What changed after the FTC's click-to-cancel rule was vacated, what statutes still protect you, and the escalation path that actually returns money to your account.
Last updated: May 18, 2026
If you were charged today and want your money back, do this in order:
On July 8, 2025, the U.S. Court of Appeals for the Eighth Circuit vacated the FTC's amended Negative Option Rule, also known as click-to-cancel, in Custom Communications, Inc. v. FTC, No. 24-2691. The compliance deadline was six days away. The court found the FTC skipped a required preliminary regulatory analysis once an Administrative Law Judge determined the rule's compliance cost would exceed $100 million per year, a Section 22 violation under the FTC Act. The rule is gone, but the underlying federal scaffolding that grounds refund rights is intact: ROSCA, Section 5 of the FTC Act, the Fair Credit Billing Act, and a thickening patchwork of state auto-renewal statutes. The FTC restarted the rulemaking process on March 11, 2026, but a replacement rule is at least a year away.
Meanwhile, the largest refund recoveries of the past year did not come from rules. They came from enforcement actions: Amazon's $1.5 billion Prime refund pool (Sept 2025), Instacart's $60 million FTC settlement (Dec 2025), Chegg's $7.5 million FTC settlement (Sept 2025), HelloFresh's $7.5 million California DA settlement (Aug 2025), Equinox's $600,000 NY AG settlement (June 2025), MUBI's $1.6 million class action. The rest of this guide tells you which statute applies to your situation and exactly who to escalate to.
Every successful refund claim rests on at least one of these. Identify yours before contacting anyone.
The Restore Online Shoppers' Confidence Act requires online sellers using negative option billing to: (a) clearly and conspicuously disclose all material terms before obtaining billing information, (b) obtain the consumer's express informed consent, and (c) provide a simple cancellation mechanism. ROSCA survived the rule vacatur intact. Violations are unfair or deceptive practices under Section 5 of the FTC Act, with civil penalties up to $53,088 per violation in 2026.
What it gets you: ROSCA does not directly mandate refunds for unused time, but a ROSCA violation invalidates the underlying consent. The FTC has used ROSCA in nearly every major subscription enforcement action of the past two years, including Amazon Prime, where the agency argued obstructed cancellation was a ROSCA breach.
This is where refunds actually live. California Business and Professions Code § 17602 is the strongest: if a business charges a consumer for a continuous service without first obtaining affirmative consent to clear and conspicuous renewal terms, the goods or services are deemed an unconditional gift. The consumer keeps what they got and is entitled to a refund of every unauthorized charge. AB 2863, effective July 2025, requires online sign-ups to be cancellable online. New York's amended GBL §§ 527 and 527-A, effective November 5, 2025, requires affirmative consent to price increases or a prorated refund within 14 days of the first higher charge.
What it gets you: Real money. The class actions cited below were all built on state ARL theories.
The most powerful consumer tool, period. The FCBA, implemented through Regulation Z at 12 CFR § 1026.13, lets you dispute a credit card billing error within 60 days of the statement date showing the charge. Categories include unauthorized charges, services not delivered, and charges for goods or services not as agreed. Your issuer must acknowledge in 30 days, resolve within two billing cycles (cap of 90 days), and cannot charge you finance fees on the disputed amount during the investigation.
What it gets you: A provisional credit fast, often within days. Debit cards are weaker: the Electronic Fund Transfer Act (15 U.S.C. § 1693f) governs them, with shorter dispute windows and no statutory protection against being on the hook while the bank investigates.
The catch-all. Section 5 prohibits "unfair or deceptive acts or practices in or affecting commerce." Dark-pattern signup, obstructed cancellation, hidden auto-renewal, misrepresented free trials: all of these are Section 5 violations. State analogs (UDAP statutes) exist in every state. After the click-to-cancel vacatur, Section 5 is the FTC's primary enforcement hook, and the agency has not slowed down: the Amazon Prime case (FTC v. Amazon.com, Inc., No. 2:23-cv-00932, W.D. Wash.) was pleaded under both ROSCA and Section 5.
If the service materially degrades or removes features you paid for, you have a basic breach-of-contract claim. Most app-store subscriptions are also governed by Apple Media Services Terms or the Google Play Terms of Service, which carve out their own refund discretion. These contractual paths are slower than chargebacks but matter when a chargeback would be denied (for example, the merchant proves delivery of the service).
