1. Simple Cancellation (ROSCA)
15 U.S.C. § 8403: Online negative-option sellers must provide a simple mechanism to stop recurring charges. FTC 2021 policy: cancel should be at least as easy as signup and available in the same medium.
⚖️ ROSCA · State ARLs · Post-Vacatur 2026
Subscription Rights & Consumer Protection Suite
The 2024 FTC Click-to-Cancel CFR amendments were vacated in 2025. You still have powerful tools: ROSCA’s simple cancel mechanism, state automatic renewal laws, EFTA/FCBA payment revocation, and bank chargebacks—without forced phone mazes when those laws apply.
2. Disclosure & Consent
ROSCA triad: Clear material-term disclosure and express informed consent before charging. Pre-checked recurring boxes are a classic enforcement red flag.
3. Revocation of Payment Authority
EFTA 15 U.S.C. § 1693e / CFPB Reg E: Consumers may stop/revoke preauthorized recurring electronic transfers with timely bank notice (≥3 business days).
4. California Unconditional Gift Remedy
Cal. Bus. & Prof. Code § 17603: Goods or services provided in violation of California’s Automatic Renewal Law may be deemed unconditional gifts with zero consumer liability.
50-State Auto-Renewal Law & Attorney General Directory
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California Automatic Renewal Law (AB 2863)
Cal. Bus. & Prof. Code §§ 17600–17606
Mandates immediate, friction-free online cancellation parity; unconditional gift status for non-compliant billing (§ 17603); clear pre-purchase disclosures; and standalone affirmative consent.
✓ Cal. B&P § 17603 Unconditional Gift Remedy Active
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LEGAL DISCLAIMER: Privacy Dawg and Outset Solutions LLC provide consumer self-help tools, educational summaries, and automated document synthesis. We do not provide formal legal representation or individualized legal advice. Citations (ROSCA, current 16 CFR Part 425 prenotification rule, EFTA, FCBA, state ARLs) are educational only. The 2024 Click-to-Cancel CFR amendments were vacated July 8, 2025.