Amex C28 — Cancelled Recurring Billing: What It Is and How to Respond

⚠️ 20-Day Deadline: American Express gives you only 20 calendar days to respond — shorter than Visa (30 days) or Mastercard (45 days). Act within 48 hours of receiving notification.

Amex C28 is filed when a cardholder claims they cancelled a recurring billing arrangement — a subscription, membership, or any recurring charge — but were billed again after the cancellation. It is Amex’s equivalent of Visa 13.2. Like 13.2, the dispute turns on a single question: is there a valid cancellation request in your records that predates the disputed charge?

C28 disputes have a fundamentally different evidentiary landscape than fraud disputes (like F29). There is no authentication shortcut — 3DS won’t help here. Your cancellation log is your entire case. If your records show no cancellation request before the disputed charge, you can fight. If there is any cancellation communication — even an informal email — that predates the charge, you should accept and issue a refund.

Common reasons you received this dispute

1Customer cancelled via your online portal but the cancellation didn't process correctly
2Customer contacted support to cancel but support didn't update the subscription system
3Customer cancelled through the App Store or a third-party platform, but your system wasn't updated
4Customer disputes the charge from a free trial that converted to paid without sufficient advance notice
5Customer forgot to cancel before a renewal and is now claiming they had cancelled earlier

Can you win this dispute?

Fight this dispute if...

✓Your subscription system has no record of any cancellation request before the disputed charge
✓The cardholder's claimed cancellation date is after the billing date that generated this charge
✓You can show the service was accessed or used after the claimed cancellation date

Accept this chargeback if...

✗Any cancellation communication exists — email, support ticket, portal submission — before the billing date
✗The customer cancelled through a third-party platform and that platform confirms it

Evidence checklist

✓️ Required
Complete cancellation log export for this account: Showing no request received before the charge date. The absence of a cancellation request is your primary evidence.
✓️ Required
Subscription agreement accepted at signup: Including billing schedule and cancellation policy. This establishes what the cardholder agreed to.
✓️ Required
Full billing history: Showing the disputed charge was within an active subscription period. Demonstrates the charge was legitimate under the agreed billing schedule.
⭐ Strongly recommended
Account activity log: Login history and usage records showing the subscription was active and the account was used after the date the cardholder claims to have cancelled.
◯ If available
Third-party platform records: App Store, Google Play, or PayPal records confirming no cancellation was logged before the disputed charge.

How to write your response

Your response must directly address whether a cancellation was received before the disputed charge. State clearly that your system has no cancellation record, and reference your exhibits systematically.

“We are writing to dispute Amex chargeback [reference] under reason code C28. Our subscription management system has no record of a cancellation request from this account prior to [charge date]. Exhibit A is the complete cancellation log for account [id], showing no request was received before the billing date. Exhibit B is the subscription agreement accepted at signup, including billing schedule and cancellation policy. Exhibit C shows the account’s usage activity through [date], demonstrating the subscription was active. We respectfully request reversal of this chargeback.”

Key deadlines

Response window: 20 calendar days from the notification date. Set up your dispute notifications immediately — for Amex, by the time you see the notification, you may already have lost a week.

Unlike fraud disputes, there is no authentication shortcut for C28 — your cancellation records are everything.

Retain subscription and cancellation records for a minimum of 18 months to cover potential disputes.

How to prevent this chargeback

1
Log every cancellation request immediately: Emails, support tickets, portal submissions, and third-party platform webhooks must all feed into a single cancellation record with timestamps. The absence of a logged cancellation is your primary defence.
2
Send advance renewal reminders: For annual subscriptions (14–30 days before) and trial-to-paid conversions (7 days before). These reduce disputes from customers who forgot they were still subscribed.
3
Integrate App Store, Google Play, and PayPal cancellation webhooks: With your subscription system to prevent cancellation blind spots. Cancellations made through these channels that don’t reach your system are a common source of C28 disputes.
4
Make cancellation as easy as signup: A single online cancellation button reduces disputes and regulatory risk. Complex cancellation processes generate disputes and attract regulatory attention in most jurisdictions.

Frequently asked questions

What is Amex C28?

Amex C28 is Amex's equivalent of Visa 13.2 — it's filed when a cardholder claims they cancelled a recurring subscription but were charged again after the cancellation. The dispute turns on whether a valid cancellation was received before the disputed charge.

Can I win C28 if I have no cancellation record?

Yes, if no cancellation request is in your system, your log showing its absence is your primary evidence. Pair this with the subscription agreement, billing history, and usage logs to demonstrate the account was active and the charge was legitimate.

How is Amex C28 different from Visa 13.2?

The content and structure of the dispute are essentially identical. The critical practical difference is the response window: Amex gives you 20 days vs Visa's 30 days. C28 disputes must be actioned faster. The evidence requirements are the same: cancellation log, subscription agreement, billing history, and usage data.

What if the customer cancelled through the App Store but not through my app?

App Store cancellations are valid cancellations. If the App Store confirms the subscription was cancelled before your billing date, accept the chargeback. To prevent this scenario, set up App Store Server Notifications (and the Google Play equivalent) to automatically sync App Store cancellations to your subscription system.

Related reason codes

Visa 13.2

Cancelled Recurring

Discover AP

Cancelled Recurring

Amex C05

Goods / Services Cancelled

Dealing with an Amex C28 chargeback?

You have 20 days. Generate a winning dispute response in minutes, or let ChargeMate handle it for you.

Generate my dispute response →Let ChargeMate handle this for me →

3 free generations included · No credit card required