11 subscription cancellation laws most SaaS founders have never read (#5 requires a second button most products don't have)
Most founders find out about these laws the same way. A lawyer sends a letter.
Cancellation law exists in every major market where you have subscribers. United States, European Union, Australia, United Kingdom, Canada. If you have a paying customer there, their government has jurisdiction over how your cancellation works.
Your company doesn't need to be registered there. One paying customer is enough. What can they actually fine you?
These aren't hypothetical figures. These companies have already paid them. Recent fines and active lawsuits, with the regulator behind each and what went wrong.
Cancel process internally named "The Iliad Flow." Users sent in circles. One of the largest FTC penalties ever. September 2025.
50% Early Termination Fee not disclosed before purchase. Settled March 2026.
Cancellation deliberately obstructed. Fees charged after cancellation attempts. March 2025.
Multiple confusing screens before cancellation. Charges continued after the flow completed. September 2025.
Auto-renewal enrollment deceptive. Cancellation intentionally obstructed. August 2025.
Subscription cancellation violations. June 2025.
Dark patterns and junk fees trapped users trying to cancel. Charged after cancellation. FTC, 2022.
No compliant cancellation button. "Deactivating payment" not recognized as cancellation. January 2026.
Charged without consent. Cancellation unnecessarily difficult. Filed April 2025.
No online cancellation. Required certified mail or in-person form. Filed August 2025.
Cancellation buried behind survey questions and dark patterns. FTC, August 2025.
A "$2" chat answer that signed users into a $50–$90/month subscription. ACCC penalty, 2026.
After Chegg and HelloFresh settled in 2025, private attorneys filed more than 12 new class actions against other subscription companies within weeks.
Regulators move first. Plaintiff attorneys follow with the same playbook. They already know which violations to look for.
These cases are built slowly and quietly. But when one succeeds, the penalty is extreme. The numbers above are what winning looks like for them.
How this actually works
Every market where you have a paying customer can act on its own. They don't coordinate, and they don't wait for each other. You can face the United States, California, the European Union and Germany at the same time, each applying its own law to the same product.
How the fine is worked out depends on the country. The United States and California fine you per customer affected there, so the more customers you have in that market, the bigger the bill. The European Union, United Kingdom, Canada and Australia instead take a percentage of your revenue, in some cases your worldwide revenue.
A country only acts when its own customers are affected. A German court won't take up a complaint from your customers in the United States. But once it does act, the fine it can impose is sized against your whole business, not just your customers there. So if you have customers across several of these markets, every one of them can come after you at the same time.
Who these laws apply to
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A note before you start
We design and build SaaS products for a living, so we see a lot of subscription flows.
Most of them break these laws. Our own clients do, and so do plenty of well-known SaaS startups you would recognise. They build cancellation to reduce churn, not to meet a legal standard they have never heard of.
The penalties are huge, and almost no founder we talk to knows these laws exist. That is why we put this together.
We are designers, not lawyers. We gathered all of this for our own work, so we can design and advise our clients correctly. But laws change, and interpretations vary.
This document is for informational purposes only and does not constitute legal advice. We have verified every requirement below against primary sources, but laws change and interpretations vary by jurisdiction. Before acting on anything in this document, validate it with a qualified lawyer in each relevant jurisdiction. Spot Design does not accept liability for fines, penalties, or legal consequences arising from reliance on this document.
United States
Federal FTC rules apply to every US subscriber, in every state
Before any state law, there is a federal floor.
The FTC governs how online subscriptions are sold and cancelled across the whole country. It sits on top of whatever California, New York, or Colorado require.
It applies to B2C, and it reaches B2B as well. ROSCA is one of the few US rules that also covers business subscribers.
At signup
- The recurring price, how often it is charged, and how to cancel must be shown plainly before the customer pays, not buried in a linked terms page. They must appear on the payment screen itself, before any card details are entered, and not below the fold.
- Consent to the auto-renewal must be a separate, affirmative action the customer actively takes, such as ticking a box that starts unchecked. A pre-checked box, or consent folded into the general terms, does not count.
- Every claim in the signup flow must be accurate. A free trial must state the date it converts to a paid charge and the amount. The way the plan, the trial, and the renewal are described cannot contradict or hide the terms the customer is actually agreeing to.
At cancellation
- Cancellation must take no more effort than signing up did, and must be offered through the same medium the customer used to sign up (web, app, or wherever they subscribed).
