Subscription Cancellation Dark Patterns — FTC 16 CFR 425
The FTC's amended Negative Option Rule (16 CFR Part 425) mandates that cancelling a subscription must be as easy as signing up. Violations carry penalties of $51,744 per instance. Most SaaS platforms still use forced-retention flows.
The law creating this problem
The FTC's Click-to-Cancel provision, effective since March 2025, amends the Negative Option Rule to require that businesses provide a cancellation mechanism that is at least as easy as the signup mechanism. It also mandates explicit informed consent for auto-renewal, prohibits pre-ticked consent boxes, and requires affirmative consent before presenting retention offers.
Penalties start at $51,744 per violation. The FTC has already signalled aggressive enforcement, with actions against Amazon, ABCmouse, and others serving as precedent.
Who is affected
Any business operating in the US with a subscription model, recurring billing, or auto-renewal mechanism. This includes SaaS, media subscriptions, membership clubs, and subscription box services.
What currently exists
Most compliance checks happen reactively — after an FTC inquiry or consumer complaint. Existing legal review processes take weeks and cost $5,000–$20,000. No tool provides instant, clause-level mapping of your cancellation flow against the rule.
What we're building
A question-by-question diagnostic that walks through your subscription lifecycle — signup, consent gathering, renewal notices, cancellation flow — and maps each answer to a specific 16 CFR 425 requirement, producing a compliance score and exposure estimate.
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Qualifying question
Does your business offer subscriptions, recurring billing, or auto-renewal?
What happens after you sign up
You will receive an email when the diagnostic is available. We do not share your email. Typical development cycle: 4–6 weeks from waitlist open.