Substitution Days Counter Serious Error

Full rules for penalties must be provided. The substitution penalty rules are in conflict with each other.
Update for 03/07/2020: Acct 3 exist days = 36; active sub days = *39*. Again, how is this possible?
Again, you fail to answer. The substitution penalty algorithm apparently charges an account for a full day of substitution activity for each instance of substitution activity even if the activity lasts for only a few minutes, and apparently charges another full day of sub activity if the account has the sub cancelled and then reinstated and used again the same day. This idiocy must be corrected.
Yes, the game developers do not readily share their algorithm formulas, but many have leaked out. Hopefully, the substitution penalty formula will also leak out so we can see just how incompetent some of the game developers really are. They apparently write software algorithms that are not tested to see if they can produce unexpected results.
The Origin promise was that the substitution penalty would not be incurred if a sub account was not *actively* subbed more than 50% of the time the account was in existence. But, then the counting algorithm was (inadvertently?) set up to ignore activity *time* altogether and instead to consider only the number of times an account was subbed, thus counting each time as a new day. Is there any other way to get more active sub days than actual account existence days? The 50% of time rule must count actual time, and not instances of activity.

Original Post:
I have 3 accounts in each of 3 worlds. I use substitution continuously, rarely turning it off on worlds where there is no substitution penalty, to quickly switch between accounts from the very first day the accounts are opened. Thus, the "exist" and "active" days should be nearly the same on these worlds. On a 3rd world, there is a substitution restriction and I use substitution very sparingly. The Substitution Days Counter appears to be inaccurately logging active substitution days on all 3 worlds:
1. World 90 West Coast - no substitution restrictions - as of 03/03/2020
Acct 1 exist days = 2,206; active sub days = 0 (primary account which accepts subs from alt accounts)
Acct 2 exits days = 2,136; active sub days = 1,716 (low since this alt acct has been subbed from the start)
Acct 3 exist days = 2,135; active sub days = 916 (ridiculously low since this acct has also been continuously subbed from the start)
2. Wrath 23 - no substitution restrictions - as of 03/03/2020
Acct 1 exist days = 534; active sub days = 0 (primary account which accepts subs from alt accounts)
Acct 2 exist days = 533; active sub days = 128 (low since this alt acct has been subbed regularly, mostly continuously, from the start)
Acct 3 exist days = 533; active sub days = 32 (ridiculously low since this alt acct has also been subbed regularly, mostly continuously, from the start))
3. Tiberian 43 - severe substitution restrictions - as of 03/03/2020
Acct 1 exist days = 32; active sub days = 0 (primary account which accepts subs from alt accounts)
Acct 2 exist days = 32; active sub days = 1 (low since this alt acct was subbed regularly, sometimes continuously, for the first couple weeks of its existence)
Acct 3 exist days = 32; active sub days = 33 (yes *33* sub days for this alt acct that has been in existence for only 32 days!!!) This is an egregious error. This account was *not* subbed for a full 2 weeks of its existence, so how can the active sub days be greater than the number of days the acct has been in existence. I know Origin records account activity, so check this and you will see that I am right.
On Tiberian 43, I got a sub violation warning shortly after the 2nd week of activity because I had been subbing accts 2 and 3 dally, but not continuously. I only activated the subs when I was online and upgrading or farming. There is no way I could have accumulated more sub days than days of actual account existence!! What are you doing? Counting as a sub day each time I login and actively sub an alt acct? I sometimes do this 2 or 3 times a day. Does each time count as a whole active sub day even if I am subbing for only an hour at a time? The key word here seems to be *active*, as in online and actively using a sub account from a primary account. I am online only a few hours a day, so to accumulate a full day of active subbing would take me several days. You seem to be charging me a full day of active subbing when in fact, it is only a few hours at most.
Origin needs to tell us *all* the sub rules including how you add up charges to the active sub days, and how the 50% rule is actually applied. There is clearly something really screwy going on here and it seems to me that all players are being cheated. Poorly defined and implemented rules are as bad as poorly written laws. Please explain all the details of the substitution rules and how you determine when a violation has occurred. Of course, there is no way to explain how active sub days could ever exceed the days an account has been in existence, so I am really interested to hear how you managed to do this.

