The Federal Trade Commission (FTC) has filed a lawsuit against Uber Technologies, Inc. and Uber USA, LLC, alleging the companies engaged in deceptive billing and cancellation practices tied to their Uber One subscription service. The complaint, filed in the U.S. District Court for the Northern District of California, accuses Uber of enrolling consumers without their consent, misrepresenting promised savings, prematurely charging users, and making it extraordinarily difficult to cancel the recurring service.

Uber One offers users benefits like discounts on rides and food deliveries for $9.99 per month or $96 annually. However, according to the FTC’s complaint, Uber misled consumers by promoting “$25 in monthly savings” without accounting for the subscription fee itself, and falsely advertising that consumers could “cancel anytime” without penalty.

Instead, the FTC alleges that canceling Uber One requires users to navigate a labyrinth of as many as 23 screens and complete 32 actions, particularly difficult within 48 hours of renewal when the cancellation option reportedly disappears. In some cases, consumers were charged even after requesting cancellation, with some forced to cancel their payment methods to stop the billing. The agency also noted Uber often charged consumers before their advertised billing dates — even during free trial periods — in violation of its own stated terms.

The FTC’s complaint cites violations of Section 5 of the FTC Act, which prohibits unfair and deceptive acts, and the Restore Online Shoppers’ Confidence Act (ROSCA), which governs online subscriptions and requires clear disclosures, affirmative consent, and simple cancellation mechanisms.

FTC Chairman Andrew N. Ferguson emphasized the broader implications of the case, stating, “Americans are tired of getting signed up for unwanted subscriptions that seem impossible to cancel. The Trump-Vance FTC is fighting back on behalf of the American people.”

The Commission voted 2-0-1 to authorize the filing, with Commissioner Mark R. Meador recused. The case will now proceed through the court system.

INSIDER TAKE

While not the first enforcement action of its kind, the lawsuit against Uber reflects the FTC’s increasing willingness to challenge major companies over misleading subscription tactics and obstructive cancellation flows.

Subscription businesses across industries should take note: the FTC is clearly signaling that “dark patterns” — such as burying cancellation options or making it harder to quit than to join — will not be tolerated.

Of particular concern is the Commission’s explicit tying of the complaint to violations of ROSCA, a law that has often been underused but is now becoming a potent tool against subscription abuses. Companies operating subscription models online must ensure:

• Clear and conspicuous disclosures before enrolling customers
• Affirmative, express consent to charges
• A straightforward and frictionless cancellation process

The allegations around Uber’s 48-hour billing window and obstacles to cancellation are also instructive. Even technical timing tricks — such as charging before the end of a free trial or renewal date — may expose companies to regulatory action if consumers are not fully informed and empowered to cancel easily.

The case is likely to have ripple effects across the subscription economy, particularly as the FTC simultaneously pursues its new “Click-to-Cancel” rulemaking initiative aimed at simplifying subscription cancellations industry-wide.

Subscription executives would be wise to proactively review their enrollment and cancellation flows now, before facing similar scrutiny.