What the federal law focuses on
The Restore Online Shoppers' Confidence Act applies to online sales that use a negative option, where a customer's silence or failure to cancel is treated as agreement to continued charges. At its core, the law is about informed consent at sign-up and a simple way out afterward. The Federal Trade Commission enforces it and has brought large cases against well-known companies over subscriptions that were hard to cancel. A broader FTC rule on cancellation was struck down by a federal appeals court, but the underlying statute remains in force, and the status of any replacement rule should be checked.
State laws add their own requirements
Many states have automatic renewal laws, and New York has one of its own, so a business selling to customers in several states may need to meet the strictest version that applies. These laws can address renewal reminders, cancellation methods, and how free trials convert to paid plans. State attorneys general also bring cases under consumer protection statutes, and private class actions are common in some states. Requirements have changed often in recent years, so a policy written a few years ago may be out of date.
Reviewing a subscription flow
We walk through the sign-up and cancellation process the way a customer would, on desktop and on mobile. We review the disclosures near the point of purchase, the consent mechanism, confirmation emails, and the cancellation path, including whether customers are pushed through repeated offers before they can leave. Records of consent and cancellation requests should be kept, because they become central if a regulator or a plaintiff asks questions. For businesses that have already received an inquiry, we review what was offered and when, and help prepare a response. ROSCA compliance is easier to build into a product than to retrofit under pressure.
