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Subscription CancellationMay 27, 2026
The FTC’s Negative Option Rule (ROSCA) — What Companies Must Do When You Want to Cancel
ROSCA and the FTC Negative Option Rule require companies to make cancellation simple. Here’s what the rule says, who it applies to, and how to cite it in a cancellation request.
The Restore Online Shoppers’ Confidence Act (ROSCA, 15 U.S.C. §§ 8401-8405) and the FTC’s Negative Option Rule (16 CFR Part 425) are the primary federal laws governing subscription cancellation. If a company makes it easy to sign up but hard to cancel, these rules apply.
What ROSCA Requires
ROSCA addresses “negative option” marketing — any arrangement where silence or failure to act is treated as acceptance of an offer. Under ROSCA, sellers must:
• Clearly and conspicuously disclose all material terms of the transaction before obtaining billing information
• Obtain the consumer’s express informed consent before charging
• Provide a simple mechanism to stop recurring charges and cancel
Violation of ROSCA is treated as an unfair or deceptive act under the FTC Act.
The Click-to-Cancel Principle
The FTC has interpreted ROSCA to mean that cancellation must be at least as easy as sign-up. If you subscribed online with a few clicks, the company must generally provide an equally simple online cancellation path. Requiring a phone call, certified letter, or in-person visit when the subscription was initiated online may violate this principle.
Who ROSCA Applies To
ROSCA applies to any person or entity that charges consumers through negative option features in online transactions. This includes:
• Gym memberships sold online
• SaaS and software subscriptions
• Streaming services
• Telecom services sold online
• Mobile app subscriptions
• Any subscription where you provided billing information online
ROSCA is federal law — it applies in all 50 states.
How to Cite ROSCA in a Cancellation Email
An effective reference reads: “Under the Restore Online Shoppers’ Confidence Act (ROSCA), 16 CFR Part 425, sellers offering negative option features are required to provide consumers with a simple mechanism to stop recurring charges. I am exercising that right and revoking authorization for future charges to my payment method.”
This is factual, cites the specific rule, and states what the consumer is doing — without evaluating the case or predicting an outcome.
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Generate your free cancellation emailsThis article provides general information about consumer protection statutes. It does not constitute legal advice and does not evaluate specific claims. Statutes may be amended; verify current law with official sources. Consider consulting a licensed attorney for advice about your specific situation.