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For GC & Heads of Growth at subscription companies

Click-to-cancel is dead. Your cancel-flow risk isn't.

In July 2025 a federal court threw out the FTC's click-to-cancel rule. Since then the FTC has kept enforcing under ROSCA and Section 5 — Amazon settled Prime for $2.5 billion — while California, New York and a dozen more states passed their own auto-renewal laws. The rules are in flux; the enforcement is not.

Scored against the live rulesCA ARL · AB 2863NY Auto-RenewalROSCA · 15 U.S.C. §8401FTC Act §5

Built by Merrowby. Every date and figure on this page is public record, and we cite the statute and the settlement behind each one, so you can check our work.

Form CP-1 — Self-Audit
Not legal adviceAnswered 0 of 10

Self-audit your cancel flow

Ten yes/no questions about your live signup-to-cancel journey. It runs entirely in your browser — nothing is sent anywhere until you ask for the full report.

  1. Can a customer who signed up online cancel online, without a phone call or email?

    Same-medium cancellation is now the baseline in California and New York.

    CA ARL · AB 2863
  2. Does cancelling take about the same number of steps as signing up — no extra survey screens or hurdles?

    Regulators have treated multi-screen cancel mazes as an unfair practice.

    FTC Act §5 · 15 U.S.C. §45
  3. Is your cancel flow free of a forced retention offer the customer cannot skip?

    A 'save' offer is fine — as long as it can't trap the customer from finishing.

    FTC Act §5 · 15 U.S.C. §45
  4. Before the first charge, do you clearly show the price, billing frequency, and that it auto-renews?

    The disclosure has to be clear and conspicuous, not buried in linked terms.

    CA ARL · AB 2863
  5. Do you capture separate, affirmative consent to the auto-renewal itself — not just a link to your terms?

    'Express affirmative consent' to the renewal is required, distinct from accepting terms.

    CA ARL · AB 2863
  6. If you run a free trial, do you disclose when it converts to paid and at what price before it converts?

    Free-to-pay conversions are squarely in scope, and a recent ROSCA settlement turned on this.

    ROSCA · 15 U.S.C. §8401
  7. Do you email a renewal reminder before the charge — e.g. 15–45 days before an annual renewal?

    New York and California both require pre-renewal notices within set windows.

    NY Auto-Renewal
  8. Before you raise a subscriber's price, do you get consent or give a cancel window with a pro-rata refund?

    New York now requires advance consent to increases or a 14-day cancel-and-refund window.

    NY Auto-Renewal
  9. When someone cancels, do you confirm it immediately and keep a timestamped record?

    A confirmation and an audit trail are your defence against a 'we never cancelled' dispute.

    ROSCA · 15 U.S.C. §8401
  10. Do charges actually stop the moment someone cancels — no extra billing cycle?

    Charging after a cancellation drew a seven-figure ROSCA settlement in 2025.

    ROSCA · 15 U.S.C. §8401

Get the full CancelProof redline.

Your on-page score is the free version. The redline goes deeper, for your specific flow:

  • Every gap mapped to the exact statute and a recent settlement it turned on.
  • A per-jurisdiction redline: California, New York, and federal ROSCA, in priority order.
  • Monthly automated re-checks that re-walk your live flow and email you when a new gap appears.

Pre-launch. You'll get the first redlines as early access opens. No card, no sales call.

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Why now

The federal rule is in limbo. The enforcement and the state laws are not.

Every date and figure below is a matter of public record: the FTC orders, the state statutes, and the settlements themselves. This is the twelve months your cancel flow has to survive — with or without a federal rule on the books.

  1. Jul 8, 2025

    A federal court throws out the FTC rule

    The Eighth Circuit vacates the FTC's click-to-cancel Negative Option Rule on procedural grounds, days before it was due to take effect.

  2. Jul 1, 2025

    California's AB 2863 goes live

    Same-channel cancellation, clear pre-billing disclosure, express consent to auto-renew, free-trial coverage and annual renewal reminders — all now required on new or renewed contracts.

  3. Sep 2025

    Amazon settles Prime for $2.5 billion

    A $1 billion civil penalty plus $1.5 billion in consumer refunds over deceptive Prime enrollment and a hard-to-cancel flow.

  4. Aug–Sep 2025

    The FTC keeps filing

    It sues LA Fitness over a cancel-only-in-person model (ROSCA) and settles with Chegg for $7.5 million over cancellation and charges that continued after cancel.