- A subscription started online must be cancellable online, with no added steps that obstruct or delay it. Required phone calls, mailed forms, mandatory retention agents, and retention mazes (successive screens of surveys, warnings, and offers before the cancel button) are not permitted.
- A retention or discount offer may be shown, but the cancel option must stay right beside it, and only one offer is allowed. Stacking offers, or adding screens that delay cancelling, is itself a violation.
Fines
Charged per customer affected, so a large subscriber base compounds into the biggest cancellation penalties on record:
Fined or in court Amazon Restore Online Shoppers' Confidence Act (ROSCA), 15 U.S.C. §8401, and FTC Act §5. The FTC's amended "Click-to-Cancel" Negative Option Rule was vacated by the Eighth Circuit in July 2025; enforcement continues under ROSCA.
California
The fine is $2,500 per subscriber, not per company
When you read "$2,500", maybe you think that's manageable. But then we do the math.
2,000 subscribers in California. A non-compliant cancellation process. That's $5 million in potential fines.
At signup
- The recurring price, how often it is charged, how to cancel, and what the customer will pay when any trial ends must be shown plainly before the customer pays, not buried in a linked terms page. They must also visually stand out.
- Consent to the auto-renewal must be a separate, affirmative action the customer actively takes, such as ticking a box that starts unchecked. A pre-checked box, or consent folded into the general terms, does not count.
- Right after signup, a confirmation the customer can keep (an email or receipt) must be sent, covering the terms, the cancellation policy, and how to cancel.
- For a free trial, that confirmation must include a working way to cancel (a link and the steps) before the trial turns into a paid charge.
During the subscription
- For a free trial, gift, or promotional price lasting more than 31 days, a reminder must go out 3 to 21 days before it ends, stating the price that starts next and how to cancel.
- For an initial term of a year or longer, a renewal notice must go out 15 to 45 days before it renews.
- For any annual plan, a yearly reminder must be sent through the same channel used at signup (email, app, wherever they subscribed), covering the product, the charges, and how to cancel.
- For a price or fee change, notice must be given 7 to 30 days in advance, with how to cancel. The customer must be warned, but does not need to agree again for the subscription to continue.
At cancellation
- Cancellation must take no more effort than signing up did, and must be offered through the same medium the customer used to sign up (web, app, or wherever they subscribed).
- A subscription started online must be cancellable online, with no added steps that obstruct or delay it. A prominent "click to cancel" link or button, or a termination email the business provides, satisfies this.
- A retention or discount offer may be shown, but a prominent, continuous "click to cancel" option must stay right beside it.
Records
- Keep proof of each subscriber's consent for at least 3 years, or one year after they cancel, whichever is longer.
Fines
Each subscriber is a separate violation under California's Unfair Competition Law. Same type of violation, same result:
Fined or in courtCal. Bus. & Prof. Code §§17600–17606, amended by AB 2863, effective July 1, 2025.
New York
Cancellation must be at least as easy as signing up was
Here's how New York measures whether your cancellation is compliant.
They look at your signup. Then they look at your cancellation. If cancellation requires more effort than signup, you fail.
That's the test. A comparison.
At signup
- The recurring price, how often it is charged, how to cancel, and the deadline to act before charges start must be shown plainly before the customer pays, not buried in a linked terms page.
- If the price will change later, the signup must state when it changes and the exact amount that will be charged after the change.
- Consent to the auto-renewal must be a separate, affirmative action the customer actively takes, such as ticking a box that starts unchecked. A pre-checked box, or consent folded into the general terms, does not count.
- Right after signup, a confirmation the customer can keep (an email or receipt) must be sent, covering the terms, the cancellation policy, and how to cancel.
During the subscription
- For a plan whose first term is a year or longer and that renews for six months or longer, an email or message must go out 15 to 45 days before the cancellation deadline, stating the renewal charge that is coming and how to cancel.
- For a free trial or gift lasting more than one month, a reminder must go out 3 to 21 days before the deadline to cancel before the first charge, stating the charge that will start and how to cancel.
- For any change to the terms, including a price change, the customer must be told 5 business days to 30 days before it takes effect, through the same medium the customer used to sign up (web, app, or wherever they subscribed), stating what is changing and how to cancel.
- For a price increase the customer was never told about in advance, either the customer must actively agree to the new price, or they must be allowed to cancel within 14 days of the charge and get the rest of the term refunded.
At cancellation
- Cancellation must take no more effort than signing up did, and must be offered through the same medium the customer used to sign up (web, app, or wherever they subscribed).
- A subscription started online must be cancellable online, with no added steps that obstruct or delay it. A termination email the business provides can satisfy this.
