Written for owners of hair salons, barbershops, beauty, nail, lash and brow businesses, spas and massage, tanning, tattoo and piercing studios and med spas in the United States.
The short version
- Show the terms before taking card details.Deposit, no-show and membership terms, in plain words, at booking or sign-up. Keep the record that the client agreed.
- Get express consent to the auto-renewal.A clear yes to the renewal terms, with proof kept. California's law covers sales to California clients wherever your salon is.
- Give clients a simple way to cancel.In California, signed up online means cancel online. For online sign-ups, federal law also requires a simple way to stop recurring charges.
Deposits and no-show fees are enforceable when they are disclosed before booking and proportionate to the lost slot. A fee charged to a card on file needs the client's agreement to that specific policy, so show it at booking and keep the record.
Online memberships: federal law still applies
The FTC's 2024 click-to-cancel amendments were vacated on July 8, 2025, and the FTC opened a new rulemaking in March 2026. Federal law still governs online negative-option sales: you must clearly disclose all material terms before taking billing information, get express informed consent before charging, and provide a simple way to stop recurring charges. State automatic renewal laws may add more. As of Oct 2026.
ROSCA, 15 U.S.C. 8403
California's Automatic Renewal Law
It applies to sales to California consumers, wherever your salon is. A client who signed up online must be able to cancel online, at will, as required since July 1, 2022. For a contract entered into, amended or extended on or after July 1, 2025, you also need express affirmative consent to the automatic renewal terms, verification of that consent kept for at least 3 years or 1 year after the contract ends, whichever is longer, an annual reminder for an annual renewal, and cancellation in the medium the client used to sign up or usually uses with you. As of Oct 2026.
California Bus. and Prof. Code 17600 et seq. and 17602 (online cancellation as amended by AB 390, from July 1, 2022)
New York (GBL 527 and 527-a) and Florida (Fla. Stat. 501.165) have their own automatic renewal laws. The safe pattern everywhere: clear terms, affirmative consent, an acknowledgment and an easy way to cancel.
California's law follows the consumer, not the salon's address.
A signed consent form documents informed consent, but it rarely waives negligence, so do not rely on it against an injury claim. The lesson on when it goes wrong covers what to do the day one happens.
Business contracts to read twice
- A booth rental agreement that sets prices, hours, dress code or product quotas, or charges rent as a percentage of the renter's sales through your POS: the renter can become your employee for wage law and taxes, and in California it breaks the Lab. Code 2778 conditions.
- A med spa management agreement that pays the management company a percentage of medical revenue or gives it control of clinical staff or protocols: corporate practice and fee-splitting risk in strict states.
- A medical director agreement with no on-site time, no chart review and no good-faith exam process: a board finding waiting to happen.
- A lease without assignment rights or with a narrow use clause such as 'hair salon only': it blocks a sale or adding med spa services.
- A franchise or salon suite deal: a prospective franchisee must get the current disclosure document at least 14 calendar days before signing a binding franchise agreement or paying the franchisor or an affiliate (16 C.F.R. 436.2(a)). A salon suite agreement falls under the rule only if it meets the federal definition of a franchise (16 C.F.R. 436.1(h)), so take advice before signing.
- A booking platform that charges marketplace fees on returning clients or limits your data export.
Asked in Greymill
For your California members:
Consent: for contracts made, changed or extended from July 1, 2025, you need express affirmative consent, a clear and active yes, to the renewal terms.
Records: keep proof of that yes for at least 3 years or 1 year after the contract ends, whichever is longer (As of Oct 2026).
Canceling: they joined online, so they must be able to cancel online. Phone-only fails.
For everyone, federal law on online memberships still requires:
Before card details: clear terms
Before charging: express informed consent
To cancel: a simple way to stop the charges
The easy fix: online cancellation, plus the consent and acknowledgment steps, for everyone who signs up online.
Paste your sign-up page here and I'll redraft the wording and cancel steps to meet both sets of rules.
Ask it about your own business
Paste this into Greymill with your own figures, and Contracts & Disputes works it through for your business.
I run a salon or beauty business in [state], in the US. Here are my deposit, no-show and membership terms: [paste], and how clients sign up and pay: [online, app, in person, card on file]. I have clients from [states]. Check each term against the federal rules and the automatic renewal laws that apply, tell me what would not hold up, and redraft the sign-up wording and the cancellation steps.
More for beauty, hair and aesthetics in the US
- Pricing a color service so it still pays after commission and productPrice each service from the provider's time and product, check what commission leaves you, and track service sales per available hour before you change the menu.Read the lesson
- We sold a stack of gift cards in December. Why is cash tight now?Gift card and deposit money is service you still owe, no-shows are hours you never get back, and a 13-week cash view shows both before they hurt.Read the lesson
- Am I claiming the FICA tip credit, and do I owe tax on back-bar color?Salons can now claim the FICA tip credit on employees' tips, while back-bar product and New York City's service tax catch out owners who never checked.Read the lesson
- Adding laser, microneedling, injectables or tattoos: whose license covers it?Every state licenses the person and the shop separately, scope of practice decides what an esthetician may do, and injectables, and in most states lasers that affect living tissue, are the practice of medicine.Read the lesson
- Commission stylists, '1099' stylists and booth renters: am I underpaying or misclassifying?A booth renter must really run their own business, and every commission employee needs a minimum wage and overtime check each workweek.Read the lesson
- Getting more five-star reviews and Instagram bookings without breaking FTC rulesRebooking, reviews, portfolios and texts bring in salon clients, and each comes with federal rules on incentives, endorsements, photos and consent.Read the lesson
- A client was burned, reacted or had an injectable complication: what do I do today?The first hours after a burn, reaction or injectable complication decide the client's outcome and whether your insurance responds, so act in order and admit nothing.Read the lesson
Open the interactive lesson · Every beauty, hair and aesthetics lesson · What Greymill knows about the trade
Sources
The primary sources behind this lesson, checked Oct 2026.
- CCP 335.1; CPRC 16.003; CPLR 214; Fla. Stat. 95.11 (Client complaints, deposits and memberships)
- California Business and Professions Code s. 17602(a)(4), (a)(6), (d), (f), (h) and (j) (Client complaints, deposits and memberships)
- 91 FR 6507, section I.A, vacatur and restoration of the prior rule (Client complaints, deposits and memberships)
- 16 C.F.R. 436.1(h), federal franchise definition; 436.2(a), disclosure at least 14 calendar days before signing or payment (Contract red flags)