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Amex C28 - Cancelled Recurring Billing

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TL;DR

The cardholder says they cancelled. You kept billing. That's a C28. Your defense is one of two things. Either you never got a cancellation request, or the charge landed before it did. You'll need consent documentation, cancellation logs and usage records. You've got 20 calendar days to respond. Strong consent and usage evidence help your case.

Got this code?​

Your deadline: Amex gives you 20 calendar days, and the date on your notice wins.

The claim: You billed a subscriber who says they'd already cancelled. Amex calls that C28.

Records that answer it:

  1. Cancellation records: did a cancellation request reach you?
  2. Billing dates: was this charge before or after the cancellation?
  3. Usage logs: did the cardholder keep using the service?
  4. Consent records: terms, signup confirmation and billing notices

Next: Decide whether it's worth fighting, then fill in the response outline for this claim and follow the Representment Workflow.

Overview​

Amex files C28 when a cardholder disputes a recurring charge. They're saying they already cancelled the subscription, membership or billing arrangement. The code covers subscriptions, memberships, automatic renewals, and any repeating charge that should have stopped. It's one of the fastest-growing categories as subscription commerce grows.

When This Code Applies​

  • Subscription cancelled but charges continue
  • Free trial converted to paid without clear consent
  • Recurring billing after account closure
  • Automatic renewal without proper notice
  • Charge processed after explicit cancellation request
  • Membership fees after cancellation

Cardholder Requirements​

Before Amex files a C28, the cardholder should:

  1. Have attempted to cancel - Through the merchant's cancellation process
  2. Allow reasonable processing time - For cancellation to take effect
  3. Retain proof of cancellation - Confirmation emails, reference numbers
  4. The transaction must be recurring - Not a one-time charge

Time Frames​

20-Day Response Window

You've got 20 calendar days to respond to a C28. Each disputed charge can be filed separately. One unhappy subscriber can trigger several chargebacks.

ScenarioDispute Window
Standard recurring chargeExceptions apply; confirm the applicable filing window
Each chargeCan dispute each billing cycle separately
Free trial conversionExceptions apply; confirm the applicable filing window
StageWindow
Inquiry response20 calendar days
Chargeback response20 calendar days
Documentation requestUse the reply-by date; get it from your acquirer in writing if unclear

Representment Options​

1. No Cancellation Request Received​

When to use: You've got no record of a cancellation request.

Evidence required:

  • Cancellation policy and process documentation
  • Communication logs showing no cancellation request
  • Account history showing active status throughout
  • Available cancellation channels (showing they were accessible)

2. Transaction Occurred Before Cancellation​

When to use: The disputed charge was processed before the cancellation request.

Evidence required:

  • Cancellation request date and timestamp
  • Transaction date and timestamp
  • Billing cycle terms showing charge was properly timed
  • Terms and conditions specifying billing schedule

3. Terms Allow the Charge​

When to use: Your terms clearly disclose post-cancellation or renewal charges.

Evidence required:

  • Signed or accepted terms and conditions
  • Specific language about cancellation timing and billing cycles
  • Proof cardholder agreed to terms at signup
  • Renewal notice sent before charge (if applicable)

4. Cardholder Continued Using the Service​

When to use: Usage logs prove the cardholder accessed the service after the alleged cancellation.

Evidence required:

  • Login and access logs after cancellation date
  • Feature usage records
  • Content consumption data
  • Account activity history
Usage Logs Are Powerful Evidence

Show the cardholder logging in after they claim they cancelled. That's the strongest version of this case. Log everything.

5. Refund Already Issued​

When to use: You've already credited the disputed charge.

Evidence required:

  • Refund transaction details (date, amount, reference)
  • Refund confirmation sent to cardholder
  • Proof refund was processed to the same card

6. Valid Free Trial Conversion​

When to use: Cardholder signed up for a free trial that converted to paid per disclosed terms.

