FTC v. Uber One: When “Cancel Anytime” Meets 23 Screens of Hell
The FTC’s lawsuit against Uber over its Uber One subscription is basically a live lecture on what not to do with a SaaS subscription flow.
On paper, Uber One is simple:
- $9.99/month or $96/year for free deliveries, discounts, “$25/month savings,” and “cancel anytime.”
In the FTC’s telling, the reality looked more like this:
- users enrolled without clear consent,
- the promised savings ignored the cost of the subscription, and
- cancelling could mean up to 32 actions across 23 screens if you tried near your billing date. (AP News)
That combination is why the FTC sued Uber under both Section 5 of the FTC Act and the Restore Online Shoppers’ Confidence Act (ROSCA). (Federal Trade Commission)
For SaaS companies, this case is effectively:
“Here are the dark patterns we’re going to treat as unlawful going forward.”
What the FTC Says Uber Did
Here’s the Uber One case in one snapshot:
| 🚗 Item | 🔍 FTC’s allegation |
|---|---|
| Enrollment | Uber charged consumers for Uber One without their consent, including some who only intended to claim a one-time discount, some whose free trial hadn’t yet ended, and even some who didn’t have a full Uber account. (Federal Trade Commission) |
| Savings claims | Advertising that Uber One would save users “about $25 per month,” while not clearly accounting for the $9.99/month fee in that savings calculation. (Benesch Law) |
| “Cancel anytime” | Marketing Uber One as easy to cancel, but in practice requiring up to 12 actions over 7 screens, and in some scenarios up to 32 actions across 23 screens plus customer support contact, especially when cancellation was attempted within 48 hours of renewal. (AP News) |
| Legal frame | Violations of Section 5 (unfair/deceptive practices) and ROSCA for failing to clearly disclose material terms, obtain express informed consent, and provide a simple cancellation mechanism. (Federal Trade Commission) |
Uber, for its part, says its sign-up and cancellation flows are “transparent and user-friendly,” and that users can now cancel “in under 20 seconds” via the app, noting that earlier flows near the billing date were already changed. (AP News)
But from the FTC’s perspective, for years:
- signing up was frictionless and appealing,
- cancelling was a maze, and
- the marketing copy quietly skipped inconvenient math.
That’s exactly the combination ROSCA was built to attack.
ROSCA, Negative Option Rule, and “Dark Patterns” in One Picture
ROSCA (15 U.S.C. §§ 8401–8405) is a deceptively simple statute. In the subscription context, it basically demands three things:
| 📜 ROSCA requirement | 💡 Plain-English version | 🚫 How Uber allegedly failed |
|---|---|---|
| Clear, conspicuous disclosure of material terms before billing | Tell people in an obvious way that this is an auto-renewing subscription, what it costs, how often they’ll be billed, and how to cancel, before you get their card. (Cooley) | Uber allegedly hyped “$25/month savings” without clearly netting out the monthly or annual fee, and buried key subscription terms in the sign-up flow. (Benesch Law) |
| Express informed consent | Get an unambiguous “yes” to the subscription—no pre-checked boxes, no ambiguity between one-time and recurring. (Cooley) | FTC says consumers were billed for Uber One without clear consent, including after free trials and via flows where the subscription aspect wasn’t obvious. (Federal Trade Commission) |
| Simple cancellation mechanism | Make cancelling as easy as (or easier than) signing up—no labyrinth, no surprise hurdles. (Federal Register) | The complaint describes a cancellation UX with double-digit clicks and screens, extra barriers near billing dates, and failure to honor some cancellation attempts. (AP News) |
The FTC’s new Negative Option Rule / “click-to-cancel” rule—finalised in October 2024—was supposed to bake those expectations into a broad rule: equal ease of sign-up and cancellation, clear disclosures, and one-step cancellation. (Federal Trade Commission)
Then the 8th Circuit vacated the rule in July 2025, holding the FTC had exceeded its authority. (Inside Privacy)
So where does that leave subscription law?
- The negative-option rule is gone (for now).
- ROSCA and Section 5 are very much alive, and the FTC is leaning on them harder than ever—see Amazon’s $2.5B ROSCA settlement over Prime enrollments and cancellation, and now Uber. (Cooley)
The agency is basically saying: “We don’t actually need the new rule to treat these patterns as illegal; we’ll do it with ROSCA and the FTC Act instead.”
The Dark Patterns Uber Is Being Used to Illustrate
The Uber complaint reads less like a one-off case and more like a pattern manual:
| 🧩 Pattern | 🎯 How it shows up in Uber One allegations | 🧨 Why the FTC cares |
|---|---|---|
| “Roach motel” UX 🪤 | Easy to get in; hard to get out. Streamlined sign-up; multi-screen, multi-click cancellation, especially near renewal. (AP News) | Keeps people paying who would otherwise cancel; classic negative-option abuse. |
| Misleading savings claims 💸 | “Save $25/month” without clearly netting out the $9.99 fee or explaining assumptions. (Benesch Law) | ROSCA requires all material terms up front; cherry-picked savings are treated as misrepresentation. |
| Free trial traps 🎁 | Allegedly charging people before free trials ended, or rolling them into paid auto-renewals without clear consent. (AP News) | “Free” trials converting without clear consent are a classic ROSCA and ARL trigger. |
| Time-gated cancellation ⏳ | Requiring extra steps and even customer support contact when cancellation is attempted close to renewal. (AP News) | Non-obvious restrictions on cancellation windows are viewed as deceptive obstacles. |
If you strip away the Uber branding, this is the same pattern the FTC challenged with Amazon Prime’s “Iliad” cancellation flow—a four-page, six-click, 15-option gauntlet—and with other subscription providers. (Cooley)
The through-line:
The agency is done tolerating subscription revenue that depends on user confusion, inertia, or design tricks.
