> A person making an automatic renewal or continuous service offer to a consumer must provide the consumer with the option to cancel at any time using a simple cancellation mechanism that is as easy to use as the mechanism that the consumer used to provide consent and that is through the same medium that the consumer used to provide consent

So if a startup lets someone sign up using Stripe, for example, does this mean that they need to have a way to unsubscribe that is as easy as Stripe? Lots of companies have a way to unsubscribe electronically, but it requires logging in to your account, going into settings, saying you want to unsub, and possibly declining various offers to stay.

Surely at some point a company could cross the line of "a simple cancellation mechanism that is as easy to use as the mechanism the consumer used to provide consent". But where is the line exactly? Surely you don't have to have a big red cancel button on every page of your platform, but at the same time surely it can't be hidden 8 levels down in the settings.

Some examples would be helpful to let businesses and consumers know what is acceptable and what is not acceptable.

There's a funny thing when people don't like something where they can intentionally misunderstand it or impart artificial complexity onto it painting a picture like the rule is hard to comply with. I suppose to variation of a straw man argument. I honestly don't think this is one is hard to understand at all. If you can sign up through the web you should be able to cancel through the web. If you can sign up through the phone you should be able to cancel through the phone. Companies knowingly an intentionally make it harder to cancel than to sign up for obvious reasons that have nothing to do with doing right by the consumer. This is a very good law and it should be adopted everywhere.

Maybe those people who’ve spent so much time A/B testing where to put the signup buttons can use those skills to figure out where to put the cancel buttons so that they are as easy to find.

I think the point of the law is - the same medium. If you signed up online, you should be able to cancel subscription also online.

> ...and possibly declining various offers to stay

Unless there were several efforts to get you to think twice before subscribing, clearly trying to get you to think twice before unsubscribing is not as easy to use.

Heres what you should do to be safe. On the user's settings/profile/whatever user page you have, add a cancel button. When the user clicks it say "are you sure? Yes/no". If the user clicks yes, cancel the account.

No extra hoops at all.

I suspect that something as simple as 2-3 emails prior to renewal, each with a one-click (no auth needed) clear, unobscured "unsubscribe" button would be sufficient.

I don’t think anyone will have trouble figuring out a good way to comply with this. It’s not clear exactly where the line is, so just don’t go near it. Make it easy to cancel, job done. If a company wants to push the boundaries by making it as difficult to cancel as the rule allows, they’re running the risk of being on the wrong side of the line and suffering the consequences, and that’s their choice.

The only reason any company would have trouble complying with this rule is if they want to abuse customers to keep them from canceling when they want to cancel. The amount of sympathy I have towards such companies requires advanced scientific notation to quantify.

But where is the line exactly?

This is what courts are for. There is no exact line because many situations are different.

Surely you don't have to have a big red cancel button on every page of your platform

Why not?

Some examples would be helpful

The text you quoted is clear enough to me, and it's probably clear to any reasonable person (most rules are written this way). If you're worried about gaming the system to find the exact process that just on the "legal" side of things, you probably aren't reasonable.

In my country the rule is "unsubscribe the same way you subscribed". So no bullshit with having to write a literal physical letter through the mail (yes really this happened) or having to call a callcenter in India and having to explain why you want to your stop subscription.