A subscriber who signed up online can end the subscription online, at will, without being handed to support [1][2]. No rule names a screen count. Five is the shortest sequence we found that meets the rules in force today and still tells a leaving subscriber everything they need.
The pattern those five screens replace has a nickname: the roach motel, easy to get into and hard to get out of.
All five are below, with the copy each one carries and the check each one has to pass. You can also download them as a two-page PDF, free and with no form.
The federal anchor in the US is ROSCA, which asks for simple mechanisms for stopping recurring charges [1]. California’s amended automatic renewal law carries the screen-level detail: what a cancel control has to be, and what a retention offer may do while somebody is leaving [2].
This is a design template and not legal advice. It says what the rules we read require of a screen, and your counsel says what they require of you.
| Screen | What it does | The rule behind it |
|---|---|---|
| 1. Cancel entry point | A direct link or button in the account, billing or settings area, reachable without contacting anyone | ROSCA simple mechanism [1], section 17602 (d)(1) and (f) [2] |
| 2. One retention offer | At most one offer, with a click to cancel control displayed beside it the whole time | Section 17602 (e)(2) [2] |
| 3. Cancellation survey | Asks why, accepts a skip, never holds the cancellation behind an answer | Section 17602 (d)(1), no steps that obstruct or delay [2] |
| 4. Confirmation | States the end date and what happens next, then two buttons that each name their action | Section 17602 (d)(1) [2] |
| 5. Done screen and email | Confirms it is done, repeats the end date, sends the same record by email | No rule in this post requires the email. It is the record you keep |
What the roach motel pattern looks like, and what replaces it
A roach motel is a product you join in one click and leave through a support inbox.
Its opposite is boring on purpose. The way out sits where the subscriber already is, in the same medium they subscribed in, and every screen in the path either carries information they need or ends the subscription. Nothing in it exists to slow them down.
The taxonomy that named this category of design calls the pattern Hard to cancel [3]. Roach motel is the colloquial name for it, so you'll meet both.
Cancellation is one of three flows where these patterns cluster. The full catalogue, with pricing and onboarding as well, is in the guide to dark patterns in SaaS products.
What is a roach motel dark pattern?
It's an interface with an easy way in and a hard way out. The taxonomy’s entry for it describes a user who “finds it easy to sign up or subscribe, but when they want to cancel they find it very hard” [3]. In a subscription product it's rarely one deliberate wall. It's a sign-up flow that got rebuilt every year and a cancel flow that nobody opened.
What is an example of a dark pattern?
Here's one you can check in your own product this afternoon. A subscriber clicks cancel, lands on a discount offer, and the only two buttons on that screen are the offer and a way back, so the cancellation they asked for needs a second attempt. That screen does not meet the California condition. The statute allows the offer only while a prominently located, continuously and proximately displayed click to cancel control sits on the same screen [2].
Which rules does a compliant cancellation flow have to meet?
Four rules decide what a cancellation screen can look like, and one of the four stopped counting in 2025.
| Rule | Status on 15 October 2026 | What it requires of a screen |
|---|---|---|
| ROSCA, the Restore Online Shoppers’ Confidence Act, US federal | In force | All material terms disclosed before billing information is taken, express informed consent before the charge, and simple mechanisms for stopping recurring charges [1] |
| California Business and Professions Code section 17602, as amended by AB 2863 | In force. The amendments reach contracts entered into, amended or extended on or after 1 July 2025 [2] | Online termination at will with no further steps that obstruct or delay it (d)(1), cancellation in the same medium used to subscribe (f), and a retention offer only beside a click to cancel control (e)(2) [2] |
| EU Digital Services Act, Article 25 | Applicable since 17 February 2024 [4] | No interface that deceives, manipulates or materially distorts or impairs a free and informed decision, for providers of online platforms as Article 3 defines them [4] |
| FTC 2024 amendment to the Negative Option Rule, the click-to-cancel rule | Vacated in its entirety on 8 July 2025, before its deferred compliance date of 14 July 2025 [5] | Nothing. No federal click-to-cancel rule is left to design a flow against [5] |
Two of those four reach a screen directly, and they're the two every screen below is built from.
Article 25 binds providers of online platforms, defined in Article 3 as a hosting service that stores and disseminates information to the public, so a closed B2B tool often sits outside it [4]. Recital 67 is worth holding your flow against either way, because it names a cancellation made significantly more cumbersome than signing up among the practices the Article is aimed at [4].
The walkthrough of all four, and what they mean for pricing and onboarding too, is in the main guide.
Is dark pattern illegal?
Not as a category, and that's the honest answer to the question people type. No rule in the table bans dark patterns by name. Particular flows meet particular rules instead, and which rule reaches you depends on where your subscribers are and what your product does.
Screen 1: the cancel entry point
Screen 1 is a link or a button, and the only hard part is putting it where a subscriber will look.
California names two acceptable online routes: a prominently located direct link or button, which may sit in a customer account or profile or in device or user settings, or an immediately accessible termination email that the business formats and the subscriber can send without adding anything to it [2]. A support ticket is neither of those.