- For an in-person sign-up, cancellation must also be offered online or by phone where practical.
- A retention or discount offer may be shown, but it cannot carry unreasonable conditions that make cancelling harder.
Fines
The base penalty is $100 per violation, or $500 when a single act causes several. Both double, to $500 and $1,000, when the company breaks the rule knowingly. The Attorney General adds these up across every affected subscriber and can order refunds on top, which is how per-violation penalties reach the total below:
Fined or in courtN.Y. Gen. Bus. Law §527-a (automatic renewal), amended effective November 5, 2025.
Colorado
The only US state that extended these laws to B2B companies in 2026
Every other US state on this list applies to consumers only.
Colorado is different.
It applies to individual consumers from August 6, 2025, and to business subscribers from February 16, 2026, wherever the company is based. If you sell SaaS to companies in Colorado, that second date already puts you in scope.
At signup
- The recurring price, how often it is charged, how to cancel, and that the plan renews on its own (and the length of each renewal) must be shown plainly before the customer pays, not buried in a linked terms page.
- Consent to the auto-renewal terms must be given before any charge.
- For a trial, the price that starts when the trial ends, and anything else the customer will owe, must be stated plainly, and the customer must be able to cancel before the first payment is due.
- Right after signup, a confirmation the customer can keep (an email or receipt) must be sent, covering the terms, the cancellation policy, and how to cancel.
During the subscription
- Before the first automatic renewal, and before every renewal after it, a reminder must go out 25 to 40 days ahead, stating the charge that is about to renew and how to cancel.
- For a plan with a term under 12 months, that same 25-to-40-day reminder must also go out before any renewal that would carry the subscription past 12 months in total, stating the charge and how to cancel.
- For any change to the terms, the customer must be told what is changing and how to cancel, in a form they can keep (such as an email), before the change takes effect.
At cancellation
- The way to cancel must be simple, quick, easy to find, and free of extra cost.
- If the customer signed up online, a one-step online cancellation link must be provided, on the website or in an email, available right away or after a reasonable login step.
- If the customer signed up in person or offline, cancellation may instead be required in person, or the online link may be offered.
- A cancellation cannot be unreasonably obstructed or delayed.
Fines
Breaking these rules counts as a deceptive trade practice under the Colorado Consumer Protection Act. The Attorney General and district attorneys can seek up to $20,000 per violation (up to $50,000 when the customer is elderly), and customers can also sue on their own.
Colo. Rev. Stat. §6-1-732 (automatic renewal), amended by SB25-145, effective August 6, 2025, extending to B2B February 16, 2026.
European Union
A mandatory withdrawal button is now required in every account area
This law came into force on June 19, 2026.
Most SaaS products built before that date don't have what it requires.
What makes this different: the law doesn't ask for a cancel button. It requires a withdrawal button, a separate element with its own label, for the 14-day withdrawal window. That is not the same as ending a subscription.
It applies to B2C contracts concluded online (not by phone, email or post), and non-EU companies directing activities at EU customers are in scope.
At signup
- The main features, the total price, how long the contract runs, and how to end it must be shown plainly before the customer is bound.
- The customer must be told about the right to withdraw (its conditions, time limit, and how to use it), and be given the standard withdrawal form.
- The button that places the order must make clear that clicking it means paying, labelled "order with obligation to pay" or equally clear wording. If the label is vague, the customer is not bound by the contract.
- The customer must be told that the withdrawal button exists and where to find it.
Withdrawal
- The customer gets 14 days to withdraw from an online contract, for any reason and at no cost. The 14 days count from when the contract is made (for services), or from delivery (for goods).
- The online interface must carry a withdrawal button labelled "withdraw from contract here" (or clear equivalent), shown prominently and available throughout the whole 14-day window.
- It works in two steps: the customer starts the withdrawal, then confirms it on a "confirm withdrawal" step. No extra forms, surveys, or required calls, and withdrawing cannot be harder than signing up was.
- An automatic confirmation of receipt must be sent in a form the customer can keep (such as email), with the date and time.
- The button is only required where a withdrawal right exists. It does not cover the directive's exceptions, such as digital content or services the customer chose to start at once after clearly giving up the right.
- If the customer is not told about the withdrawal right, the 14-day window stretches to 12 months and 14 days.
Fines
Each EU country sets its own penalties. For widespread cross-border breaches, EU-coordinated enforcement can reach up to 4% of the company's annual turnover.
