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Before you start a SaaS free trial, find the cancel button first
Most SaaS shopping starts with a free trial, and the part people skip is how the trial ends. This post covers what the US Federal Trade Commission says about trials that turn into paid plans, where the rules stand per its March 2026 notice, and a checklist to run before you enter a card.
What the FTC calls it
The FTC uses the term "negative option" for any sales term where a seller treats your silence, or your failure to act, as accepting an offer. In its March 2026 notice, published in the Federal Register, it lists four kinds: prenotification plans, continuity plans, automatic renewals, and free-to-pay or nominal-fee-to-pay conversions, where you get something free or cheap for a trial and are then charged unless you cancel. That last kind is the familiar SaaS trial.
Where the rules stand
The same notice says that in October 2024 the FTC amended its Negative Option Rule, and that on July 8, 2025 the Eighth Circuit vacated the amendments, holding that the FTC had not done a required preliminary regulatory analysis. The FTC says the remaining rule covers only prenotification plans. It also says it still relies on other law: Section 5 of the FTC Act, and the Restore Online Shoppers' Confidence Act (ROSCA), which applies to internet sales.
According to the FTC, ROSCA bars charging consumers through a negative option feature online unless the seller clearly discloses all material terms before getting billing information, gets express informed consent before charging, and provides simple ways to stop recurring charges. The FTC adds that complaints about negative option marketing rose from at least 33 per day in late 2020 to more than 90 per day in 2025.
In March 2026 the FTC asked the public for comment on whether to amend its rule again. Comments were due April 13, 2026. We did not verify anything that happened after that notice, so check ftc.gov for the current status. This is not legal advice.
A checklist before you enter a card
These steps are our suggestions, built around the disclosures the FTC says sellers should make.
- Find the price after the trial. The amount and the date it starts should be stated before you give a card number.
- Find the cancel path now. Open the help or billing docs before signing up. Notion's pricing page, for example, says you cancel under Settings, then Billing, then Change plan, and keep paid features until the end of the billing cycle.
- Read the refund terms. Notion's page says it will refund in full if you downgrade within three days of signing up for monthly billing, or 30 days for annual billing. Policies differ by tool, so read each one.
- Prefer no-card starts when they fit. Systeme.io's pricing page says its free plan does not require a credit card. That removes the trial-conversion question, though you still need to read the plan limits.
- Screenshot the offer (price, trial length, cancel steps) and set a reminder before the trial ends.
Sources
- Rule Concerning the Use of Prenotification Negative Option Plans (advance notice of proposed rulemaking), Federal Register, March 13, 2026
- Notion pricing (read October 4, 2026)
- Systeme.io pricing (read October 4, 2026; page says last updated April 2026)