A subscription application should show exactly what the customer buys, when each charge occurs, how consent is recorded, and how future charges stop. Cybin can review that file and discuss processing options for the disclosed model. The processor or acquiring bank decides eligibility and account terms.
What changed in the FTC rulemaking?
As reviewed on September 15, 2026, the FTC’s March 2026 notice describes the expanded 2024 Negative Option Rule as vacated and seeks comment on possible amendments. An advance notice of proposed rulemaking is not a final replacement rule. Do not use the vacated rule as proof that one federal cancellation design applies to every subscription business.
That does not remove existing obligations. For online negative-option offers, ROSCA requires clear disclosure of material terms before obtaining billing information, express informed consent before charging, and a simple mechanism to stop recurring charges. Have the applicable state laws, sales-channel rules, payment-method requirements, and provider terms reviewed for your business.
Make the charge understandable before signup
- Show the seller, what is included, the amount or calculation method, and the billing frequency.
- Explain trial length, the first paid charge, renewal terms, and any deadline to avoid the next charge.
- Place relevant terms where the customer makes the purchase decision, with a clear action showing agreement.
- Preserve the version of the offer and consent presented to the customer; do not keep sensitive payment credentials in ordinary support records.
Test cancellation through the actual billing system
Test each signup channel from the customer’s perspective. Verify that cancellation reaches the billing system, stops the charges it is meant to stop, and gives the customer a clear confirmation. Include account-access problems, subscriptions bought through a partner, and cancellation near a billing date. Document who handles exceptions and how to correct an unwanted charge.
Stopping renewal, ending access, refunding an earlier charge, and withdrawing a payment authorization can be different actions. State clearly what the requested action does and record the outcome. Review material changes to pricing or terms before sending notices or continuing charges; an old consent record is not a blanket authorization for every future change.
Prepare a subscription underwriting file
- A walkthrough of signup, the offer shown, consent, confirmation, cancellation, and support.
- The products, services, markets, payment methods, and subscription terms you actually plan to offer.
- Available processing statements and records of refunds, cancellations, disputes, and failed payments.
- Expected monthly volume, average and largest charge, and planned changes to customer acquisition or pricing.
- The proposed gateway, billing platform, statement descriptor, and procedures for handling customer requests.
Compare the written payment terms
Ask Cybin to help review processor fit before you commit to a billing integration. Confirm acceptance of your trial and recurring model, approved payment methods, account limits, recurring-transaction handling, and any changes requiring a new review. Compare fees, reserve conditions, funding, cancellation terms, and support responsibilities using the same projected sales.
If you are considering ACH alongside cards, review authorization, account verification, returns, and refund procedures for that method separately. A customer’s consent to a subscription and permission to debit a particular payment account are related questions that need to be addressed in the actual setup.
Use your own customer and payment records
Track why customers cancel or dispute a charge, how quickly support responds, and whether billing stopped successfully. Use those records to fix unclear offers and failed workflows. Do not assume a particular cancellation design or dispute percentage guarantees continued processing; the provider evaluates the business under its account conditions.