Tiberian 43 Update for 03/05/2020
Acct 3 exist days = 34; active sub days = *36*. I subbed this acct for only 4 hrs on 03/04/2020 (and 0 hrs for the 2 weeks before this) and the active sub days jumped from 33 to 36. This is wrong. How can active sub days be greater than the days the acct has existed? How can 4 sub hours cause the active sub days counter to increase by 3 days? Fix this problem. The best fix is to END the substitution penalty, NOW.

Have you ended the substitution every time? There are no other players substituting on the account?

Yes, I ended all substitutions at the same time, most of the time. My thinking is that if the prime acct that is holding the subs is not active, then the subs are not active and just holding a sub, but not using it, should not be time charged to the sub acct. So, in the first week TIberian 43 was open, I did allow the prime to hold subs continuously and did not pay attention to the active sub counters. Only after getting a sub violation in week 2 did I begin to realize that inactive time (off-line time) was apparently being charged as active sub time. This is not right. Off-line time is NOT active time, period. After week 2, I stopped using subs entirely until my sub violation penalty ended and then I carefully made sure I ended each sub properly every day so that my sub time should not amount to more than a few hours per day.
Why have you not explained how any player can accumulate more active sub days than exist days? How is this possible?
Where are the full rules for substitutions clearly spelled out?
No other player uses any of my subs. I am online daily and do not need anyone else to collect credits for me.

Full rules for any activity in the game have never been revealed. They don't share the formula for many, many things.

Substitution time is counted from the point on where the substitute accepts the offer, whether they log in and play or not is second nature.
Have other players also been substituting on that account? That might indicate the faulty counter. OR do you manage substitutions via script?
Anyway, we are looking into this for 20.2

No one else has subbed any of my accounts and I do not manage my subs via scripts. I have 3 active accounts and I use #1 to manage #2 and #3.
So, you define "active" as any time a sub has been accepted and is "available" to be played, whether or not the player who accepted the sub is actually logged into the sub account and is actively using it. That can account for the exorbitant amount of time charged to my subbed account #3, but it does not explain how the active sub days can exceed the account exist days. I don't like how you define "active", because you are counting dormant time, but you are the gods of this game and my only alternatives are to take the thou$and$ I invest in every world I play on and go find something else to do, or bite my tongue and keep playing until I can't stand it any more.
Thank you for looking into the counter issue. It really is broken.

Update for 03/15/2020: Acct 3 exist days = 44; active sub days = *48*.
It has been 8 days since my last update, and I did not sub Acct 3 for 5 of those days (and neither did any one else), and I did not mistakenly leave the sub "accepted" by my primary Acct 1, which is the only account I use to accept subs. But *surprise*: the active sub days increased by 9 days. The sub was accepted and active on 3 days and for only a few hours per day, then the sub was cancelled until the next time it was needed. Again, how is it possible to sub an account 3 times in 8 days and have that account get charged for 9 "active" sub days? ! ? ! Your accounting scheme is hopelessly broken.
I bet i am being double counted if I log on with an active sub twice in a single day, and probably also being double counted if my active sub logon time goes from 11 PM to 1 AM. You should also check to see if I am double counted if I accept a sub, mistakenly reject it, and then accept it again in the same log on session.
Once again I ask you to reconsider charging acceptance of a sub as an active sub day even if the sub account is never logged into. A sub account is not "active" until the account is actually logged into!!

I think there is a difference between 'Active' as you understand it and the more accurate 'Activated'.

If something is activated it doesn't become 'not activated' because it is not used. Think of gym membership (or any other membership). You activate it when you sign the forms and hand over your money at which point it is activated. It then remains activated until the duration of the membership runs out, or some act of suspension takes place. Leaving the gym doesn't deactivate your membership so a one year membership is from day one for 365 days continuously, not 365 days of membership visits with a break for your vacations etc..

It seems that they are using the term 'Active' when it should be 'Activated'.