Short answer: A med spa membership charges members on a schedule until they cancel, so renewal rules shape how you sell it. For online sign-ups through a negative option feature, a federal statute requires clear terms before billing details, express informed consent and simple ways to stop charges. Google’s ad policies require the price and billing interval of a membership to be clear.
Before you read: This guide explains what a federal statute, a Florida statute and Google’s advertising policies say about selling and advertising a membership. It is general information, not legal advice.
The federal rule for memberships sold online
The FTC’s legal library lists the Restore Online Shoppers’ Confidence Act among its statutes, as 15 U.S.C. §§ 8401 to 8405. Section 8403 covers goods or services sold in a transaction on the Internet through a negative option feature. For that term, it points to the FTC’s Telemarketing Sales Rule.
Under section 8403, it is unlawful to charge a consumer that way unless the seller does all of this:
- It provides text that clearly and conspicuously discloses all material terms of the transaction before it obtains the consumer’s billing information.
- It obtains the consumer’s express informed consent before charging their credit card, debit card, bank account or other financial account.
- It provides simple mechanisms for the consumer to stop recurring charges.
In our view, the sign-up page is where your terms belong. Put the price, the billing interval, what each cycle includes and how to cancel above the card form, in the same type size as the rest.
Florida’s rule on automatic renewals
Florida Statutes section 501.165 covers service contracts with an automatic renewal provision. It defines that as a provision that renews a contract for a specified period of more than 1 month. The renewal also has to keep the contract in effect more than 6 months after it began.
A seller offering such a contract must disclose the automatic renewal provision clearly and conspicuously in the contract or contract offer. It must also allow the consumer to cancel in the same manner, and by the same means, as the consumer accepted the contract.
A contract of 12 months or more that renews for a specified period of more than 1 month needs a written or electronic notice too. The seller sends it no less than 30 days or no more than 60 days before the cancellation deadline.
That notice says clearly and conspicuously that the contract will renew unless the consumer cancels. It also says how the consumer can get the details of the renewal and of the cancellation procedure.
A violation of subsection (2), which holds all of these requirements, renders the automatic renewal provision void and unenforceable. A failure caused by an error isn’t a violation if the seller shows it follows written procedures to comply and refunds the unearned part of the contract. The statute also lists entities it doesn’t apply to, among them financial institutions and a health studio as section 501.0125 defines it.
The definition turns on how long each renewal period and the whole contract last. Check whether your plan’s terms fall under it, and which rules your state adds if you aren’t in Florida.
Advertising a membership on Google
Google’s Misrepresentation policy has a part on dishonest pricing practices. Under that part, the payment model and the full expense a user takes on, before and after purchase, have to be disclosed clearly and conspicuously.
Google calls its examples non-exhaustive. They include not clearly showing the price and billing interval for subscriptions or memberships. Omitting recurring costs and the billing interval is one too, and so is not disclosing the total price with all taxes, fees and surcharges.
Promoting a free trial without clearly stating the trial period, or that the user will be automatically charged at the end of it, is another of Google’s examples.
Google asks that your landing page or app clearly and conspicuously disclose how your billing process works and the full expense a user will pay. It says a site shouldn’t hide costs with similar or identical text and background colors, very small fonts, or other page elements.
For this policy, Google says it issues a warning at least 7 days before it suspends an account. Our guide to pricing pages explains how a service business can show its prices on its website.
What to decide before you launch it
In our view, a membership works when a patient can explain it in one sentence: what they pay, how often, and what they get each time.
In our view, write down the price and billing interval, what each cycle includes, whether unused treatments carry over, when billing starts and how a member cancels. Those answers become your terms, your sign-up page and your ads.
In our view, let members cancel the same way they joined, so someone who signed up online can also leave online. For the contracts it covers, the Florida statute requires exactly that.
In our view, which treatments a plan includes, and how often, is a clinical decision before it is a pricing one, so your medical director signs off on it.
Telling patients about it
Members and leads hear about a plan through email, texts and your site. Our guide to HIPAA and patient messages covers what a clinic can send by email, text or WhatsApp. Our guide to TCPA rules for texts covers consent, hours and opt-outs.
For promotions beyond the membership, our guide to med spa marketing ideas covers what to try and what Meta and the FTC allow.
Set up a membership, step by step
- Write the terms: price, billing interval, what each cycle includes, renewal and cancellation.
- Show all material terms on the sign-up page before the card details, and get the patient’s express informed consent to the charge.
- Let members stop the charges through a simple mechanism, the same way they joined.
- If the Florida statute covers a contract of 12 months or more, send the renewal notice 30 to 60 days before the cancellation deadline.
- Show the price and billing interval in your ads and on the landing page, and state any free trial period and the automatic charge after it.
Steps 2 to 5 come from the federal statute, the Florida statute and Google’s policy. Step 1 is our advice.
Before you launch it
- The price and billing interval appear in the ad and on the landing page.
- All material terms appear before the card details.
- The patient gives express informed consent to the recurring charge.
- Members can stop the charges simply, the same way they joined.
- Any free trial states its length and the automatic charge at the end.
- You have read your terms against your state’s law.
RememberA membership is a recurring charge, so the terms come first. Show the price, billing interval and cancellation before the card form, get express informed consent and make stopping simple. Florida adds a renewal notice for longer contracts, and Google wants the price and billing interval clear in ads.
Through our med spa marketing service, we help med spas get found on Google for each treatment. We run Facebook and Instagram ads that end in a WhatsApp chat, and Google Search campaigns in an account in your name.
Questions about med spa memberships
Does a med spa membership have to follow automatic renewal laws?
It depends on how and where you sell it. A federal statute covers goods or services sold online through a negative option feature, and the Florida statute covers service contracts with an automatic renewal provision as it defines one. Which rules apply depends on your plan’s terms and your state.
What must a membership sign-up page show?
For online sales through a negative option feature, the federal statute requires text that clearly and conspicuously discloses all material terms before the seller obtains billing information. The seller also needs express informed consent before charging, and simple mechanisms for the consumer to stop recurring charges.
How do members cancel under Florida’s rule?
The Florida statute covers service contracts with an automatic renewal provision. The seller must allow the consumer to cancel in the same manner, and by the same means, as the consumer accepted the contract. A violation renders the renewal provision void and unenforceable. A failure caused by an error isn’t a violation if the seller shows it follows written procedures to comply and refunds the unearned part of the contract.
What does Google require in an ad for a membership?
Google’s Misrepresentation policy lists not clearly showing the price and billing interval for subscriptions or memberships among its examples of dishonest pricing practices. Promoting a free trial without clearly stating the trial period, or that the user will be charged automatically when it ends, is another example.
Does Florida require a renewal reminder?
For a contract of 12 months or more that renews for a specified period of more than 1 month, yes, except for the entities the statute excludes. The seller sends written or electronic notice no less than 30 days or no more than 60 days before the cancellation deadline. It says the contract will renew unless the consumer cancels, and how to get the details.
Sources
We read these pages on November 8, 2026. The FTC: Restore Online Shoppers’ Confidence Act. Cornell’s Legal Information Institute: 15 U.S. Code § 8403 - Negative option marketing on the Internet. The Florida Legislature’s Online Sunshine: The 2026 Florida Statutes, section 501.165. Google’s Advertising Policies Help: Misrepresentation and Dishonest pricing practices. On our site: our page for med spas, plus our guides to med spa marketing ideas, HIPAA and patient messages, TCPA rules for texts and pricing pages.