More than 25 states now regulate auto-renewing subscriptions. These are the heavyweights consumers actually invoke when seeking refunds in 2026.
| State | Statute | Refund hook |
|---|---|---|
| California | Bus. & Prof. Code §§ 17600–17606 | Unauthorized charges deemed unconditional gifts. Online sign-up requires online cancellation (AB 2863, July 2025). |
| New York | GBL §§ 527, 527-A (amended Nov 5, 2025) | Affirmative consent to price increases or a prorated refund within 14 days of the first higher charge. |
| Colorado | SB 25-145 (effective Feb 16, 2026) | One-step online cancel link if signed up online. Extends to B2B subscriptions. |
| Virginia | Va. Code § 59.1-207.46; H.B. 744 (eff. July 1, 2024) | Renewal notice required for renewals causing contracts to run past 12 months. |
| Illinois | 815 ILCS 601 | Reminder notice required for free-to-paid conversions of 30+ days. Refund recoveries common via private suits. |
| Oregon | ORS 646A.295 | Annual renewal reminders; failure invalidates the renewal. |
| Florida | Fla. Stat. § 501.165 | Written consent for auto-renewal contracts over $30 with terms over 12 months. |
| Washington, D.C. | D.C. Code § 28-3905a | Strict disclosure rules and easy cancellation enforced by D.C. AG. |
For your state's full ARL text, see your AG's consumer protection page. For deeper coverage, read our guide to auto-renewal laws.
If the charge came through an app store, the platform is the gatekeeper. The card-issuer dispute path still exists but app stores will block your account if you chargeback without trying their flow first.
Refunds to credit/debit cards post in up to 30 days. Apple Account credit posts within 48 hours. Apple's Media Services Terms govern the discretion, not federal law, so escalation works best when you can point to an objective fact (unauthorized, defect, charged after cancellation).
Google's subscription policy: canceling preserves access through the paid period but does not refund the current cycle unless there is a billing error or policy violation. For old developer-handled charges, a card chargeback is often faster than the second-tier appeal.
Most consumers underuse the FCBA. The statute (15 U.S.C. § 1666) is one of the strongest consumer protections in U.S. law, and card issuers process billions in chargebacks each year. The catch: you have to do it right, and you should not do it casually.
Your written notice must reach the issuer no later than 60 days after the first periodic statement showing the charge. After day 60, you fall back on issuer goodwill and Visa/Mastercard rules (typically 120 days from the charge for "services not provided").
When you dispute, the merchant has roughly 20 to 45 days (depending on network rules) to rebut with evidence: terms of service screenshots, IP logs, the click-stream showing consent, prior usage records. Subscription chargebacks are won and lost on documentation. Save cancellation confirmation emails, screenshots of the "subscription canceled" status page, and any chat transcripts with support. Bank's online dispute form first; written follow-up letter sent certified mail second.
Where the big money has actually moved in the past 12 months. If you were charged by any of these companies in the relevant window, file before the deadline expires.
FTC v. Amazon.com, Inc., No. 2:23-cv-00932 (W.D. Wash., settled Sept 2025). Eligibility: U.S. customers enrolled through a "challenged enrollment flow" or who tried to cancel online and could not, between June 23, 2019 and June 23, 2025, and who used three or fewer Prime benefits in any 12-month period. Maximum refund: $51 per claimant. Automatic payments went out Nov–Dec 2025; claims window opened Jan 5, 2026; deadline July 27, 2026. File at subscriptionmembershipsettlement.com.
FTC v. Maplebear Inc. d/b/a Instacart, N.D. Cal., December 2025. The FTC alleged Instacart failed to disclose that free Instacart+ trials would convert to paid subscriptions and obstructed cancellation, in violation of ROSCA and Section 5. Eligible consumers charged for Instacart+ without express informed consent will receive refunds from the $60 million fund. Refund distribution is administered by the FTC; visit ftc.gov/enforcement/refunds.
In the Matter of Chegg, Inc., FTC Docket No. C-4782. The FTC found Chegg charged nearly 200,000 consumers after they had requested cancellation, in violation of ROSCA. The $7.5 million payment funds consumer refunds. Eligible Chegg subscribers are being contacted directly by the FTC's redress administrator. Notably, this settlement landed two months after the click-to-cancel vacatur, demonstrating that ROSCA alone is enough.
Los Angeles and Santa Clara County DAs, settled August 14, 2025: $6.38M civil penalties, $120K investigative costs, $1M consumer restitution. California residents enrolled in HelloFresh auto-renewal subscriptions between January 1, 2019 and August 18, 2025 who canceled after the first shipment without a refund were eligible. The claim window closed December 17, 2025. Future claimants on similar facts can still file directly with the DAs' restitution programs.
NY AG Letitia James settled with Equinox Group for obstructed cancellation and inadequate renewal disclosures. Refunds up to $250 for subscribers who filed cancellation complaints between Feb 9, 2021 and Dec 31, 2024 (with Equinox, the BBB, the FTC, or the AG), and up to $100 for other eligible NY members. The initial claim email deadline was August 2, 2025; late submissions are reviewed at the AG's discretion.
California residents who subscribed on or after April 1, 2021 and were renewed between April 1, 2021 and May 31, 2025 without receiving full refunds. Claim deadline: June 9, 2026. File through the settlement administrator listed in the class notice.
