The Subscription Trap: ROSCA, the Revived Click-to-Cancel Rule, and Dark Patterns Enforcement in 2026

Andrew Lustigman, Chair of Olshan's Advertising, Marketing & Promotions Group and Co-Chair of the firm’s Brand Management & Protection Group, will deliver a presentation for a myLawCLE webinar entitled “The Subscription Trap: ROSCA, the Revived Click-to-Cancel Rule, and Dark Patterns Enforcement in 2026” on November 16 from 1:00 P.M. – 2:10 P.M. EST. The goal of the seminar is to provide practical guidance for businesses navigating subscription and auto-renewal compliance—the FTC’s most active enforcement front—from enrollment and billing disclosures to cancellation practices, dark patterns and class action risk. Participants will learn to apply ROSCA and state auto-renewal laws, structure free trials and cancellation flows that survive scrutiny, spot dark patterns, and audit enrollment, billing, and cancellation UX.

You can register for this webinar here.