Machine unlearning, the process of selectively removing data from trained models, is increasingly crucial for addressing privacy concerns and knowledge gaps post-deployment. Despite this importance, existing approaches are often heuristic and lack formal guarantees. In this paper, we analyze the fundamental utility, time, and space complexity trade-offs of approximate unlearning, providing rigorous certification analogous to differential privacy. For in-distribution forget data—data similar to the retain set—we show that a surprisingly simple and general procedure, empirical risk minimization with output perturbation, achieves tight unlearning-utility-complexity trade-offs, addressing a previous theoretical gap on the separation from unlearning for free" via differential privacy, which inherently facilitates the removal of such data. However, such techniques fail with out-of-distribution forget data—data significantly different from the retain set—where unlearning time complexity can exceed that of retraining, even for a single sample. To address this, we propose a new robust and noisy gradient descent variant that provably amortizes unlearning time complexity without compromising utility.