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.