Washington compliance assistance for subscription coaching platforms

Below is a concise, actionable, and state-specific compliance briefing for subscription-based coaching platforms operating in Washington state, plus a practical checklist you can use to update contracts, billing, tax registration, and consumer-facing processes.

Key Washington requirements and risks

Below is a concise, actionable, and state-specific compliance briefing for subscription-based coaching platforms operating in Washington state, plus a practical checklist you can use to update contracts, billing, tax registration, and consumer-facing processes.

Key Washington requirements and risks

Automatic renewal / "auto-renewal" rules (state law and proposed/updated statutes) - Washington’s legislature has enacted and considered laws adding consumer-protection requirements for automatic renewals in business contracts. Required disclosures include

(a) a statement that the contract will be renewed or extended unless the customer declines renewal; (b) the duration of the additional contract period that would result from an automatic renewal; (c) whether an increase in charges will apply upon renewal; (d) a description of the action the customer must take to decline renewal; and (e) the deadline for the customer to decline renewal. Failure to comply can render an automatic renewal provision unenforceable. (Source: WA bill text/law language.)

Washington Attorney General enforcement focus - The WA Attorney General’s office has prioritized subscription/auto-renewal issues as part of its consumer-protection "Honest Fees" initiative, surveyed consumers about unintentional enrollments, and pursued enforcement/resolutions requiring clear disclosures, advance reminder notices, and easy cancellation options. Expect enforcement risk and potential investigations if terms are not clear and conspicuous. (Source

WA AG coverage and enforcement actions.)

Sales tax, B&O tax, and digital/IT services changes (important tax developments affecting subscriptions) - Washington’s Dept. of Revenue (DOR) treats many subscription-delivered digital products and digital automated services (DAS) as taxable retail services. The DOR guidance and new laws (effective Oct 1, 2025 and related notices) expanded sales tax to certain IT and digital services; sales/use tax apply to digital products, streamed/subscription digital goods, and DAS unless a specific exclusion applies. Sellers with nexus in WA must collect retail sales tax on taxable digital products and are subject to B&O tax (retailing classification) for retail sales sourced to Washington. DOR guidance also lists relevant RCW/WAC citations and sourcing rules. (Source

WA DOR pages on "Services subject to sales tax" and "Digital products including digital goods.") - Importantly, DOR guidance excludes "live interactive presentations" and services that primarily involve human effort performed after a customer requests the service from the DAS definition — this affects coaching that is delivered live or is substantially human-driven rather than prewritten automated digital content. Determine whether coaching is taxable as DAS/RAS/digital product or instead taxable as a service subject only to B&O (and not sales tax) under the DOR rules and definitions.

Business registration and nexus - Platforms doing business in Washington should register with the WA Dept. of Revenue (seller’s tax registration) and the WA Business Licensing Service (if required for the type of business). If you have economic nexus (sales into WA) or physical presence, you must register, collect sales tax where applicable, and remit B&O tax; DOR provides sourcing rules to determine local rates.

Payment, consumer-protection, and recordkeeping best practices - Ensure affirmative consent and clear, conspicuous disclosures at point of sale; send advance reminder notices for renewals where required; provide an easy cancellation mechanism (preferably using the same medium the customer used to enroll); retain records of the customer’s consent, confirmation emails, renewal notices, and cancellations; and include clear pricing, renewal dates, and notice of any future price increases. - Prepare for consumer complaints and AG/FTC enforcement

maintain internal compliance documentation and a consumer-complaint handling process. Practical checklist — what to do now (actionable steps for platform owners/LLC founders) A. Contracts & checkout flow - Add explicit auto-renewal disclosure at checkout (renewal statement, renewal term length, price/price-change disclosure, cancellation process, deadline to cancel). Archive the user-facing text and the timestamp of acceptance. - Require affirmative consent (a clear checkbox not pre-checked or similar mechanism) before charging recurring fees; email a confirmation with the same renewal terms. - Build a reminder-notice workflow for renewals where required by statute or by AG settlement terms (timing and content as required by the law or settlement — e.g., advance notice period and content describing it is a renewal). B. Cancellation and refunds - Implement an easy cancellation path (self-service via account settings, or email/phone if that matches enrollment channel) and document cancellations. State laws and AG expectations favor same-or-similar means of cancellation. - Publish a refund/cancellation policy that is compliant with disclosures made at purchase. C. Taxes and registration - Register with WA Dept. of Revenue and the Business Licensing Service if you meet nexus/registration thresholds. - Classify your offerings per DOR guidance: determine whether subscriptions are taxable as digital automated services/remote access software/digital products or are excluded because they are live, human-delivered coaching. If taxable, collect retail sales tax (sourced per DOR rules) and remit B&O tax accordingly. - For multi-state sellers, implement sales tax sourcing rules and ensure correct rate calculations for Washington customers. D. Data, payments, and privacy - Use PCI-compliant payment processors; keep records to demonstrate consent and notices sent. - Comply with privacy/data requirements (state and federal), particularly if you gather health information (if coaching overlaps with health or therapy, consider HIPAA implications and state health licensing rules). If your coaching could be construed as licensed practice (behavioral health, medical advice), consult counsel and the WA Department of Health to confirm licensing requirements. E. Monitoring and enforcement preparedness - Monitor WA AG guidance and FTC enforcement trends for subscription services; respond quickly to consumer complaints; maintain internal compliance logs and a remediation plan.