I almost shipped an auto-renew checkbox that broke ROSCA

We were about to launch a yearly plan with auto-renew. I wrote the checkout copy, the cancellation page, and the confirmation email, then sent it to legal. They came back with a list of problems that should have been obvious and weren't — and every one traced back to a ROSCA expectation I'd never internalized.

The Restore Online Shoppers and Consumers Act (ROSCA) governs negative-option and auto-renewal offers in the US. The short version: you can't charge someone on a recurring basis without clear disclosure, express informed consent, and a simple way to cancel. My draft failed all three in small ways.

What my copy got wrong

First, the pre-billing terms were buried. The renewal price and date were in a footnote, not next to the consent action. ROSCA wants the material terms disclosed before the consumer agrees, not after. Second, the checkbox was pre-checked — which is not express consent. Consent has to be an affirmative act, not a default.

Third, the cancellation path required emailing support and waiting. "Simple" cancellation means a mechanism at least as easy as the sign-up; a support ticket with a two-day lag isn't it. Fourth, the free trial wording implied the trial was free when the card would be charged unless cancelled by a specific date I'd phrased vaguely. Fifth, the post-transaction upsell added a third-party charge the user hadn't clearly agreed to.

A pre-check tool would have flagged each of these before I wasted legal's time. AutorenewPrecheck scores enrollment, checkout, and cancellation wording for exactly these five issues — pre-billing disclosure, express-consent detection, simple-cancellation check, free-trial misrepresentation, and post-transaction third-party charges.

Why I treat it as a pre-check, not a guarantee

I want to be precise about scope. This is decision-support. It reads the wording I paste and points at likely gaps against ROSCA patterns; it is not a lawyer and it doesn't certify compliance. I used it to catch my own blind spots, then handed the flagged sections to counsel. That division — machine for the obvious, human for the binding call — is the only sane way to use a tool like this.

If you're pasting your own offer into AutorenewPrecheck, read the flagged lines as "explain this to legal," not "this is safe to ship."

The free-trial wording was the sneakiest gap

The one that bit me hardest was the trial. My copy said "start your free trial" and only mentioned the upcoming charge in a line below the fold, with a date phrased as "around your next billing cycle" instead of a fixed day. That's free-trial misrepresentation: the trial isn't free if the consumer can't tell when and how much they'll be charged.

Fixing it meant stating the exact charge date and amount before the consent action, in the same visual block as the button. A small change in placement, a large change in compliance. Pre-checks catch these because they look at where the disclosure sits, not just whether the words exist somewhere on the page. That placement logic is the part a human reviewer skims past and a structured check won't.

FAQ

Does this replace a lawyer?
No. It's a pre-publish check that surfaces likely ROSCA gaps in your wording. The legal call on whether you comply is still a person's.

What's the most common auto-renew mistake?
A pre-checked box or buried renewal terms. Both read as a lack of express, informed consent, which is core to ROSCA.

Does it cover state auto-renewal laws?
It focuses on the federal ROSCA pattern. State "auto-renewal laws" add requirements; check those separately with counsel.

When should I run it?
Before the offer goes live — paste the enrollment, checkout, and cancellation copy while it's still cheap to change.