Last updated: October 2025 (Philippine context). This is general information, not legal advice.

1) What counts as an “unauthorized online subscription charge”?

Unauthorized charges generally include:

Account takeover or card theft – someone used your card or e-wallet without consent.
Negative-option subscriptions – a “free trial” that converts to paid without clear, informed consent.
Dark patterns – hidden fees, pre-ticked boxes, or obstructed cancellation flows.
Billing errors – double-charges, wrong amount/currency, or continued billing after cancellation.
Child/minor purchases – charges made without the account holder’s consent.

Key Philippine laws and policies that typically apply:

Financial Consumer Protection Act (FCPA), R.A. 11765 – duties of banks/e-money issuers; complaint handling; restitution.
Consumer Act, R.A. 7394 – deceptive, unfair, or unconscionable sales acts or practices.
E-Commerce Act, R.A. 8792 – electronic contracts and records.
Data Privacy Act (DPA), R.A. 10173 – unlawful/unauthorized processing of personal data; remedies via the National Privacy Commission (NPC).
Internet Transactions Act (ITA), R.A. 11967 – consumer safeguards for online sellers, e-marketplaces, and e-retailers (phased implementation via IRR).
Cybercrime Prevention Act, R.A. 10175 – for computer-related fraud/access (if criminal activity is involved).

2) Act immediately: the “Golden Hour” checklist (first 24–48 hours)

Secure your accounts.
- Change passwords; enable multi-factor authentication.
- Freeze card via your bank app or call; for e-wallets, temporarily block.
Preserve evidence.
- Screenshots of the subscription page, checkout terms, cancellation attempts, emails/SMS, in-app receipts, timestamps, IP/device logs if available.
- Bank/e-wallet statements showing posting dates, merchant names, reference numbers.
Contact the merchant in writing.
- Ask for immediate cancellation, full refund, and a written confirmation with a ticket/reference ID.
- Give a clear, short deadline (e.g., 5 business days).
Notify your bank/e-money issuer (EMI).
- Report as fraud/unauthorized (not “dissatisfaction”).
- Request a chargeback/dispute and card reissuance to stop further debits.
File internal complaints quickly.
- Under the FCPA, BSP-supervised institutions must have accessible complaint channels and clear timelines for acknowledgment and resolution.
If you suspect a data/privacy breach, document why (e.g., card stored without consent) for possible NPC action.

3) Chargebacks with banks and e-money issuers

3.1 What is a chargeback?

A chargeback is a reversal of a card or e-wallet transaction initiated through your issuer under card-network/e-money rules when a transaction is unauthorized or erroneous.

3.2 Deadlines and timing

File as soon as possible. Issuers and networks apply strict windows (commonly within 30–120 days from posting date, sometimes shorter for recurring charges).
Each issuer sets internal cut-offs; late filings risk denial regardless of merits.

3.3 How to file

Provide, at minimum:

Filled dispute/chargeback form (issuer-provided).
Valid ID and the account owner’s signed statement denying authorization.
Statements showing the entries, plus merchant correspondence (refund refusal, cancellation proof).
For subscription dark patterns: screenshots of pre-checked boxes, unclear disclosures, impossible-to-find cancel button, or deceptive trial language.

3.4 What happens next

Provisional credit may be granted during investigation (issuer policy-dependent).
Issuer sends a chargeback to the merchant’s acquiring bank; the merchant can represent (defend) with evidence of consent (e.g., IP logs, 3-D Secure, checkbox audit).
If unresolved, the matter may escalate within the network’s dispute process (including arbitration rules).

3.5 Tips to improve your odds

Frame the reason correctly: fraud/unauthorized, not “buyer’s remorse.”
Recurring charges: show date of cancellation and proof the merchant kept billing after cancellation.
Cross-border merchants: expect longer timelines; still file immediately.
Virtual cards: if your bank offers merchant-locked or single-use cards, use them going forward to reduce exposure.

3.6 If your issuer denies the dispute

Request the written final response and the basis (reason code, evidence relied upon).
Escalate under the FCPA complaint ladder (see §6), and consider DTI (consumer protection) or NPC (privacy) depending on the issue.

4) DTI complaints (consumer protection angle)

When to go to DTI:

Deceptive or unfair online selling practices, negative-option billing, obstructive or impossible cancellation, refusal to honor clear cancellation/refund terms, or false/misleading advertising.

Who you can complain against:

The merchant, and under the ITA, certain online platforms/e-marketplaces/e-retailers may have duties to adopt measures against fraud or resolve complaints.

What to prepare:

Identification; contact details.
Narrative of facts (chronology).
Evidence bundle: screenshots, emails, receipts, terms, cancellation attempts, dispute filings with bank, and any ticket numbers.

Process (typical path):

Filing & docketing (online or in person).
Mediation/conciliation – quick resolution is common here.
Adjudication (if needed) – DTI may issue orders (e.g., refund), impose fines, or refer cases to prosecutors for criminal aspects under the Consumer Act.

Remedies:

Refunds, cancellation of future billings, administrative fines, and compliance orders.
Keep in mind DTI proceedings are administrative; they do not award moral/exemplary damages (that’s for courts), but their orders can compel merchant action.

5) NPC complaints (privacy/data angle)

When to consider NPC:

Your personal data (card details, email, phone) was processed without your valid consent, retained beyond stated purposes, shared to third parties improperly, or security safeguards failed causing unauthorized use.
Merchants storing or tokenizing your card without express consent, or platforms using dark patterns to obtain consent, may raise DPA issues.

