The Federal Trade Commission (“FTC”) filed a complaint on April 21, 2025, in the U.S. District Court for the Northern District of California against Uber Technologies, Inc. and Uber USA, LLC (collectively, “Uber”). The agency alleges violations of Section 5(a) of the FTC Act and Section 4 of the Restore Online Shoppers’ Confidence Act (“ROSCA”) stemming from Uber’s subscription program, Uber One.
According to the FTC’s complaint, Uber One, which costs $9.99 monthly or $96 annually, promised benefits like savings on rides and food delivery services. The complaint alleges that Uber enrolled consumers without their consent, billed some users before the promised charge date, and implemented a deliberately complicated cancellation process.
Consumers seeking to cancel allegedly had to pass through at least seven screens and complete 12 separate steps, with the first three screens omitting any reference to cancellation. If a user attempted cancellation within 48 hours of the billing date, Uber purportedly removed the option altogether, forcing a path of up to 23 screens and 32 steps, often looping consumers back to the start. Even those who reached customer service reportedly endured excessive wait times, leading to additional unwanted charges.
The FTC claims these practices violate multiple consumer‑protection obligations. Specifically, the FTC alleges Uber engaged in deceptive practices in violation of Section 5(a) by misrepresenting that consumers could “cancel anytime” without additional fees when in reality, cancellation required navigating through numerous screens and obstacles. The complaint also alleges Uber violated ROSCA’s requirements by failing to clearly disclose all material terms before (1) obtaining billing information, (2) securing express informed consent, and (3) providing a simple cancellation mechanism. The Commission seeks both injunctive relief and monetary remedies.
Potential Implications for Businesses
This action underscores the FTC’s renewed focus on negative‑option marketing, coming just ahead of the agency’s “Click to Cancel” compliance deadline. Companies should reassess their subscription workflows now to ensure they satisfy ROSCA and forthcoming FTC requirements. Below are recommended steps businesses can take to remain in compliance.
- Review enrollment flows. Disclose all subscription terms, including renewal dates, billing amounts, and cancellation procedures clearly and upfront before the customer complete sign-up.
- Streamline cancellation. Offer a cancellation path that is as quick and intuitive as enrollment, requiring no more steps than the original sign‑up flow.
- Audit billing practices. Confirm that charges post only on the disclosed dates and that no consumer is billed early or without authorization.
- Obtain express consent. Use unambiguous, affirmative consent mechanisms and place required disclosures immediately adjacent to the consent action so consumers understand they are agreeing to recurring charges.
- Document compliance. Maintain contemporaneous records showing adherence to the FTC Act, ROSCA, and the forthcoming Click‑to‑Cancel requirements.
- Monitor customer complaints. Track subscription‑related customer feedback to detect, investigate, and remediate emerging compliance issues promptly.
For more information or to discuss how these developments may affect your organization, please contact your assigned Relationship Partner or reach out to Susan Duarte at sfd@commlawgroup.com.