The statute also puts the exit in the same medium the subscription started in [2]. A plan that starts self-serve in the app ends self-serve in the app.
You can still ask who they are. Authentication before an online termination is allowed where the subscriber has an account, provided somebody who can't or won't authenticate online keeps another way out [2].
- Nav label: Plan and billing
- Control: Cancel subscription
- Helper line: Access runs to the end of the period already paid for. [Edit this line to match your own terms.]
The check: a subscriber who has never cancelled before reaches the control from the product home screen without using search and without asking anyone.
Screen 2: one retention offer, with a click to cancel button beside it
Flows get into trouble on screen 2, and the rule on it is unusually specific.
A business may display a discounted offer, a retention benefit or information about the effects of cancellation, provided it simultaneously displays a prominently located and continuously and proximately displayed direct link or button entitled “click to cancel”, or words to that effect [2]. Use that control and the cancellation gets processed promptly, with nothing further put in the way [2].
So: one offer, on one screen, with the exit visible throughout.
The failure shape is a queue. An offer, then a survey, then a pause suggestion, then the confirm. Each of those screens tests well on its own, and together they're the practice Recital 67 describes, a cancellation made significantly more cumbersome than the sign-up it mirrors [4].
- Offer heading: Before you go: [the one offer, with its price and its end date]
- Primary control, always visible: Click to cancel
- Secondary control: Take the offer
- Never on this screen: a cancel control behind a scroll, a tab or a second click
The check: at the smallest width you support, the offer and the cancel control are on screen together, and the cancel control stays there while the offer is read.
Screen 3: the cancellation survey, and why it is skippable
Asking why is fine. Requiring the answer is the problem.
California’s wording is that a business letting people subscribe online has to let them terminate online, at will, without further steps that obstruct or delay their ability to terminate immediately [2]. A mandatory survey answer is a step between a subscriber and the exit, so the survey asks once and then gets out of the way.
We'd keep the question and drop the requirement. An answer somebody chose to give is worth more than one they gave to get out, and that is our judgement rather than a measurement.
- Heading: Why are you cancelling? (optional)
- Options: Too expensive, missing a feature, we found another tool, the project ended, something else
- Free text label: Anything else you want us to know? (optional)
- Skip control: Skip and continue
The check: the path completes with every field empty, and the word optional is on the screen rather than in a tooltip.
Screen 4: the confirmation step and its two buttons
By screen 4 the subscription is one click from ending, so it carries the facts somebody needs in order not to regret that click.
Four of them. The date access ends, what happens to their data after that date, what happens to the seats and invitations they have issued, and whether anything is refunded.
Then two buttons, each naming its own action. One ends the subscription, one keeps it, and neither says anything else.
Labels that editorialise are the pattern rather than the fix. A confirm button written as a confession reads as an interface pushing a decision instead of describing one, which is the shape Article 25(1) calls out as impairing a free and informed decision, for the platforms it covers [4]. Literal labels also stay consistent with the rest of your product, which is a design system question as much as a copy one.
- Heading: Confirm cancellation
- Body: The subscription ends on [date]. Access runs until then. After that, [what happens to data, seats and invitations]. [Refund position.]
- Buttons: Cancel subscription, and Keep subscription
- Never on this screen: a button label carrying a feeling instead of an action
The check: read both labels aloud with no context. If either one needs the screen around it to be understood, rewrite it.
Screen 5: the done screen and the confirmation email
Screen 5 says it is done, and says when.
No rule in this post’s table requires the email that follows it. Send it anyway: it's the record both sides keep, and the cheapest evidence you'll ever produce that somebody got out when they asked to.
Five lines are enough. What was cancelled, the date access ends, what happens after that date, how to come back, and who to contact if something looks wrong.
- Screen heading: Your subscription is cancelled
- Screen body: Access runs until [date]. We have sent a copy of this to [email].
- Email subject: Your [product] subscription is cancelled
- Email body: the five lines above, in that order, with no offer attached to them
The check: the email arrives with no marketing block in it, and its end date matches the end date on screen.
How to run this template against your own flow
Take the two-page PDF, open your own product, and give it an hour this week.
- Cancel your own product. Use a test account on a paid plan and go all the way to a confirmed end date. Not the admin panel: the account your customers actually have.
- Write down every screen between the entry point and the confirmation, in order, including the ones that only carry an offer.
- Lay your list beside the five. Any screen of yours that isn't one of them is either carrying information the subscriber needs or standing in their way.
- Fix the ones in their way first, and fix them by removal. A screen taken out of a cancel path needs no copy review and no second opinion.
- Check the two controls the statute names: a direct link or button where a subscriber would look, and a click to cancel control beside any retention offer [2].
- Hand the list to counsel before engineering. You're the one who can see the flow, and they're the ones who can say which rules reach your subscriber base.
