Certified machine unlearning ensures the proximity between the unlearned model and a model retrained without the data to be forgotten. Extending this framework to sequential deletion requests, typically arriving as groups of variable size (e.g., all records of one user or of coordinated users), is challenging. For unlearning methods based on fine-tuning on the retain sets, this leads to either degrading performance or increasing computation as the number of unlearning requests grows. For independent successive requests, we instead certify each model release against a counterfactual unlearning trajectory in which the group being deleted never took part. With a fixed fine-tuning budget per deletion, we show that, for smooth strongly convex objectives, this approach keeps the performance loss bounded, uniformly in the number of requests. Experiments with multiclass logistic regression on FEMNIST show that the resulting algorithm needs fewer corrective steps than existing sequential methods and outperforms training-time differential privacy, particularly when group sizes are heterogeneous.

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