Directive (EU) 2023/2673, inserting Article 11a (withdrawal function) into the Consumer Rights Directive 2011/83/EU; applies from June 19, 2026.
Germany
Two separate laws that both apply at the same time. Most products fail both.
Most SaaS products built outside Germany fail this section.
Not because the laws are complicated. Because most founders have never heard either one exists.
One has been law since 2022: the cancellation button and the lock-in limits. The other, the withdrawal button, applies from June 19, 2026.
At signup
- The main features, the total price, how long the contract runs and any minimum term, and how to end it must be shown plainly before the order.
- The customer must be told about the right to withdraw (its conditions, time limit, and how to use it), and be given the standard withdrawal form.
- The button that places the order must make clear that clicking it means paying, labelled "order with obligation to pay" or equally clear wording. If the label is wrong, the contract is not validly concluded.
Withdrawal
- A withdrawal button must be provided, for goods, services, digital content, and financial services alike.
- It must be labelled "withdraw from contract" or a clear equivalent, placed prominently, reachable from every sub-page, visually distinct from ordinary links, and available throughout the whole 14-day withdrawal period.
- It works in two steps: the customer gives only their name, which contract it is, and an email address, then submits with a "confirm withdrawal" button. No extra fields, and no forced login unless the contract itself needs an account.
- A confirmation of receipt must be sent promptly in a form the customer can keep (such as email), stating the withdrawal's content and the date and time it was received.
- The button is required where a legal withdrawal right exists. If the customer is not properly told about that right, the 14-day window can stretch to 12 months and 14 days.
During the subscription
- The first lock-in period (the fixed time the customer is committed at the start) can be at most two years.
- When that period ends, any auto-renewal must roll into an open-ended plan the customer can cancel at any time, not another fixed lock-in.
- The notice the customer has to give to cancel can be at most one month.
- If the contract breaks any of these rules, that part of it has no legal force: the customer can cancel and leave right away, whatever the contract says.
At cancellation
- A clearly labelled cancellation button ("cancel contracts here" or equally clear) must be directly and easily accessible, with no login or password required to reach it.
- It cannot be hidden, greyed out, or buried, and must be as visible as the rest of the page.
- Clicking it leads straight to a confirmation page with a second button, "cancel now". That page may only collect what identifies the contract (name, contract reference, email), never a "why are you leaving" survey.
- Receipt of the cancellation must be confirmed promptly in a form the customer can keep (such as email), stating its content, the date and time of receipt, and when the contract ends.
- German courts have already struck down: requiring login before confirming, hiding the button behind a "show more" control, grey text on a white background, and forcing the customer to answer questions before reaching the final "cancel now" step.
Fines
The two laws carry different penalties. Breaking the cancellation-button rules (§312k) brings no direct government fine, but competitors and consumer groups can win a court injunction, and each violation can cost up to €250,000. Missing the withdrawal button (§356a) draws government fines up to €50,000, rising to 4% of annual turnover (or €2 million) for widespread cross-border breaches.
§309 No. 9 and §312k BGB (Fair Consumer Contracts Act, 2022) and §356a BGB (withdrawal button), in force June 19, 2026.
United Kingdom
Up to 10% of global annual turnover. Not just UK revenue. Everything.
Spring 2027 is the enforcement date. That sounds like there's time.
There isn't.
If you have UK subscribers and your process isn't compliant by Spring 2027, the fine is calculated on everything your company earns globally. Not just what you earn in the UK. Every pound, dollar, and euro, anywhere in the world.
At signup
- Before the customer commits, the essentials must be shown prominently: the price and how often it is charged, that the plan renews on its own and keeps charging until cancelled, the price after any trial or intro offer, and how to cancel.
- That up-front summary must also say when renewal reminders will be sent.
- The complete terms must also be given in a form the customer can keep (such as email).
Withdrawal
- The customer gets two 14-day cooling-off periods: an initial one right after they enter the contract, and a renewal one after a free or discounted trial ends, or after a 12-month-or-longer contract auto-renews.
- During a cooling-off period the customer can cancel and get a refund, minus a fair amount for whatever they used in that time.
- The first cooling-off period can be waived so the customer gets digital content right away, but only if they actively agree and confirm they are giving up that cancellation right.
During the subscription
- Before each renewal, a reminder must go out at the timing the business promised up front (there is no fixed legal window), stating that the plan is about to renew, the price, and how to cancel. Annual plans get an extra reminder.
- A reminder may also carry other service or marketing content, but the renewal details must stand out more than anything else in it.