Then run the ten checks. They're the same ten on page two of the PDF, two per screen, so a reviewer can tick them in a meeting without reading this post first.
| Screen | Check | Passes when |
|---|---|---|
| 1 | Is the cancel control in the account, billing or settings area? | A subscriber finds it without search and without support |
| 1 | Can a plan that started online end online? | Self-serve in, self-serve out, in the same medium [2] |
| 2 | How many offers sit in the path? | At most one |
| 2 | Is a click to cancel control beside the offer? | Visible and usable the whole time, at every width [2] |
| 3 | Can the survey be skipped? | The path completes with every field empty |
| 3 | Is the word optional on the screen? | On the screen, not in a tooltip |
| 4 | Does the screen state the end date and what happens to data? | Both, above the confirm button |
| 4 | Do both button labels name their action? | Neither label carries a feeling |
| 5 | Does the subscriber get a record? | A done screen and an email carrying the same end date |
| 5 | Is the email clean? | Confirmation only, with no offer attached |
Two habits make the rebuild stick. Put the cancel path into whatever you already review before a release, and keep a test subscription alive so somebody can walk it without asking billing for help.
Cluma runs this kind of rebuild as design work: user flows, wireframes and prototypes in the Ship module, with pricing published per module. Everyday graphic design tasks come back in about 48 hours, and bigger product work moves milestone by milestone with progress roughly every 48 hours in a shared board. Your engineers implement it and your counsel rules on it.
More free files sit on the templates page, and the playbooks are on the guides page.
Where this template stops
Four limits, and we'd rather print them than let you find them later.
This is a design template. It isn't legal advice, and nothing in it says your flow is compliant.
California’s statute is one state’s law. It's in here because it's the one with requirements specific enough to draw a screen from, and a flow built to it is not thereby compliant everywhere your subscribers live [2].
Whether Article 25 of the Digital Services Act reaches your product is the Article 3 question, answered product by product, and having European users is not the same thing as being an online platform [4].
The US federal picture has been unsettled since July 2025, which is why every rule here carries a date [5]. If you're reading this well after October 2026, treat the dates as part of the claim and check the rules again.
The sequence itself is ours. The statute names controls and prohibits obstruction, it does not name a screen count, and we picked the shortest sequence that still carries everything a leaving subscriber has to be told [2].
References
- Federal Trade Commission, Time for a ROSCA recap: FTC says risk free trial was risky and not free, business guidance blog, page last updated 2 December 2025, read 15.10.2026. Tier 1, government primary source. Source for the three things ROSCA asks of an online negative-option seller, in the FTC’s own summary. Known weakness: staff business guidance rather than the statutory text, so it is the regulator’s reading of the law and not the law itself. ftc.gov refuses automated clients from our server, both plain HTTP and a headless browser, so the page was read and re-checked from a different network path.
- State of California, Business and Professions Code section 17602, as amended by AB 2863 (Stats. 2024, Ch. 515), California Legislative Information, read 15.10.2026. Tier 1, the statute itself. Every screen requirement in this post traces to a subdivision of this section. Online termination at will, with no further steps that obstruct or delay it, is subdivision (d)(1), and the two acceptable online methods are (d)(1)(A) and (B). Authentication, with an offline route kept for anyone unwilling or unable to use it, is (d)(3). A retention offer shown only beside a continuously and proximately displayed click to cancel control is (e)(2). Cancellation in the same medium the consumer used is (f). The amendments applying to contracts entered into, amended or extended on or after 1 July 2025 is (j). Known weaknesses: this is one state’s statute, and the step from a subdivision to a screen is our design reading of it. The site refuses plain HTTP clients, so the section was read in a rendered browser session.
- Deceptive Patterns, Types of deceptive pattern, deceptive.design, read 15.10.2026. Taxonomy publisher’s own site. Where the pattern’s formal name, Hard to cancel, and the definition quoted in this post come from. Known weakness: the taxonomy does not use the term roach motel at all, and it is cited here for nothing beyond that name and definition.
- European Union, Regulation (EU) 2022/2065, the Digital Services Act, Articles 3, 25 and 93 and Recital 67, EUR-Lex, read 15.10.2026. Tier 1, official EU legal text. The Article 25(1) wording, the Article 3 definition of an online platform, the Recital 67 line on cancellation being made significantly more cumbersome than signing up, and the date the Regulation applies from all come from the regulation itself. Known weakness: none as to authority, but whether Article 25 binds a given product is the Article 3 question and this post does not answer it for you. EUR-Lex refuses plain HTTP clients, so it was rendered in a browser session to read it.
- Latham & Watkins, Eighth Circuit vacates FTC click-to-cancel rule days before compliance deadline, client alert, read 15.10.2026. Tier 3, law firm client alert. Source for the case name, the date and the holding: Custom Communications, Inc. v. Federal Trade Commission, decided by the Eighth Circuit on 8 July 2025, vacating the 2024 amendment in its entirety days before full enforcement was due on 14 July 2025. Known weakness: a law firm’s summary and not the opinion itself. It was cross-checked in the same week’s research against alerts from four other firms reporting the same case name, the same date and the same holding.
