross receipts of $10 million or less averaged over three years, and at least 51 percent owned by U.S. citizens or legal residents.
- Wisconsin's law is titled "Renewals and extensions of business contracts" and covers contracts for business services, with exclusions for usage-based contracts with a yearly minimum of $250,000 or more and for contracts the customer can end on a month's notice or less.
- Illinois says plainly: "This Act does not apply to business-to-business contracts."
- California, New York's General Business Law, Colorado and Minnesota protect individuals buying for personal, family or household purposes.
- Florida covers individuals but excludes an individual "engaged in business."
- New York's General Obligations Law 5-903 covers automatically renewing contracts for service, maintenance or repair, without a consumer limit, but only where the renewal period is longer than one month, so most monthly plans fall outside it. Whether an annual software subscription counts as that kind of service is unsettled, in our reading.
Where these laws do apply, they ask for similar things. California and New York require that a free trial offer include "a clear and conspicuous explanation" of the price that will be charged after the trial. California, Virginia, Illinois and Minnesota require reminder notices before some longer trials end. Several require online cancellation as easy as the sign-up.
A software company selling to small businesses nationwide may well have customers in Virginia or Wisconsin. The practical move isn't to find the one state that applies. It's to build the trial so it would pass the strictest of them.
Keep a short record, too: what the sign-up page said on each date, what the reminder email said and when it went out. If a customer or a state ever asks how a trial was sold, that record answers in minutes, and it costs nothing to keep.
Adobe Agreed to a $150 Million Settlement Over How It Sold Software Subscriptions. Federal Law Wants the Terms Before the Card.
The federal law here is the Restore Online Shoppers' Confidence Act, usually called ROSCA. It applies to online sales with a "negative option feature," such as a trial that turns into a paid plan unless the buyer cancels. It requires a seller to disclose "all material terms of the transaction before obtaining the consumer's billing information," get the buyer's clear agreement before charging and provide "simple mechanisms" to stop the charges.
It has reached software. In March 2026, the DOJ announced a proposed settlement in which Adobe would pay $75 million in civil penalties and offer customers $75 million in free services over allegations that its subscription practices violated ROSCA, including "using fine print and inconspicuous hyperlinks" to hide important terms. Business buyers have been in the picture too: in 2022, the FTC brought a case against a payment processor accused of "trapping small businesses with hidden terms," under a proposed court order to return $4.9 million. Law firms report that ROSCA was among the claims, a theory not yet tested in court.
One thing that's no longer in force: the FTC's 2024 "click-to-cancel" amendments. After a federal appeals court vacated them, the FTC restored its older Negative Option Rule effective February 12, 2026, and opened a new rulemaking a month later. Watch that space, but don't build to a rule that isn't there.
Google adds its own layer. As Chapter 8 covered, its dishonest pricing policy counts a free-trial ad that leaves out the trial's length, or the automatic charge at the end, as a violation, and expects the price and billing interval on the landing page.
30 of 215 Low-Star Software Reviews We Read Described Money Taken Without Clear Consent. Renewal Laws Exist for That Complaint.
The laws track a real complaint. Of the 215 one- and two-star Capterra reviews we read across twelve software products, 30 described a billing error, a charge after canceling, a refused refund, a locked contract or a renewal surprise. Separately, 11 reviews called the pricing hidden or opaque, including the buyer from Chapter 15 who sat through nearly a month of emails and meetings before seeing a price over $400 a month.
Most of the sample companies avoid the problem by design. Seven of the eleven with a free trial said the trial simply expires or locks. Only one said it bills the card automatically when the trial ends, and it said so only in its pricing FAQ.
If your trial does bill automatically, build the disclosure where buyers actually look:
- In the ad, the trial length and what happens at the end (Chapter 8).
- Next to the sign-up button, the price after the trial and the date of the first charge.
- Before the trial converts, a reminder email with a one-click way to cancel.
- In the account, cancellation that takes no more steps than signing up did.
None of this hurts a good product. Buyers who stay after a clear reminder are customers who chose to pay, which is the kind the CRM from Chapter 1 should be counting.
A "#1 on G2" Claim Needs a Paid License and a Link to the Report. A 30-Character Headline Has Room for Neither.
Ratings are everywhere in software ads. Of the 640 recent ads we read, 86 from 28 companies carried a rating, an award or "#1" wording. Ten of the twelve sample sites showed a G2 or Capterra rating, and two of the twelve showed different rating or customer-count figures on different pages of their own site.
The review sites have rules for how their names and numbers are used. G2's usage guidelines, for example:
- Live category rankings like "Leader" have to cite G2 with the date the data was pulled and link back to the category page.
- Numeric claims like "#1" or a satisfaction score require a paid content subscription.
- Your aggregated star rating can be used on free plans, cited as "Source: G2.com, Inc." with a link to your profile.
- Never republish another vendor's aggregated star rating.
Capterra, which G2 agreed to buy in January 2026 and whose May 2026 policy now names G2, has its own policy: quotes must be under 12 months old, used verbatim, and carry a disclaimer, which a character-limited format can skip only if it links to a page hosting the full text.
We found no G2 rule written specifically for search ad text. Our reading: a "#1 on G2" headline can't carry the subscription-backed citation and the link to the report, so keep numeric review-site claims on the landing page, where they fit, and keep the ad to claims you can back on that page.
Paying for Software Reviews Is Legal Only When the Payment Doesn't Depend on the Stars. A Federal Rule Now Says So.
Chapter 8 sent you to your reviews for headlines. Getting more of them has rules too.
The FTC's rule on consumer reviews took effect October 21, 2024. It makes it unfair or deceptive to give incentives "conditioned expressly or by implication on... consumer reviews expressing a particular sentiment, whether positive or negative." The FTC's own guidance is that a neutral incentive, offered for any honest review, is allowed if it's disclosed. The FTC's guides on endorsements go further on the other side: paying for positive reviews is deceptive "even if the payment is disclosed."
The review sites set their own limits. G2 caps the value of any incentive at $100 and labels incentivized reviews. Capterra requires that incentives be "offered equally to all eligible participants, regardless of the rating provided."
So: ask every customer, offer the same thank-you to all of them, never hint that the gift depends on the score and never review your own product through employees. A slightly lower average built on honest reviews is worth more in an ad than a perfect score nobody believes.
Google Learns From Whatever You Count. Count Raw Sign-Ups, and It Goes Looking for More Sign-Ups.
That's the whole guide. Here it is in the order a software account is built:
- Conversion tracking: send qualified leads from the CRM back to Google, not sign-ups.
- Marketing goals: bid on buying searches, not definitions.
- Budget and lifetime value: know what a customer pays back before setting a bid.
- Landing pages and Quality Score: one page per ad group.
- Keyword research: skip the brand names and the junk.
- Exact and broad match: Isolation first, Exploration later.
- Bidding: by hand until about 30 qualified leads a month.
- Ad copy: headlines from buyer reviews, trial terms stated.
- Settings: currency, time zone, countries and defaults.
- Performance Max: only once qualified leads flow.
- Demand Gen: audiences from rivals and searches.
- Brand campaigns: keep login searches out.
- AI Max: last, and tested on qualified leads.
- Competitor campaigns: small, separate and honest.
- Trials and demos: two sales, two goals.
- Trial terms and review rules: this chapter.
Every chapter is also on the guide's home page. For software companies that want the account built this way, our Google Ads management starts with the first chapter: the CRM connection, before a single keyword goes live.