At cancellation
- Cancelling must be straightforward, with no steps beyond what is reasonably necessary.
- A subscription started online must be cancellable online.
- Terms that make leaving unreasonably hard (like narrow cancellation windows) are not allowed.
Fines
The fine is calculated on everything the company earns worldwide, not just its UK revenue (or up to £300,000 if that is greater). The CMA can impose it directly, without going to court.
Digital Markets, Competition and Consumers Act 2024 (DMCCA), Part 4, Chapter 2 (subscription contracts); regime expected in force Spring 2027.
Canada
Three provinces, three different laws, no federal standard
There is no single national law in Canada.
There are three provincial laws, each with different requirements, each tightening. If you have subscribers in Ontario, British Columbia, and Quebec, you have three separate compliance obligations.
At signup
- In Ontario, a subscription cannot auto-renew unless the customer actively agreed to it. Ontario is moving to go further: the company will have to get the customer's agreement again at each renewal or change, not rely on the one-time yes from signup.
During the subscription
- In British Columbia, for renewal terms of 60 days or more, the customer must be sent a notice 30 to 60 days before each renewal, stating the renewal date, the amount, and how to cancel.
- In Quebec, when a free or reduced-price period is ending, a clear written notice must be sent 2 to 10 days before it ends, stating the end date and the price that will then apply.
At cancellation
- In British Columbia, for renewal terms under 60 days, the customer can cancel at no charge or penalty. For terms of 60 days or more, they can cancel penalty-free before it renews, or cancel after and get a set portion refunded.
- In Quebec, online subscriptions must offer an easy-to-find, one-click cancel button to end the contract.
- In Ontario, unnecessary barriers to cancelling are not allowed.
Fines
Penalties vary by province. Quebec's Bill 10 carries a criminal penalty of up to 5% of worldwide turnover, plus separate administrative fines. British Columbia and Ontario set their own under their consumer protection acts.
Ontario Consumer Protection Act, 2023 (regulations pending); B.C. Business Practices and Consumer Protection Act (2025 amendments); Quebec Bill 10 (2025).
Australia
No dedicated law, but the fine can reach A$100 million
There's no dedicated subscription law in Australia yet.
For now, the job is done by the law on unfair contract terms, which carries penalties up to A$100 million, and the regulator has made subscription traps a top target.
A dedicated law is coming: the Unfair Trading Practices reform, with subscription-specific rules, is proposed to start on July 1, 2027.
It applies to both B2C and B2B: the unfair-terms law covers individual customers and small businesses alike, and foreign companies are in scope.
At signup
- An auto-renewal term can be ruled unfair if it is heavily one-sided against the customer and goes beyond what the business genuinely needs to protect itself.
- Since November 9, 2023, including or relying on an unfair term is illegal and carries penalties, and the term itself has no legal force.
- Renewal terms must be shown clearly and must not be misleading.
- From July 1, 2027, the Unfair Trading Practices reform will require the important subscription details (such as the price, how often it is charged, and how to cancel) to be shown before signup, with any required fees shown prominently and up front.
During the subscription
- A clause that lets the business change the price or terms mid-subscription on its own can itself be an unfair term if it is one-sided.
- From July 1, 2027, the Unfair Trading Practices reform will require the customer to be told, before a free trial ends, that it is about to turn into a paid plan.
At cancellation
- Cancelling must be genuinely easy. A process that is deliberately complex, hard to find, or built to discourage cancelling can count as misleading or grossly unfair conduct.
- From July 1, 2027, the Unfair Trading Practices reform will require unreasonable barriers to cancelling to be removed.
Fines
For each breach, the penalty is the greatest of: A$100 million, three times the benefit gained, or 30% of the company's turnover during the breach period. Each unfair term counts as a separate breach. The same penalties will back the incoming Unfair Trading Practices rules.
Australian Consumer Law, unfair contract terms regime (penalties from November 9, 2023); Unfair Trading Practices reform proposed to commence July 1, 2027.
Japan
The law specifies what must be on the checkout screen before anyone pays
Japan doesn't regulate cancellation the same way the US or EU do.
What it regulates is the moment someone agrees to pay.
Get the screen wrong, and the customer gets a legal right to unwind the contract after the fact, not just file a complaint or a chargeback.
At signup
- The final confirmation screen (the last screen before the order is placed) must clearly show the quantity, the price, when and how payment is taken, when the product or service is delivered, how long a subscription runs, and how to cancel or withdraw the order.
- All of it must be on the confirmation screen itself, not behind a terms link and not one click away.
