Belgium’s Act of 20 April 2026 introduces a new notification obligation for businesses that use automatic renewal clauses in fixed-term B2C contracts. From 1 May 2027, businesses must inform consumers at least 15 days before the consumer’s deadline to object to a renewal.
The existing and new rules are set out in Article VI.91 of the Belgian Code of Economic Law and apply to:
- B2C service contracts (e.g. fitness, streaming, app subscriptions); and
- B2C contracts combining the sale of goods with a service element (e.g. a mobile service contract that includes a mobile phone). Goods-only sales contracts fall outside the scope.
What do the existing rules already require?
If you are offering fixed-term contracts to consumers, the law already sets requirements for automatic renewal clauses.
Under the current rules, the renewal clause must appear in bold, in a separate box, on the front page of the contract. It must spell out the consequences of renewal, how to object, and the deadline for objection.
Once a contract has been automatically renewed, the consumer can terminate at any time, subject to a notice period of no more than two months.
What’s new? A prior notification obligation
The Act of 20 April 2026 does not replace the existing rules, but complements them. From 1 May 2027, businesses must proactively inform the consumer of an upcoming automatic renewal before it happens. The Act contains no transitional provision, which means the new obligation will apply to any automatic renewal occurring on or after that date.
The notification must be provided on a durable medium (such as an email), in a clear, comprehensible and unambiguous manner, at the latest 15 days before the consumer’s deadline to object. The notification must also remind the consumer of their right to object.
Contracts concluded for a term of one month or less are exempt from this new obligation.
What happens if you don’t comply?
Here is the notable gap in the new legislation: the Act does not introduce any specific sanction for failing to send the notification. Non-compliance does not automatically void the renewal, nor does it entitle the consumer to compensation. The consumer’s primary protection remains that they may terminate the renewed contract at any time, without compensation, subject to a notice period that cannot exceed two months. However, this right already exists and is nothing new.
A damages claim is theoretically possible under general civil liability principles, but the consumer bears the burden of proving actual damage and a causal link. On the public enforcement side, a deliberate, bad-faith breach of Book VI CEL could in principle attract a criminal or administrative sanction.
Conclusion
Businesses operating B2C contracts with automatic renewal clauses should prepare to update their current contracts and customer notification processes by 1 May 2027. At ALTIUS, our Commercial team regularly advises businesses on consumer law compliance and contract management. Do not hesitate to reach out if you need guidance on how to adapt your processes.