FTC v. JustAnswer LLC, N.D. Cal., filed January 13, 2026. The FTC alleges JustAnswer marketed "$1" or "$5" expert answers while silently enrolling consumers into recurring subscriptions of $28 to $125 per month, in violation of ROSCA. JustAnswer has moved to dismiss. If the case settles in 2026, a refund pool is the likely remedy. Save your billing records if you were affected.
The CFPB's 2024 negative-option guidance is no longer being actively enforced. Since February 2025, the bureau has dismissed most of its open enforcement actions, and in May 2025 it rescinded roughly 70 guidance documents. The bureau remains a complaint-routing channel for credit-card and bank issues at consumerfinance.gov/complaint, but for 2026 subscription disputes the FTC, state AGs, and your card issuer are the active venues.
The EU Consumer Rights Directive grants a 14-day no-questions-asked withdrawal right on most online purchases including digital subscriptions, with exceptions for fully-delivered digital content where the consumer waived withdrawal at checkout.
In the U.S., the FTC's federal Cooling-Off Rule (16 CFR Part 429) is narrow: it covers door-to-door sales and certain telemarketing transactions, not online subscriptions. There is no general federal cooling-off right for online recurring billing. Some state ARLs include refund windows for specific contract types (gym memberships in California under Civil Code § 1812.85, dating services in several states), but no state has a blanket digital-subscription cooling-off rule.
If you signed up within the last few days and want out, your best moves are: (1) cancel immediately through the company's flow, (2) request a goodwill refund within the first 24 hours, (3) check whether your state has a category-specific cooling-off period for the service type. For more, see our cooling-off period guide.
Step 1: Email support with your cancellation confirmation, demand a refund within 7 days. Step 2: If denied, file an FCBA dispute with your card issuer citing "services not provided / cancellation of recurring transactions." Win rate is very high when you have written cancellation evidence.
Step 1: FCBA dispute as "unauthorized transaction." Step 2: File a complaint with your state AG and reportfraud.ftc.gov. Step 3: If a state ARL applies, cite the unconditional-gift or void-renewal provision in writing to the company. California's § 17602 is the gold standard.
Step 1: Request a goodwill refund immediately. Many companies grant it within the first 7 to 14 days. Step 2: Check if you got a renewal-reminder notice as required by your state ARL. Step 3: For app-store charges, use the platform refund flow; for direct-bill, ask for a partial pro-rated refund if you haven't used the service since renewal.
Step 1: Document the change with screenshots before and after. Step 2: Demand a refund in writing citing breach of the subscription agreement. Step 3: If denied, FCBA dispute as "services not as described," attaching your documentation of the feature loss.
This is the textbook ROSCA violation. Step 1: Document every blocked cancellation attempt. Step 2: File with your AG and the FTC. Step 3: FCBA dispute citing the obstructed cancellation. State AGs have made obstructed cancellation a top enforcement priority since the click-to-cancel vacatur, and individual complaints often feed pattern investigations.
No. The Eighth Circuit vacated it on July 8, 2025 in Custom Communications, Inc. v. FTC, No. 24-2691. The rule never took full effect. ROSCA, Section 5 of the FTC Act, and state auto-renewal laws still apply. The FTC opened a new ANPRM on March 11, 2026, but a replacement rule is at least a year out.
Federal law does not require it. Your three real paths: (1) state auto-renewal statutes (California §17602 is strongest), (2) Fair Credit Billing Act dispute within 60 days, (3) the platform refund flow at reportaproblem.apple.com or play.google.com. Many companies also grant goodwill refunds inside the first 7 to 14 days if you ask.
Under the FCBA (15 U.S.C. § 1666), you have 60 days from the statement date. File through your issuer's online dispute portal, document the cancellation attempt, identify the basis (unauthorized, services not delivered, or charge after cancellation). The issuer must acknowledge within 30 days and resolve within two billing cycles, capped at 90 days.
If you enrolled in Prime in the U.S. through a "challenged enrollment flow" or tried to cancel online and couldn't, between June 23, 2019 and June 23, 2025, and used three or fewer Prime benefits in any 12-month period: yes. File at subscriptionmembershipsettlement.com by July 27, 2026. Max refund $51.
Visit reportaproblem.apple.com, sign in, choose "I'd like to" then "Request a refund," select a reason, pick the charge, and submit. Decisions usually come in 24 to 48 hours. Card refunds post within 30 days; Apple Account credit posts within 48 hours. If denied, escalate via Apple Support chat with documentation.
There is no general federal cooling-off rule for online subscriptions. The FTC Cooling-Off Rule (16 CFR Part 429) covers door-to-door and certain telemarketing sales. Some state ARLs include category-specific windows (gym memberships, dating services). EU consumers get a 14-day withdrawal right under the Consumer Rights Directive.
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