- Misleading subscription-trap designs are not allowed: labelling the order button "Send" instead of "Order," hiding the recurring terms behind images, burying details at the bottom, or leaving no way to fix a mistake in the order.
- If the screen leaves out required information or misleads, the customer can cancel the order and undo the contract.
Fines
Getting the final confirmation screen wrong (leaving out required information or misleading) is a crime. An individual faces up to 3 years in prison or a ¥3 million fine; the company faces up to ¥100 million. The Consumer Affairs Agency can also order the business to fix its practices or suspend operations, and consumer groups can seek injunctions.
Act on Specified Commercial Transactions, final confirmation screen rules (Art. 12-6), penalties under Art. 70; in force since June 1, 2022.
South Korea
Six specific dark patterns now explicitly prohibited since February 2025
Most countries prohibit cancellation dark patterns in general terms. South Korea lists them.
Since February 14, 2025, six specific patterns are explicitly prohibited by name. If your product uses any of them, it isn't a judgment call.
It's a violation.
It applies to B2C, and the Korea Fair Trade Commission has said it will enforce against foreign online platforms selling to Korean customers.
At signup
- Who the seller is, the product or service details, the total price and payment terms, and how and when the customer can withdraw must all be shown plainly before purchase.
- For a subscription, the recurring charge, how often it is charged, and the renewal terms must also be shown plainly.
Withdrawal
- The customer can withdraw within 7 days for any reason and get a refund.
- This right cannot be waived. Any term that removes or limits it to the customer's disadvantage has no legal force.
- A few standard exceptions apply (for example, digital content the customer already started after being told and agreeing, or goods that have been used or damaged).
During the subscription
- Before a subscription's price goes up, or a free trial turns into a paid plan, the customer must be clearly told and must actively agree to it. Silence does not count.
Prohibited dark patterns
- Hidden renewals: letting a price rise or a free trial turn into a paid plan without the customer clearly noticing.
- Drip pricing: showing the cost piece by piece instead of the full total up front (the grace period for this ended August 13, 2025).
- Pre-selected options: pre-ticking paid add-ons the customer didn't choose.
- Misleading layout: using colour, size, or position to steer the customer toward one choice.
- Making cancellation or withdrawal difficult.
- Repeated interference: nagging pop-ups that pressure the customer to change their mind.
Fines
The Korea Fair Trade Commission can order the business to fix the practice and can fine it up to about KRW 5 million for breaking the consent-and-notification rules. For serious cases it can add penalty surcharges based on a share of revenue, and even suspend the business. Enforcement stepped up sharply through 2025.
Act on Consumer Protection in Electronic Commerce, dark-pattern rules in force February 14, 2025 (drip-pricing grace period to August 13, 2025).
Brazil
Every online customer has a 7-day right to a full refund. Including yours.
In Brazil, this right applies to everything purchased online.
Digital products. SaaS subscriptions. Annual plans. There are no exceptions.
If the customer cancels within 7 days of signing up, they're entitled to a full refund including any transaction fees. No questions asked. No minimum purchase required.
At signup
- The site must clearly show who the business is: company name, CNPJ registration number, and a postal and email address.
- The product or service details, the total price including any extra costs, and the contract terms must all be shown before the customer buys.
- A clear summary of the contract must be given before purchase, along with an easy way to reach customer service.
Withdrawal
- A customer who buys online has 7 days to change their mind (counted from signing up or from receiving the product or service) with no need to give a reason.
- Every amount paid must be refunded in full, right away, and adjusted for inflation, at no cost to the customer.
- The customer must be able to use this right through the same medium they used to sign up (web, app, or wherever they subscribed), and the payment provider must be told at once to reverse or refund the charge.
At cancellation
- Cancellation must be available and genuinely easy. Creating barriers to cancellation is an abusive practice under the Consumer Code.
- Abusive clauses that trap the customer (like ones that make leaving unreasonably hard) have no legal force.
Fines
Administrative fines under the Consumer Code reach about R$13 million per violation, issued by SENACON and state and municipal agencies. On top of that, any wrongful charge must be paid back to the customer at double the amount, plus interest and an inflation adjustment. Class actions under the Code are common, and often target foreign companies with Brazilian customers.
Consumer Defense Code (CDC, Law No. 8.078/1990), right of regret (Art. 49); Decree No. 7.962/2013 on e-commerce (Arts. 4–5).
Go through the requirements above for each country where you have subscribers and check your cancellation process against them.
If you want us to do that with you and tell you exactly what needs to change, book a call.