Amex's cancelled-recurring code, decided on when the cancellation request landed and what the merchant did with it.
C28 is Amex's parallel to Visa 13.2 (cancelled recurring transaction) and the cancelled-recurring condition of Mastercard 4853. The Amex response window is the tightest of the three: 20 days from notification, against 30 for Visa and 45 for Mastercard. A merchant on multiple networks who handles a Visa 13.2 toward the comfortable end of its window will miss the C28 deadline on the same case, so the first calendar item for any C28 is the response date.
How the dispute actually arrives
A C28 typically arrives within a month or two of the disputed renewal. The cardmember sees a charge for a subscription they thought they cancelled and files with Amex directly. The notification cites the disputed renewal date and amount. The 20-day clock starts on the day of the notification.
Amex disputes are operationally different from Visa and Mastercard in that Amex is both the issuer and the network. There is no separate issuing bank reviewing the rebuttal; Amex's own dispute team reads the response, which means the merchant is arguing to Amex itself, not to a third-party issuer applying network rules. Amex tends to apply slightly stricter cancellation-clarity standards than the third-party issuers reviewing Visa 13.2 disputes, particularly around how visible the cancellation path was at sign-up.
What the issuer is looking for
Amex reviewing a C28 asks the same three questions a Visa or Mastercard issuer would on a parallel dispute. Did the cardmember consent to recurring billing at sign-up. Did the merchant provide a clear and accessible cancellation path. Did the cardmember use that path before the disputed renewal.
The original consent is the foundation. A click-through record showing the cardmember agreed to a specific cadence and price at sign-up is the centerpiece. Where the consent is implicit or buried in terms the cardmember did not have to read, Amex takes the cardmember's account seriously.
The cancellation path is the second piece. Amex expects merchants to offer a cancellation path that is at least as accessible as the sign-up path. A subscription that signs up in one click and cancels only by phone during business hours does not pass this test, and Amex tends to side with the cardmember in those cases.
The cardmember's use of the path is the third piece. The merchant's cancellation log shows whether the cardmember submitted a request through the documented path. Where the log is empty and the documented path was reasonable and accessible, the merchant has a defensible case. Where the cardmember claims to have cancelled by an undocumented method (a support chat, an email to a general address, a phone call) and the merchant has no corresponding record, Amex often gives the cardmember the benefit of the doubt.
Usage records add weight. A cardmember claiming they cancelled a SaaS subscription before the renewal, where the platform's audit log shows continued logins through and past the renewal date, is making a difficult case.
Common scenarios merchants see
A subscription the cardmember believed they cancelled. The defense is the documented cancellation path and the absence of a cancellation request through that path before the disputed renewal.
A free trial that converted to a paid plan. The strongest position is a checkout flow that required the cardmember to acknowledge the trial-to-paid conversion explicitly, with the conversion date and amount stated. The weakest is a buried disclosure in the terms.
A cancellation request the cardmember claims to have sent. If the merchant operates a documented cancellation portal and the cardmember used a different channel, the defense rests on the reasonableness of the documented portal. Amex applies tighter standards on this question than other networks.
A renewal billed at a higher rate than originally agreed. If the rate change was disclosed in advance and the cardmember did not cancel, the merchant is generally protected. If the rate change was buried or not disclosed, the renewal is reversible.
What this code is not
Reason code C28 is not a fraud claim. If the cardmember says the original signup was unauthorized, the dispute belongs under Amex F24 (no cardmember authorization). It is also not a non-receipt or quality claim; those belong under the C08 and other C-series codes.
Where this fits in our service
Amex reason code C28 is a code we draft rebuttal letters against where the merchant has the original consent record, a documented cancellation path, and a clean cancellation log. The 20-day response window means we prioritize C28 cases when they arrive. If you are reading this because you just received one, you can start with a free first letter.
Official source: Amex rules. Last reviewed 2026-05-11.