Skip to main content

Amex C28 - Cancelled Recurring Billing

On this page
TL;DR

C28 is filed when an Amex cardholder says they cancelled a recurring subscription or membership but charges continued. Your defense depends on proving you never received a cancellation request or that the charge occurred before the cancellation. You need clear consent documentation, cancellation logs, and usage records. Response window is 20 calendar days. Win rates with strong consent and usage evidence are 50-65%.

Overview​

Amex files C28 when a cardholder disputes a recurring charge, claiming they previously cancelled the subscription, membership, or recurring billing arrangement. This code covers subscription services, memberships, automatic renewals, and any repeating charge the cardholder says should have stopped. It is one of the fastest-growing chargeback categories as subscription commerce expands.

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 have 20 calendar days to respond to a C28 chargeback. Each disputed recurring charge can be filed separately, so one unhappy subscriber can trigger multiple chargebacks.

ScenarioDispute Window
Standard recurring charge120 days from disputed transaction date
Each chargeCan dispute each billing cycle separately
Free trial conversion120 days from first paid charge
StageWindow
Inquiry response20 calendar days
Chargeback response20 calendar days
Documentation request10 calendar days

Representment Options​

1. No Cancellation Request Received​

When to use: You have no record of the cardholder requesting cancellation.

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

If you can show the cardholder logged in and used the service after they claim to have cancelled, your representment case becomes significantly stronger. Log everything.

5. Refund Already Issued​

When to use: You already processed a credit for 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

Win Rate Expectations​

ScenarioExpected Win Rate
No cancellation record + usage logs55-70%
Transaction before cancellation date60-75%
Clear terms + consent documentation45-60%
Trial conversion with notice sent40-55%
No documentationUnder 20%

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 - Exact charge they will 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 chargeback rates drop by 30-50%. A $0.02 email is far cheaper than a $25-50 chargeback fee.

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 - Do not delay or require multiple steps
  4. Send confirmation - Cancellation receipt with effective date
  5. No dark patterns - Do not 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

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 - Cannot prove you never received a request
  2. Making cancellation difficult - Drives chargebacks and regulatory risk
  3. No pre-billing notifications - Charges surprise the cardholder
  4. Poor terms display - Cannot prove informed consent
  5. Ignoring Amex inquiries - Auto-escalates to chargeback
  6. Billing after cancellation - Even one extra charge triggers a dispute
  7. No usage logging - Cannot prove continued service access
  • C02 - Credit Not Processed
  • C05 - Goods/Services Cancelled
  • C08 - Goods/Services Not Received
  • C31 - Goods/Services Not as Described

Next Steps​

Got this chargeback?

  1. Check cancellation records --> Did you receive a cancellation request?
  2. Check billing dates --> Was the transaction before or after cancellation?
  3. Pull usage logs --> Did the cardholder continue using the service?
  4. Gather consent documentation --> Terms, signup confirmation, billing notices
  5. Respond within 20 days --> Representment Workflow

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​

Last updated on