  5. Nov 5, 2025

    New York's auto-renewal law takes effect

    Cancellation must be as simple as, and through the same medium as, sign-up; pre-renewal notices are mandatory; price increases need consent or a 14-day cancel-and-refund window.

  6. Dec 2025

    Instacart refunds $60M; Uber is sued

    Instacart settles a ROSCA case for $60 million over undisclosed free-trial conversion; the FTC and 21 states go after Uber One's sign-up and cancel flow.

  7. Jan 30, 2026

    The FTC moves to rebuild the rule

    It sends a draft Advance Notice of Proposed Rulemaking on negative-option plans to OMB — signalling the federal rule is coming back, even as enforcement never paused.

How it works

A browser agent that walks your own cancel flow — every month.

Not a one-time legal memo that's stale the week your site changes. CancelProof re-checks the live journey on a schedule and tells you the moment a new gap opens.

  1. 01

    Point us at your flow

    Give CancelProof the URL of your signup-to-cancel journey and a scoped test account you can revoke. We never touch production customer data, real payment methods, or your admin.

  2. 02

    We walk it like a customer

    A browser agent runs your full journey every month — sign up, get billed, try to cancel — and scores each step against the live California, New York and federal rules.

  3. 03

    You get a redline, not a maze

    A risk-scored report shows exactly where your flow diverges from each rule, mapped to the statute and a recent settlement, with a timestamped audit trail your GC can act on.

Your credentials, your control.

You give CancelProof a scoped test account, never your admin, and you can revoke it the moment a run finishes. We never touch production customer data, real payment methods, or live billing. If your security team needs it, we scope to a sandbox or a throwaway plan, so onboarding doesn't get stuck in review.

Early access

Founding price, before monitoring opens.

CancelProof is pre-launch. Join the early-access list, get your full report, and lock founding pricing before we turn on monthly monitoring. No card, no sales call.

Pre-launch. You'll get the first redlines as early access opens. No card, no sales call.

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Schedule 1 — FeesNot legal advice

$499/mo per flow

Founding price, locked for early-access members. Monthly monitoring, cancel anytime.

  • Monthly automated re-walk of your live signup-to-cancel flow
  • Per-jurisdiction redline: California, New York, and federal ROSCA
  • Every gap mapped to the exact statute and a recent settlement
  • Timestamped audit trail your GC or outside counsel can act on
  • Email alert the moment a new gap appears — law change or site change
Join the early-access list

The honest questions.

Yes — the Eighth Circuit vacated the FTC's rule in July 2025. But that rule was never the whole picture. The FTC still enforces cancellation practices under ROSCA and Section 5 of the FTC Act — that is the basis of the Amazon, Instacart and Chegg cases — and California, New York and a growing list of states have their own auto-renewal laws already in force. The federal rule is in flux; the enforcement is not.

CancelProof is not a law firm and this is not legal advice. It is a monitoring layer: it walks your live flow and flags where it diverges from the specific laws and recent settlements, so your GC or outside counsel spends their time on a prioritized redline instead of hours discovering issues. It makes counsel faster and cheaper to involve; it does not sign off for them.

Those tools can hand you a compliant cancel button, but the risk lives in the whole journey — your checkout disclosures, your consent step, your reminder emails, your retention interstitials, your post-cancel billing. A recent $60 million and a $7.5 million settlement both turned on that surrounding flow, not the button. CancelProof scores the end-to-end journey on your actual site, not a vendor's widget in isolation.

We walk your signup-to-cancel flow with a dedicated test account that you create and can revoke at any time. We never access production customer data, real payment methods, or your admin. If your security team needs it, we scope to a sandbox or a throwaway plan, so onboarding doesn't get stuck in review.

No — and anyone promising that is selling you something. What we do is show you, every month, where your live flow is exposed under the rules that are actually being enforced, so you can fix the highest-risk gaps before a regulator or a plaintiff's lawyer finds them.

Both look at the same flow from two sides. Your GC cares about defensible compliance; your Head of Growth cares that a compliant cancel path doesn't nuke retention. CancelProof gives one shared, prioritized view, so the fix isn't a tug-of-war between the two.

The on-page score and gap list are free — no email needed. The email unlocks your full report: each gap mapped to the exact statute and a recent settlement, a per-jurisdiction redline, and monthly automated re-checks that alert you when a new gap appears as the law or your site changes.

Know where your cancel flow stands.

Run the free self-audit above for an instant read, then get the full report — your gaps mapped to the live rules, re-checked every month.

Pre-launch. You'll get the first redlines as early access opens. No card, no sales call.

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