Subscription and Auto-Renewal Enforcement Tracker: FTC ROSCA Cases and Settlements

Complaints nearly tripled, from at least 33 a day in late 2020 to more than 90 a day in 2025. The FTC pointed to that climb when it restarted rulemaking in 2026.

Instacart's $60 million leads the non-Amazon cases, and the rest range from $35 million down to $5 million.

The $1 billion penalty goes to the government; the $1.5 billion in redress is what customers can get back. More than $845 million had reached consumers as of September 2026, and the FTC has raised the per-person cap from $51 to $200.

FTC subscription and auto-renewal enforcement actions, June 2024 to June 2026

Source: Federal Trade Commission, FTC Takes Action Against Adobe and Executives for Hiding Fees, Preventing Consumers from Easily Cancelling Software Subscriptions; Federal Trade Commission, FTC Takes Action Against Care.com for Deceiving Caregivers About Wages and Availability of Jobs on its Site, Impeding Cancellation Process; Federal Trade Commission, Cash Advance Company Cleo AI Agrees to Pay $17 Million As Result of FTC Lawsuit Charging It Deceives Consumers; Federal Trade Commission, FTC Returns More than $15.8 Million to Consumers Misled by Cash Advance App Company Cleo AI; Federal Trade Commission, FTC Takes Action Against Uber for Deceptive Billing and Cancellation Practices; Federal Trade Commission, FTC and States File Amended Complaint Against Uber for Deceptive Billing and Cancellation Practices; Federal Trade Commission, Paddle Will Pay $5 Million to Settle FTC Allegations of Unfair Payment-Processing Practices and Facilitation of Deceptive Tech-Support Schemes; Federal Trade Commission, Match Group Agrees to Pay $14 Million, Permanently Stop Deceptive Advertising, Cancellation, and Billing Practices; Federal Trade Commission, FTC Sues LA Fitness for Making it Difficult for Consumers to Cancel Gym Memberships; Federal Trade Commission, Ed Tech Provider Chegg to Pay $7.5 Million to Settle FTC Allegations Concerning Unlawful Cancellation Practices; Federal Trade Commission, FTC Secures Historic $2.5 Billion Settlement Against Amazon; Federal Trade Commission, Instacart to Pay $60 Million in Consumer Refunds to Settle FTC Lawsuit Over Allegations it Engaged in Deceptive Tactics; Federal Trade Commission, FTC Sues JustAnswer for Deceiving Consumers into Enrolling in a Costly Recurring Monthly Subscription; Federal Trade Commission, Shutterstock to Pay $35 Million to Settle FTC Allegations Over Illegal Subscription and Cancellation Practices; Federal Trade Commission, FTC Sues to Stop Sprawling Enterprise Operating Unlawful Subscription Schemes. Download as image

FTC click-to-cancel (Negative Option) rule timeline

Source: Federal Trade Commission, Federal Trade Commission Announces Final "Click-to-Cancel" Rule Making It Easier for Consumers to End Recurring Subscriptions and Memberships; Federal Trade Commission (Federal Register), Negative Option Rule (final rule), 89 FR 90476, FR Doc. 2024-25534; U.S. Court of Appeals for the Eighth Circuit, Custom Communications, Inc. v. FTC, No. 24-3137 (8th Cir.); Federal Trade Commission (Federal Register), Revision of the Negative Option Rule, Withdrawal of the CARS Rule, Removal of the Non-Compete Rule To Conform These Rules to Federal Court Decisions, FR Doc. 2026-02866; Federal Trade Commission, FTC Seeks Public Comment in Response to Advance Notice of Proposed Rulemaking Regarding Negative Option Marketing Practices; Federal Trade Commission (Federal Register), Rule Concerning the Use of Prenotification Negative Option Plans (advance notice of proposed rulemaking), FR Doc. 2026-04952. Download as image

Is the FTC click-to-cancel rule still in effect?

No. The FTC approved its final click-to-cancel rule on October 16, 2024, by a 3-2 vote. It took effect January 14, 2025, but companies had until a later compliance date, which the agency pushed back to July 14, 2025. Before that date arrived, the Eighth Circuit vacated the rule on July 8, 2025.