Prerequisites and essentials:

Exhaust internal remedies with the personal information controller (merchant/platform) when reasonable, or explain why immediate NPC action is necessary (e.g., risk of continuing harm).
Prepare: complaint affidavit, ID, evidence of unauthorized processing, copies of correspondence, and a clear relief sought (erasure of data, cessation of processing, breach notification, etc.).

Possible outcomes:

Compliance orders, directions to delete data, improve security, and administrative fines under the DPA (as amended).
NPC actions complement (not replace) chargebacks or DTI remedies.

6) The escalation ladder (financial services)

Issuer/EMI internal complaint under the FCPA – get reference number and written decision.
If unresolved or unsatisfactory: elevate to the Bangko Sentral ng Pilipinas (BSP) consumer assistance channel (for banks, EMIs, and other BSP-supervised institutions).
If still unresolved: consider amicable settlement, mediation, or court action for damages/ injunctive relief, as appropriate.

Note: Keep all acks/decisions; they are crucial if you later pursue DTI, NPC, or civil claims.

7) Special situations

Free trials that converted to paid: If disclosures were unclear or cancellation was unreasonably hard, argue unfair or deceptive practice (DTI) and invalid consent (NPC) in parallel with a chargeback for unauthorized/continued billing.
Child/minor purchases: Provide proof of minority and lack of parental consent; request issuer to treat as unauthorized and the merchant to void ongoing subscriptions.
Corporate cards: Follow your company’s policy first; issuers still allow chargebacks, but the cardholder may need the company’s authorization to file.
iOS/Google/app-store subscriptions: Use the platform’s in-app refund/cancellation path and file with your issuer; attach the platform’s decision to your evidence.
Merchant insists on “non-refundable” terms: Consumer protection and chargeback rights can override unfair contract terms; unconscionable provisions are not enforceable.

8) Evidence that wins cases

Clear timeline: sign-up (if any), trial start/end, cancellation attempts, first billing, subsequent billings, dispute dates.
Screenshots of terms at the time of sign-up (archive emails or cache where possible).
Server/platform logs (IP, device, 3-D Secure challenge status) if provided, and why they don’t prove consent (e.g., compromised device).
Proof of cancellation: confirmation emails, ticket IDs, chat transcripts.
Loss mitigation: steps you took to stop further charges (card freeze, new card issued).

9) Templates (use and adapt)

9.1 Bank/EMI dispute letter (summary to attach to your form)

Subject: Dispute of Unauthorized Subscription Charges – [Your Name], [Last 4 digits] I dispute the following transactions as unauthorized:

[Date] – [Merchant Name] – [Amount] – Ref: [XXXX] Facts: I did not authorize this subscription/charge. On [dates], I requested cancellation and refund (tickets: [IDs]). The merchant continued to bill me. I have secured my account and request chargeback, cancellation of future debits, and card reissuance. Evidence attached: [list]. I declare under oath that I did not authorize these charges.

9.2 DTI complaint narrative (outline)

Parties; platform used; jurisdictional facts (transaction with PH consumer).
Chronology with exhibits (A-Z).
Violations invoked: deceptive/unfair practice under the Consumer Act; duties under the ITA.
Relief: refund, cancellation, administrative penalties, undertaking to cease dark patterns.

9.3 NPC complaint (privacy angle)

Identify the personal information controller and processing involved (e.g., storing card without consent; sharing to a payment processor without proper notice).
State harm (financial loss, risk of identity theft), steps taken, and relief: erasure, restriction of processing, security measures, notification, and administrative fines.

10) Preventing recurrence

Use virtual cards or spending caps; disable “merchant-initiated transactions” when not needed.
Avoid storing card details on merchant sites; opt out of “remember me.”
For trials, set calendar reminders 2–3 days before renewal.
Regularly review statements; enable real-time alerts.
Educate household members (including minors) and use device purchase restrictions.

11) Quick FAQ

Q: Can I get my money back if I forgot to cancel a free trial? A: If disclosures were clear and you simply forgot, recovery is harder. Still try: some merchants offer courtesy refunds; otherwise ask your issuer if a recurring-billing dispute is available. If disclosures were misleading, pursue DTI and chargeback.

Q: The merchant is overseas. Do DTI/NPC still help? A: Yes, you can still complain; enforcement against foreign entities can be complex, but issuer chargebacks and platform-level remedies are often effective.

Q: The issuer says the transaction was 3-D Secure (OTP). Am I stuck? A: Not necessarily. OTP use is evidence of authentication, not conclusive consent. Show why it’s unreliable here (SIM-swap, malware, phishing, compromised device), and escalate under the FCPA if the bank’s decision is unreasonable.

12) Practical timeline (example)

Day 0–1: Secure accounts; contact merchant; file issuer dispute; freeze/reissue card.
Week 1–2: Merchant response/chargeback acknowledgment; gather more evidence.
Week 3–8: Issuer investigation; potential provisional credit; monitor for representment.
Week 8+: If denied or unresolved, escalate to BSP (FCPA); parallel DTI or NPC filings as applicable.

13) Document checklist (print this)

Government ID
Dispute form + cover letter
Statements with marked entries
Screenshots of terms, checkout, and cancellation
Merchant tickets/emails/chats
Proof of card freeze/reissue
Timeline of events (1–2 pages)
Any police blotter (for clear fraud), if applicable

Bottom line

Move fast, document everything, and choose multiple tracks: (a) chargeback through your issuer; (b) DTI for unfair/deceptive practices; and (c) NPC where consent or data processing is defective. The combination typically delivers the quickest cancellation of future billings and the best chance at a refund.