Evidence required:

  • Trial terms clearly showing conversion date and amount
  • Proof cardholder agreed to trial terms
  • Conversion notice sent before first charge
  • Opt-out option provided and accessible

Required Documentation​

Evidence TypeStrength
No cancellation record + continued usageStrong
Transaction before cancellation requestStrong
Accepted terms + cancellation policyMedium-Strong
Conversion notice sent for trialMedium
No documentation of consentVery Weak

Which defenses hold up​

ScenarioWhat it shows
No cancellation record + usage logsNo request recorded; service use documented
Transaction before cancellation dateThe charge landed before cancellation
Clear terms + consent documentationThe customer agreed to the billing terms
Trial conversion with notice sentThe conversion notice was sent
No documentationNo records to support your defense

Track your own win rate by reason code.

Trial Conversions​

Best Practices​

  1. Clear trial terms - Duration, conversion date, post-trial price
  2. Conversion notice - Email 7+ days before first paid charge
  3. Opt-out option - Easy to cancel before conversion
  4. Confirmation at conversion - Receipt email when paid billing starts
  5. Explicit consent - For the transition from free to paid

Common Trial Issues​

IssuePrevention
No conversion notice sentAutomated email 7 days before charge
Surprise charge amountClear pricing at trial signup
Hidden billing termsTerms displayed prominently at checkout
Difficult cancellationSelf-service cancel in account settings
No trial end reminderEmail 3 days before trial expires

Common Mistakes​

  1. No cancellation logs - You can't prove you never got a request
  2. Making cancellation difficult - Drives chargebacks and regulatory risk
  3. No pre-billing notifications - They don't see the charge coming
  4. Poor terms display - You can't prove informed consent
  5. Ignoring Amex inquiries - It'll auto-escalate to a chargeback
  6. Billing after cancellation - Even one extra charge triggers a dispute
  7. No usage logging - You can't prove continued service access
  • C02 - Credit Not Processed
  • C05 - Goods/Services Cancelled
  • C08 - Goods/Services Not Received
  • C31 - Goods/Services Not as Described

Prevention Strategies​

  1. Explicit opt-in - No pre-checked boxes or hidden consent
  2. Display terms prominently - Before purchase, not buried in fine print
  3. State amount and frequency clearly - "$19.99/month billed on the 1st"
  4. Explain cancellation process - How, where, and by when
  5. Send confirmation email - With all terms immediately after signup

Pre-Billing Notifications​

  1. Send reminders 7+ days before each charge - Upcoming billing notice
  2. Include the amount - The exact charge they'll see
  3. Include the date - When the charge will process
  4. Provide a cancellation link - One-click path to cancel
  5. Include contact information - Phone, email, chat options
Pre-Billing Notices Prevent Chargebacks

Merchants who send pre-billing reminders see C28 rates drop 30-50%. A $0.02 email is cheaper than a $15 chargeback fee. It's cheaper again than the sale you lose with it.

Easy Cancellation​

  1. Same channel as signup - If they signed up online, let them cancel online
  2. Self-service cancellation - Account portal with cancel button
  3. Process immediately - Don't delay or require multiple steps
  4. Send confirmation - Cancellation receipt with effective date
  5. No dark patterns - Don't make cancellation deliberately difficult

Documentation and Logging​

  1. Log all communications - Every email, call, chat, and support ticket
  2. Record consent with timestamps - When and how they agreed
  3. Track all cancellation requests - With confirmation records
  4. Maintain detailed usage logs - Login times, feature usage, content access
  5. Archive billing records - Every charge with corresponding service period

Next Steps​

Prevent future C28 chargebacks:

  1. Make cancellation as easy as signup
  2. Send pre-billing reminders 7+ days before each charge
  3. Review subscription compliance
  4. Set up dispute alerts to refund before chargeback

See Also​

Something wrong on this page? Email matt at paymentsandrisk.com and say what needs fixing.