What California AB 2426 changed (and what it didn't)

In September 2024, California became the first US state to pass a law aimed specifically at the gap between what digital storefronts say ("Buy now!") and what they deliver (a revocable license). AB 2426 took effect January 1, 2025. Here's what it actually does.

The core rule

AB 2426 amends California's false advertising law. A seller of digital goods — games, applications, movies, TV, music, ebooks — may not advertise or sell with terms like "buy" or "purchase" unless one of two things is true:

1. The seller provides a downloadable copy the customer can keep and use offline, without the seller's continued involvement; or
2. The customer affirmatively acknowledges, at the time of the transaction, clear and conspicuous language stating that they are buying a license, that the license can be revoked, and where to find the full terms.

That's why disclosure notices appeared at digital checkouts, including Steam's, in late 2024: sellers choosing option 2 must actually show you the license language rather than bury it in a EULA.

What's exempt

• Subscriptions — services advertised as access-for-a-term (Game Pass, Netflix) were already understood as rentals; the law targets transactions dressed as purchases.
• Free goods — no money, no disclosure duty.
• Permanent offline downloads — sellers who actually hand you the file (DRM-free storefronts) already satisfy option 1.

What it does NOT do

This is the part advocacy coverage most often overstates, so we'll be precise. AB 2426:

• Does not prevent revocation. A platform can still remove purchased content; the law only requires that you were told it could.
• Does not require refunds when access is revoked.
• Does not require offline copies, end-of-life patches, or server handoffs for games that die with their servers.
• Does not apply retroactively to purchases made before 2025.

AB 2426 is a transparency law. It fixed the honesty problem, not the ownership problem.

Why it still matters

First, disclosure creates a legal fact: after AB 2426, no seller can claim customers understood "buy" to mean "own." Second, it's a working template — a state consumer-protection framework that survived the legislative process with industry lobbying present. The next steps for states that want to go further are natural extensions of the same framework:

• Restitution: require a pro-rated or full refund when a paid digital good is revoked.
• Continuity: require an offline copy or end-of-life plan for products that cannot outlive their servers.

Our state tracker monitors which legislatures are moving on any of this, and the action center has a letter template built on the AB 2426 model.