Carlos Lopez By Carlos Lopez

Training & Education · EdTech Platforms

Canceling a Surprise EdTech Subscription Charge: What the Law Actually Requires

A 7-day free trial that quietly becomes a $400 annual charge is a familiar pattern on platforms like Coursera and MasterClass. The federal rule meant to stop this was struck down in court in 2025 — but state law, especially California's, is still very much in force.

The Federal Rule Is Gone — Don't Rely on It

On July 8, 2025, the Eighth Circuit Court of Appeals vacated the FTC's "Click to Cancel" rule (the updated Negative Option Rule) in its entirety, just days before it was due to take full effect. The court found the FTC had skipped a legally required procedural step, not that the underlying consumer protection goal was wrong — but the practical result is the same: the specific federal requirement for a simple, one-click cancellation process is no longer in force. If you've read articles describing this federal rule as active protection, that information is now outdated.

This doesn't mean subscription platforms are unregulated. The pre-1973 federal negative option rule remains in place, the FTC can still pursue unfair or deceptive subscription practices case by case under its general authority, and the Restore Online Shoppers' Confidence Act (ROSCA) still requires clear disclosure, informed consent, and a simple cancellation mechanism for any negative-option billing arrangement.

California's Law Is Now Stricter Than the Vacated Federal Rule

California's Automatic Renewal Law (CARL) was significantly amended by Assembly Bill 2863, with the new requirements taking effect July 1, 2025 — separate from, and unaffected by, the federal court decision. For any California consumer (and many platforms simply apply their compliance approach to all US users rather than build separate flows), the amended law now requires: "express affirmative consent" to auto-renewal terms, retained as proof for at least three years; the free trial rules now explicitly cover trials that convert to paid subscriptions, not just already-active subscriptions; cancellation available in the same medium used to sign up, without extra obstructive steps; and an annual reminder notice disclosing the charge amount, frequency, and how to cancel.

Roughly 30 US states now have similar automatic-renewal laws, with California, Colorado, and New York among the strictest — a platform operating nationally is very likely applying at least some of these state-specific rules to its checkout and cancellation flow already.

Practical Steps to Cancel and Dispute a Charge

  1. Locate your original signup confirmation and check what consent language you actually agreed to — was auto-renewal clearly and separately disclosed, or buried in general terms?
  2. Attempt cancellation through the platform's own process first, and screenshot every step, including any point where the process seemed deliberately obstructive.
  3. If the platform makes cancellation disproportionately harder than signup, cite this explicitly in a written complaint — this pattern is exactly what ROSCA and state ARLs target.
  4. If you're a California resident (or the platform applies CA-equivalent rules broadly), reference the specific AB 2863 requirements — express affirmative consent, same-medium cancellation — in your complaint.
  5. If the platform refuses a reasonable refund for an unwanted renewal you tried to cancel, a card chargeback remains a separate, available option — most banks treat "attempted cancellation, charged anyway" as a strong basis for a dispute.

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