ROSCA Compliance: What Merchants Selling in the US Need to Know About Subscriptions & Online Payments

Summary in a Snap:

• The Restore Online Shoppers’ Confidence Act protects US consumers from unexpected charges related to subscriptions, free trials and automatic billing, and requires that merchants provide a simple way to cancel.
• This year, the FTC has brought high-profile cases under ROSCA against well-known brands like Amazon and Uber.
• BlueSnap’s Subscription Billing Engine accounts for these regulations and can help you stay compliant.

ROSCA, or the Restore Online Shoppers’ Confidence Act, is a 2010 regulation. It’s designed to protect consumers from unexpected charges, and the Federal Trade Commission (FTC) continues to enforce it aggressively today.

In fact, the FTC has brought several high-profile cases just this year under ROSCA, including:

• Chegg Settlement (September 2025): Chegg, an education technology provider, paid $7.5 million after the FTC alleged it made subscription cancellations difficult and charged consumers after they made cancellation requests.
• Amazon Case (August 2025): The FTC claims Amazon used dark patterns to trick consumers into enrolling in auto-renewing Prime subscriptions. The company also designed their cancellation process to stop cancellation requests rather than accommodate them. In September, Amazon agreed to pay a $2.5 billion settlement.
• Uber Lawsuit (April 2025): The FTC sued Uber over its Uber One subscription, claiming the company charged consumers without their consent, did not deliver promised savings and made it difficult to cancel the subscription despite its “cancel anytime” promises. This suit is ongoing and no decision date has been set.

ROSCA Compliance Requirements for Merchants

If your business provides subscriptions, free trials or recurring billing online to US customers, you must understand ROSCA’s requirements. The regulation requires businesses that offer recurring or automatic billing to:

1. Clearly disclose all material terms (including prices, renewal schedule and cancellation method)
2. Obtain a consumer’s express, informed consent before charging and
3. Provide a simple way to stop future charges

Staying compliant is not only the law, but it also protects your customers and strengthens trust in your brand.

How BlueSnap, Powered by Payroc, Helps Merchants Stay ROSCA Compliant

At BlueSnap, we work with our merchants to identify what requirements they need to meet for automatic and subscription billing, and our Underwriting Team monitors merchants’ websites for compliance.

Plus, our Subscription Billing Engine includes regulatory features that make compliance easy:

• BlueSnap Checkout, our hosted checkout page, includes a mandatory checkbox at the time of enrollment to capture the cardholder’s express consent to entering an ongoing subscription service with recurring payments.
• Our Subscription Billing Engine includes a dedicated email for those who use our email solution providing the appropriate enhanced notification of the terms and conditions of the subscription to the cardholder.
• BlueSnap can also issue receipt emails that include a cancellation link that automatically cancels the subscription if the customer clicks on it.

For additional information on ROSCA, see the FTC’s ROSCA page. We recommend reviewing your signup and cancellation flows and talking to your legal team.

Frequently Asked Questions

What is ROSCA in online payments?

ROSCA, or the Restore Online Shoppers’ Confidence Act, is a regulation that protects US consumers from unexpected charges related to subscriptions, free trials or automatic billing. It requires merchants to clearly disclose terms, get express consent before charging the consumer and provide an easy way for customers to cancel recurring payments.

What are the risks of not complying with ROSCA?

Non-compliance can lead to customer complaints and chargebacks, but also FTC investigations, lawsuits, financial penalties and reputational damage.

What does the Restore Online Shoppers’ Confidence Act require from merchants?

ROSCA requires businesses that offer subscriptions or recurring billing to US consumers to:

• Clearly disclose material terms, including pricing, renewal details and cancellation method
• Obtain express, informed consent before charging customers and
• Provide a simple and accessible way to stop future charges

For additional information on ROSCA, see the FTC’s ROSCA page.

Who needs to comply with ROSCA?

Any business that offers subscriptions, free trials or automatic renewals online to US consumers must comply with ROSCA.

How does BlueSnap, powered by Payroc, help merchants with ROSCA compliance?

BlueSnap’s Subscription Billing Engine includes features to help with this compliance, including

• mandatory consent checkboxes at checkout for the cardholder to consent to entering an ongoing subscription service with recurring payments
• a dedicated email for those who use our email solution providing the appropriate enhanced notification of the terms and conditions of the subscription to the cardholder and
• BlueSnap can also issue receipt emails that include a cancellation link that automatically cancels the subscription if the customer clicks on it