Pre-check every subscription launch before publishing

The failure mode for any automated auto-renewal check is not missing things. It is training the growth team to click past it. A tool that flags every occurrence of the word "subscription" ends up ignored on the free-trial launch that actually carries FTC and state-AG risk. A pre-publish check has to earn its place on every run: deliberate about what it blocks on, what it warns about, and what it refuses to judge. The three duties in the Restore Online Shoppers' Confidence Act, 15 U.S.C. § 8403 — disclose all material terms before obtaining billing information, obtain express informed consent before charging, and provide a simple mechanism to stop recurring charges — are useful here as an ordering of attention, because they already separate wording that trips a duty on its face from wording that a human should just make clearer.

Block on what is categorically wrong in the wording

Some constructions are facts about the paste, not opinions about your product. A recurring-charge offer whose enrollment copy shows no renewal price and/or no billing cadence hits the disclosure duty in § 8403. A pre-checked box, an auto-enroll line, or "by continuing you agree" in place of an affirmative opt-in fails the express-informed-consent duty. A cancellation described only as "call customer service" or "mail a letter" with no self-serve route fails the simple-cancellation duty. "Free trial / cancel anytime / no obligation" sitting next to a card requirement or a quietly-starting charge is a misrepresentation. And a partner add-on billed to a card from an earlier purchase — § 8402 post-transaction third-party charge — needs its own consent. Block on these before publish, because these are the findings that become enforcement under § 8404 or § 8405, and the only honest uncertainty is how a given regulator weighs them — not whether the pattern is present in the text.

Warn on what is fixable by clarifying

The middle tier is where a good tool earns its keep. A renewal line that states the price but buries the cadence, or "renews automatically" with a cancel instruction that could be more reachable, is usually a one-sentence fix. A price shown only on a linked terms page, rather than in the enrollment copy before billing, is a placement problem worth warning on. Surface the exact gap, quote the sentence, and let a human tighten it. This tier is valuable because the fix is cheap and the failure is easy to make in a rush to launch.

Leave alone what cannot be decided from the text

Whether the opt-in control is genuinely un-pre-checked, whether the cancellation path actually works when a customer tries it, whether a renewal reminder was ever sent, and whether the material terms render conspicuously before billing — those live in your form, your checkout flow, your email system, and your page, and an auto-renewal checker that pretends otherwise produces confident noise. The honest move is to say plainly: I read your wording; I cannot see your consent control, your cancel flow, or your pixels. A tool that scores an "FTC-approval probability" is lying about what a text scan can do. The same discipline is why a ruleset borrows a fixed vocabulary of "must / should / may" from sources like RFC 2119 rather than inventing certainty the statute does not grant.

Duty logic beats a banned-word list

The naive approach is a list of forbidden words: block "subscribe," block "automatically," block "free." It fails twice. First, it blocks lawful uses — "Subscribe — $12/month, cancel any time in your Account" is a compliant enrollment a word list may still flag for "subscribe" and "automatically renews." Second, ROSCA is not a word list; it turns on duties and the real flow, and the same phrase is a violation or fine depending on whether the price and cadence are disclosed before billing, whether consent is affirmative, and whether cancellation is simple. Whether a renewal line sits in the enrollment copy is deterministic to check; whether your opt-in is un-pre-checked and your cancel flow works is not, and conflating the two loses trust fast.

The tiers shift with channel and plan type

Wording placed only on a terms or policy page implicates the "disclosed before obtaining billing information" duty in a way that copy shown inline at checkout does not. A post-transaction third-party offer escalates a partner-charge signal under § 8402 that a seller's own recurring charge under § 8403 does not carry. A free-trial plan makes a missing renewal price more material than a one-time purchase would. A pre-check that lets you say the plan type, the channel, and how consent is captured — signup page, checkout, email, ad/social, terms page — and escalates accordingly is more useful than one that treats every paste the same.

Keep the finding, not just the verdict

A useful rule of thumb: the goal is not a perfect score on every subscription draft. The goal is that the risky patterns never leave the drafting window. A finding that names the exact gap — "renewal cadence not disclosed before billing" — can be re-checked on the next revision and logged across a program; a bare pass/fail cannot. Log which offers were scanned, which pre-checked consents were un-checked, which phone-only cancellations gained a self-serve route, and which drafts shipped anyway. Over a quarter that tells you whether the program is safe; a green score on one paste does not.

Where the pre-check stops, and the vacatur caveat

The pre-check reads the wording you paste. It does not read your checkout code, your cancellation flow, your email logs, or how the terms render. And the ordering it uses is the ROSCA statute — not the FTC's 2024 "Click-to-Cancel" amendments to 16 CFR Part 425, which were VACATED by the Eighth Circuit in 2025 and are not asserted as current federal law. Any general "cancel as easily as you signed up" mandate or reminder formality you may remember from that rule now falls mainly to state auto-renewal laws (California, New York, and others), which a US-federal pre-check surfaces only as labeled advisories, never quoted. When the tool is quiet, that is the moment to ask what it cannot see, not the moment to stop looking.

Heuristic pre-check only — not a subscription-compliance certification or legal advice. No consent-control, cancel-flow, reminder-delivery, or enforcement verification is performed by any wording-only checker, including the one that links to this article. Federal basis is ROSCA (15 U.S.C. §§ 8402-8403); the FTC 2024 "Click-to-Cancel" amendments to 16 CFR Part 425 were VACATED by the Eighth Circuit in 2025 and are NOT asserted as current law here; state auto-renewal laws are advisories only, never quoted. For binding guidance on a specific offer, consult ROSCA, 16 CFR Part 425, and a qualified professional.