Offer wording vs published ROSCA duties for subscription brands and growth teams
Methodology: ROSCA § 8403 duties · consent & cancellation logic · human review
Paste your enrollment, checkout, or cancellation wording before it ships. Get a scored pre-check report — are the material renewal terms disclosed before billing, is consent an express opt-in rather than a pre-checked box or silence, is cancellation a simple self-serve path or a phone-only maze, does “free trial / cancel anytime” actually match the charge — based on the Restore Online Shoppers’ Confidence Act (ROSCA, 15 U.S.C. § 8403). A heads-up, not a legal opinion.
1. What the engine owns
Severity-ranked findings from pasted auto-renewal wording against heuristics derived from the Restore Online Shoppers’ Confidence Act (ROSCA), 15 U.S.C. § 8402-8403, read with the prohibition on misrepresentations in 16 CFR § 425.3 (Prenotification Negative Option Plans). ROSCA § 8403 imposes three operative duties on an online negative-option offer: (1) clearly and conspicuously disclose all material terms before obtaining the consumer’s billing information; (2) obtain the consumer’s express informed consent before charging; and (3) provide simple mechanisms for a consumer to stop recurring charges. Check families: term-disclosure (a “free trial” or “subscribe” with no renewal price and/or cadence shown before billing — § 8403(1)); express-consent (auto-enroll, a pre-checked box, or “by continuing you agree” in place of an affirmative opt-in — § 8403(2)); difficult-cancellation (phone / mail / in-person / multi-step with no self-serve route, or auto-renewal with no cancel path — § 8403(3)); misrepresentation (“free trial / cancel anytime / no obligation” contradicted by the real charge); post-transaction-third-party (a partner charge billed to a card from an earlier, different transaction without fresh consent — § 8402); and claims-context advisories (renewal-reminder wording that points at state law, and terms-page-only placement) that never invent flow facts. Scores dock per HIGH/MEDIUM/LOW finding (advisories never dock); an offer that shows the renewal price and cadence before billing, captures an un-pre-checked affirmative opt-in, and offers a self-serve cancel route is not docked. The rule snapshot is dated by the engine version — it is not synced with regulator pages in real time. Demo is labelled Rule-based — never silent mock.
2. What optional AI may do
Explain or polish findings when a key is configured. Upstream failure returns 502. No invented findings, no quotes from copy you did not paste, no consent-control, cancel-flow, or reminder-delivery check the engine did not run.
3. What you must do
- Review findings against your own enrollment, checkout, and cancellation flow — only you know whether the opt-in is genuinely un-pre-checked, whether the cancel path actually works, and whether the material terms render before billing.
- Apply fixes in your own emails, ads and pages — AutorenewPrecheck never publishes or connects to a billing platform, payment processor, or CRM.
- Treat output as decision-support, not a subscription-compliance certification or legal advice.
4. What we deliberately do not do
- Consent-control checks, cancel-flow verification, or confirmation that a disclosure renders before billing or a renewal reminder was sent — those facts live outside the pasted text.
- Continuous monitoring of live checkout pages or automated publishing.
- Compliance probabilities or enforcement-prediction numbers — outside the FTC nobody can compute what it will decide.
- Legal review — ROSCA checks read wording patterns, not your full obligations. The federal backbone is the ROSCA statute; 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; state auto-renewal laws and non-US regimes appear as labeled advisories only. Regulated programs need a qualified professional.
Heuristic pre-check — not a subscription-compliance certification or legal advice. 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; state auto-renewal laws are advisories only. No consent-control, cancel-flow, reminder-delivery, or enforcement verification performed.