What This Means for SaaS and Subscription Businesses
If you run a SaaS product, a “Pro” tier, or any auto-renewing membership, Uber is being used as a public example of what your flows should not look like.
A few concrete implications:
- Equal friction is becoming the de facto standard. Even without the click-to-cancel rule, regulators and courts are treating “easier to sign up than to cancel” as a strong indicator of deception or unfairness.
- Savings claims are now ROSCA territory. Saying “save $X/month” while hiding the subscription cost, or making heroic assumptions about usage, risks being framed as failure to disclose “all material terms” under ROSCA. (Benesch Law)
- State Automatic Renewal Laws pile on. California, New York, Colorado and others have their own ARLs with independent requirements for clear disclosures, consent, and “easy to cancel” mechanisms. The Uber complaint stresses how these state regimes and ROSCA overlap. (Holland & Knight)
- Fixes after the fact don’t erase historical risk. Uber points out that it has simplified cancellation and issued refunds, but the FTC still filed suit for past conduct. The same was true for Amazon and other companies that “improved UX” only after getting on the agency’s radar. (The Washington Post)
Designing Subscription Flows the FTC Won’t Hate
Uber One, Prime, Streamlabs Pro—these are all pointing at the same design rules for subscriptions.
If you were to formalize this into a SaaS subscription UX checklist, it would revolve around three pillars:
Clear, up-front terms 🧾
Your paywall or sign-up screen should make it ridiculously obvious that:
- this is a recurring subscription (not just a one-off upgrade),
- the exact price and billing interval (e.g., $9.99/month, auto-renewing),
- any free trial conditions (how long, what happens when it ends), and
- how to cancel (at least in summary form, with a link to fuller details).
Anything that relies on tiny gray text, hover-only tooltips, or post-checkout emails is increasingly risky.
Real consent, not constructive consent ✅
Make sure the user has to do something that unmistakably means:
“Yes, I want this subscription and recurring charge.”
That typically means:
- explicit subscription-oriented button text (e.g., “Start Uber One for $9.99/month”) rather than vague “Continue,” and/or
- a separate check-box that can’t be pre-checked.
In Uber, Amazon, and similar cases, a lot of the FTC’s theory boils down to: “You never got a clean ‘yes’ to the recurring charge.” (Cooley)
Click-to-cancel in everything but name 🧨
Even though the formal click-to-cancel rule has been vacated, the underlying expectation lives on in ROSCA and Section 5 enforcement:
- At least one in-product path to cancel that is no more complex than sign-up.
- No hidden “gotchas” near renewal (like forcing live chat or support tickets).
- Immediate confirmation of cancellation, ideally by email and inside the product.
The Uber complaint’s screenshots and step-counts exist because the FTC wants other SaaS providers to imagine their own flows as exhibits.
Where Demand Letters Fit in This Landscape
As with the Streamlabs Pro case, the Uber fact pattern is exactly the kind of thing that starts with individual complaints and demand letters:
- someone discovers months of charges for a subscription they didn’t realize they’d agreed to;
- the company stonewalls or offers partial credits;
- counsel sends a letter citing ROSCA, state ARLs, and Section 5;
- the pattern repeats enough times that class counsel or the FTC steps in.
For businesses, having a playbook for responding to subscription-related demand letters matters just as much as having polished flows:
- swiftly refunding where the UX is clearly indefensible;
- triaging which flows need immediate redesign;
- avoiding written responses that can later be used as admissions (“we know it’s confusing, but…”).
For plaintiffs’ lawyers, Uber and Amazon provide ready-made complaint templates and a clear roadmap of the facts the FTC cares about: sign-up screen design, email confirmations, cancellation paths, and internal metrics on how often users drop off mid-cancel.
The Bigger Pattern: ROSCA Is the New Big Stick
Uber isn’t happening in isolation. In the last couple of years you now have:
- Amazon Prime – $2.5B ROSCA settlement for “dark pattern” enrollments and a labyrinthine “Iliad” cancellation flow. (Reuters)
- Uber One – FTC lawsuit alleging deceptive sign-up, misrepresented savings, and cancellation barriers under ROSCA and Section 5. (Federal Trade Commission)
- A trail of other subscription cases (Publishers Clearing House, LA Fitness, Adobe, smaller SaaS and fintechs) all built on similar theories. (Cooley)
The message is increasingly straightforward:
- Subscriptions are fine.
- Subscriptions that depend on confusion, inertia, or “dark patterns” are not.
Uber One is simply the latest (and very visible) case the FTC is using to make that point to the entire SaaS industry.