From B2B contracts to free-account signup screens, regulators and courts are examining the entire subscriber relationship.
SIGNAL OF THE WEEK
It's no longer enough to know what your subscription terms say. You may also need to show what your customers actually saw, agreed to and experienced.
Your compliance lawyer may need a seat at more meetings. Week after week, we're seeing subscription lawsuits, enforcement actions and court decisions examining far more than whether customers can cancel easily. Can a B2B customer leave a recurring contract without unexpected charges? Were important terms visible when someone opened a free account? Could a business show what a subscriber agreed to pay back in 2023?
The scrutiny spans local, state, federal and international authorities, touching everything from offers and enrollment to billing, renewals and cancellation. The laws differ, and some matters involve allegations that haven't been proven or proposals that haven't taken effect. But the attention being paid to the entire subscriber relationship is difficult to ignore.
If you haven't already, it's time to get serious about preserving evidence of what subscribers actually experience. That includes the offers and terms they were shown, how consent was captured, the notices they received and what happened when they requested changes or cancellation. Your compliance lawyer should be part of those conversations, alongside marketing, product, billing and customer service, helping determine what records need to be kept and for how long.
A screenshot of today's checkout page won't necessarily explain what a subscriber saw three years ago.
Stories Behind This Week's Signal
Toast and Vermont: B2B Contracts Are Getting Attention
The FTC and seven states have sued Toast over alleged undisclosed subscription fees and cancellation restrictions. Toast disputes the allegations and the FTC's interpretation of federal law. Separately, Vermont reached a settlement with UniFirst over automatic-renewal practices involving business customers. Commercial subscription contracts shouldn't be overlooked when reviewing compliance requirements.
Read: FTC and States Sue Toast Over Subscription Fees and Cancellation
Read: Vermont Settlement Shows B2B Contracts Face Renewal Rules
SuperGrok: What Did the Customer Actually See?
A federal judge declined to enforce an arbitration provision after examining how xAI presented its terms during free-account registration. The underlying subscription allegations remain unresolved. The ruling illustrates why the design of an enrollment experience, including where important terms appear, can become evidence in court.
Read: SuperGrok Court Ruling Turns on Free Account Signup
CookUnity: A 2023 Offer Is Being Challenged in 2026
A proposed class action questions how CookUnity disclosed recurring charges after a discounted first order and handled cancellation. The allegations remain unproven, but the case raises a practical concern: Can a business reconstruct what someone was offered and agreed to several years earlier?
Read: CookUnity Suit Challenges Consent to Recurring Meal Charges
Also Worth Noting
The FTC and two states are challenging Lens.com's pricing, checkout disclosures and recurring billing practices. The FTC is also asking nine companies how customer information influences pricing, while the UK has outlined proposed requirements for renewal notices, cancellation and refunds.
ALSO ON THE RADAR
AI & Technology
Reddit's Search Traffic Falls Even as AI Cites It
Reddit is receiving fewer Google search referrals while its content appears in AI-generated answers. For publishers and subscription businesses, being cited doesn't necessarily bring visitors or potential subscribers to their sites.
Salesforce Plans to Acquire Braze
Salesforce's proposed acquisition would bring Braze's customer engagement technology into its business. Customers will be watching what happens to product development, integrations and pricing.
Payments & Billing
Stripe Expands Radar Fees to Subscription Renewals
More subscription renewals are now subject to paid Radar fraud-screening charges. The per-screening price hasn't increased, but additional screenings could raise costs for businesses using the service.
Adyen Invests in Billing and Loyalty
Adyen is accepting lower near-term margins as it expands its billing and loyalty capabilities. The investments may create more integrated services, along with new choices about how much business operators place with one provider.
South Korea Fines Apple and Google Over App Payments
A combined $48 million in fines and orders affecting alternative payment arrangements could change the choices available to subscription apps. Both companies dispute the decision.
Membership & Growth
T-Mobile Lets Customers Choose Subscription Benefits
T-Mobile's T-Mix plans let customers select and periodically change subscription benefits. Participating providers receive three months of guaranteed revenue, but must compete to remain among the customer's chosen services.
Three Different Bets on Membership Growth
Verizon added subscribers while spending less on promotions. Travelzoo doubled Club membership revenue while investing heavily in acquisition. Albertsons lowered its membership price and changed the benefits. Each is testing a different balance between growth, cost and customer value.
Read: Verizon | Travelzoo | Albertsons
QUESTION FOR YOUR TEAM
Who in your business is responsible for preserving previous versions of subscription offers, signup experiences and consent records?
And if those records were needed tomorrow, would the people responsible for compliance, billing and customer service know where to find them?
INSIDE THE MEMBER CENTER
New and updated resources this week cover compliance, recurring payments and AI.
Compliance: New Guidance and Updated Briefs
Our new UK Subscription Cancellation and Renewal Rules brief is available, alongside updates to the Subscription Regulatory Monitor and Enforcement, Litigation & Risk Activity Tracker.
We've also updated our federal online subscription, New York City, Vermont and Louisiana briefs, covering requirements, effective dates and recent regulatory activity.
Payments: Updated Operator Briefs
Our Visa, Mastercard, American Express, Stripe and PayPal briefs now reflect recent developments affecting recurring payments, fees, authorization and disputes. We've also updated our Recurring Payment Authorization Guide.
AI: October Briefing Now Available
Our October briefing, AI Is Entering the Subscription Relationship, looks beyond the latest AI tools. It examines Anthropic's research on AI helping develop more capable AI, declining search referrals as AI answers become more common, and growing questions about AI agents making purchases and payments. We connect those developments to what subscription operators need to consider about technology investments, operating costs and control of the customer relationship.
Related to this week's Signal: Our Subscriber Journey Mapping & Audit Guide, including its downloadable worksheet, helps teams examine the actual subscriber experience from enrollment through cancellation.
That's it for this week,
Kathy
Kathy Greenler Sexton
CEO & Publisher
Subscription Insider®