The court didn't say subscription traps are fine. It said the FTC skipped a preliminary regulatory analysis that section 22 of the FTC Act requires for a rule this size. On February 12, 2026, the FTC put the pre-2024 rule text back in place, and on March 11, 2026, it opened a fresh advance notice of proposed rulemaking. Comments closed April 13, 2026. So a new rule may come, but not soon. An advance notice is only the first step.

How is the FTC still suing companies without the rule?

Because the rule was never the main weapon. ROSCA, passed by Congress, already makes it illegal to charge people for an online subscription unless the company clearly discloses the terms before billing, gets express consent, and offers a simple way to stop the recurring charges. The FTC Act's ban on deceptive practices sits on top of that.

Those laws didn't go anywhere when the rule was vacated. The FTC counted 5 negative option cases filed and 6 settlements approved from January 2025 to March 2026, and the tracker table shows more after that, including Shutterstock in May 2026 and a June 2026 complaint against a subscription enterprise made up of 15 corporations and 8 individuals.

Not every FTC press release named ROSCA. The ones for Care.com, Cleo AI, Match Group, Instacart and Shutterstock talked about deception and billing practices more broadly. The outcome for the company was the same: pay, and change the flow.

What do these subscription cases have in common?

Read the complaints side by side and the same few moves keep showing up.

• A cancellation maze. The FTC alleges Uber One members could face up to 23 screens and 32 actions to cancel. That is an allegation, not a finding, but it shows what regulators count as a red flag.
• A fee that appears only when you try to leave. Adobe was referred to the Justice Department over an early termination fee the FTC says was hidden. Shutterstock's annual plans paid monthly also carried an early cancellation fee.
• Renewals nobody explained. Shutterstock allegedly didn't make clear that on-demand image packs renewed automatically.
• A cheap front door. JustAnswer allegedly charged a $1 or $5 join fee, then rolled people into a subscription of $28 to $125 a month.
• Design that pushes you one way. An international review of 642 subscription sites and apps found nearly 76% used at least one possible dark pattern, and nearly 67% used several.

What this means if you sell subscriptions

If your business bills customers on a recurring basis, the vacated rule is not a safe harbor. The Paddle case is a useful warning: Paddle is a payment processor that acted as merchant of record for other companies' software, and it still paid $5 million, partly over auto-renewing subscriptions it charged for without clear disclosure. The FTC looks at everyone in the billing chain.

Put yourself in the customer's seat and try to cancel. Count the screens. If there's a retention offer, make sure it can be skipped in one click. Check that the price, the renewal date and any early termination fee show up before the card is charged, not buried in terms people scroll past. And if a reviewer at the FTC read your checkout, would they find anything that looks like the patterns above?

Your vendor contracts matter here too. If you sell through a reseller, a billing platform or an app store, find out who owns the disclosure and the cancel button. Write it down. When the FTC came after Adobe, it named two executives along with the company, so this is a leadership problem as much as a legal one.

How big are FTC subscription settlements?

Outside of Amazon, the money is smaller than the headlines suggest. Instacart agreed to $60 million in refunds, Shutterstock $35 million, Cleo AI $17 million, Match Group $14 million, Care.com $8.5 million, Chegg $7.5 million and Paddle $5 million. Several cases, including LA Fitness and JustAnswer, had no money announced at all when they were filed.

Don't read the smaller numbers as a sign the cases are mild. These settlements come with orders that limit how the company can do business going forward, and those orders are what change behavior. A company that slips back into old habits risks violating that order, which is a much harder spot to be in.

Amazon is the outlier for a reason. Prime has an enormous member base, and the $1 billion civil penalty alone is the largest the FTC has ever obtained in a case involving one of its rules. Most businesses will never see a number like that, but the conduct the FTC described there (a hard-to-find exit and sign-up screens that steered people into paying) is the same conduct it chases in much smaller companies.

What should you do if you're the one paying?

For consumers, the cases are good news. The FTC said Amazon's settlement covers an estimated 35 million people, and the Cleo AI case shows money really does go out: the FTC announced it is sending more than $15.8 million to 2,124,796 customers, with PayPal payments starting October 27, 2026.

If you run a business that buys software, read this with some care. These cases are mostly about consumers. When your company signs an annual SaaS order form, your protection usually comes from the contract itself and whatever your state's auto-renewal law covers. That makes the renewal clause worth reading before you sign, not the week it renews.

Set a calendar reminder well ahead of any cancellation deadline in your contract. Ask the vendor to confirm in writing how notice must be given. If a renewal surprised you, look at whether the notice terms were disclosed clearly; that's often where a refund conversation starts.

Sources and method

Every number on this page comes from the sources below, each opened and read on or before October 18, 2026. A second, independent review checked every figure against its source and corrected anything that did not match. Figures that could not be confirmed were left out.

1. Federal Trade Commission, Federal Trade Commission Announces Final "Click-to-Cancel" Rule Making It Easier for Consumers to End Recurring Subscriptions and Memberships (October 16, 2024)
2. Federal Trade Commission (Federal Register), Negative Option Rule (final rule), 89 FR 90476, FR Doc. 2024-25534 (November 15, 2024)
3. U.S. Court of Appeals for the Eighth Circuit, Custom Communications, Inc. v. FTC, No. 24-3137 (8th Cir.) (Filed July 8, 2025)
4. Federal Trade Commission (Federal Register), Revision of the Negative Option Rule, Withdrawal of the CARS Rule, Removal of the Non-Compete Rule To Conform These Rules to Federal Court Decisions, FR Doc. 2026-02866 (February 12, 2026)
5. Federal Trade Commission (Federal Register), Rule Concerning the Use of Prenotification Negative Option Plans (advance notice of proposed rulemaking), FR Doc. 2026-04952 (March 13, 2026)
6. Federal Trade Commission, FTC Seeks Public Comment in Response to Advance Notice of Proposed Rulemaking Regarding Negative Option Marketing Practices (March 11, 2026)
7. Federal Trade Commission, FTC Secures Historic $2.5 Billion Settlement Against Amazon (September 25, 2025)
8. Federal Trade Commission, FTC Announces Additional Payments to Consumers Stemming from FTC's Amazon Prime Settlement (September 17, 2026)
9. Federal Trade Commission, Shutterstock to Pay $35 Million to Settle FTC Allegations Over Illegal Subscription and Cancellation Practices (May 13, 2026)
10. Federal Trade Commission, Instacart to Pay $60 Million in Consumer Refunds to Settle FTC Lawsuit Over Allegations it Engaged in Deceptive Tactics (December 18, 2025)
11. Federal Trade Commission, Ed Tech Provider Chegg to Pay $7.5 Million to Settle FTC Allegations Concerning Unlawful Cancellation Practices (September 15, 2025)
12. Federal Trade Commission, Match Group Agrees to Pay $14 Million, Permanently Stop Deceptive Advertising, Cancellation, and Billing Practices (August 12, 2025)
13. Federal Trade Commission, Cash Advance Company Cleo AI Agrees to Pay $17 Million As Result of FTC Lawsuit Charging It Deceives Consumers (March 27, 2025)
14. Federal Trade Commission, FTC Returns More than $15.8 Million to Consumers Misled by Cash Advance App Company Cleo AI (October 8, 2026)
15. Federal Trade Commission, FTC Takes Action Against Care.com for Deceiving Caregivers About Wages and Availability of Jobs on its Site, Impeding Cancellation Process (August 26, 2024)
16. Federal Trade Commission, Paddle Will Pay $5 Million to Settle FTC Allegations of Unfair Payment-Processing Practices and Facilitation of Deceptive Tech-Support Schemes (June 16, 2025)
17. Federal Trade Commission, FTC Takes Action Against Uber for Deceptive Billing and Cancellation Practices (April 21, 2025)
18. Federal Trade Commission, FTC and States File Amended Complaint Against Uber for Deceptive Billing and Cancellation Practices (December 15, 2025)
19. Federal Trade Commission, FTC Takes Action Against Adobe and Executives for Hiding Fees, Preventing Consumers from Easily Cancelling Software Subscriptions (June 17, 2024)
20. Federal Trade Commission, FTC Sues JustAnswer for Deceiving Consumers into Enrolling in a Costly Recurring Monthly Subscription (January 13, 2026)
21. Federal Trade Commission, FTC Sues LA Fitness for Making it Difficult for Consumers to Cancel Gym Memberships (August 20, 2025)
22. Federal Trade Commission, FTC Sues to Stop Sprawling Enterprise Operating Unlawful Subscription Schemes (June 17, 2026)
23. Federal Trade Commission, FTC, ICPEN, GPEN Announce Results of Review of Use of Dark Patterns Affecting Subscription Services, Privacy (July 10, 2024)