Click-to-Cancel Rule Vacated: Your Rights Now

The FTC's "click-to-cancel" rule is not in force: the US Court of Appeals for the Eighth Circuit vacated it on 8 July 2025, shortly before businesses would have had to comply with all of it, and as of October 2026 the FTC has only asked for public comment on whether to try again. You still have real protection when cancelling, though. A 2010 federal law (ROSCA) requires online sellers to offer a "simple" way to stop recurring charges, and states such as California and New York now require cancellation in the same way you signed up.

None of this is legal advice. It is a plain summary of what the primary sources say, with links so you can check them yourself.

What the 2024 rule would have required

"Click to cancel" is the nickname for the FTC's 2024 amendments to its Negative Option Rule. A "negative option" is any deal where your silence counts as a yes: free trials that convert to paid, subscriptions that auto-renew, plans that bill until you say stop.

The amended rule would have:

• Required cancellation to be as easy as sign-up, through the same medium you used to subscribe.
• Required clear disclosure of the price, renewal terms and how to cancel before taking payment.
• Required express consent to the recurring charge, separate from the rest of the deal.
• Applied to nearly all negative-option programs in every medium, not just product-of-the-month clubs.

What the court did, and why

On 8 July 2025, in Custom Communications, Inc. v. FTC, the Eighth Circuit granted the petitions for review and vacated the rule. The reason was procedural. An administrative law judge had found the rule's economic effect would pass $100 million a year, which triggers a requirement under the FTC Act for a "preliminary regulatory analysis". The FTC never issued one, so the court threw out the whole rule.

The court did not rule that hard-to-cancel subscriptions are legal. It ruled that the FTC skipped a required step when it wrote this rule.

What has happened since

• February 2026: the FTC formally restored the pre-2024 text of the rule "to conform" to the court's decision. That older rule covers only prenotification plans, the book-of-the-month model, not ordinary auto-renewing subscriptions.
• March 2026: the FTC published an advance notice of proposed rulemaking asking whether it should amend the rule again, including whether to bring back parts of the vacated 2024 version. Comments closed on 13 April 2026.
• Since then: we found no proposed rule from the FTC in the Federal Register through early October 2026. An advance notice is the earliest stage of rulemaking. It creates no obligations for businesses.

The federal law that does apply: ROSCA

The Restore Online Shoppers' Confidence Act (2010) makes it unlawful to charge you through an online negative-option deal unless the seller:

1. clearly discloses all material terms before taking your billing information,
2. gets your express informed consent before charging you, and
3. provides "simple mechanisms" for you to stop recurring charges.

The FTC enforces it. In September 2025 it announced a $2.5 billion settlement with Amazon over Prime enrolment and cancellation, brought under the FTC Act and ROSCA. Amazon agreed to pay a $1 billion civil penalty and $1.5 billion in refunds, and to offer an "easy way for consumers to cancel Prime, using the same method that consumers used to sign up."

ROSCA is not as specific as the vacated rule. It says "simple", not "same number of clicks". But it is in force, and it covers subscriptions bought online.

State laws that require online cancellation

California. AB 2863, enacted in September 2024 (Chapter 515, Statutes of 2024), amended California's Automatic Renewal Law for contracts entered into, amended or extended on or after 1 July 2025. It requires cancellation to be available in the same medium you used to sign up, express affirmative consent to the renewal terms, and an annual reminder of what you're paying and how to cancel. A business may make a discount offer when you try to leave, as long as you can still cancel.

New York. General Business Law § 527-a, amended in 2025, requires businesses to let you cancel through the same medium you used to consent, with a mechanism "as easy to use" as the sign-up. It also requires:

• Renewal notice for long terms: for a paid term of a year or more that renews for six months or more, notice 15 to 45 days before the cancellation deadline.
• Trial notice: for a free gift or trial longer than a month that turns into a charge, notice 3 to 21 days before the cancellation deadline.
• Price-change notice: notice of a price increase 5 business days to 30 days before it takes effect.

Other states have their own automatic renewal statutes. If you live elsewhere, search your state attorney general's site for "automatic renewal".

When a company won't let you go

• Cancel through the channel you signed up in. If you subscribed online, look for the online cancel path before calling. In California and New York the law requires one. Elsewhere, ROSCA requires a simple mechanism for online sign-ups.
• Keep evidence. Screenshot the confirmation page, keep the email, and note the date and any reference number.
• Dispute charges made after you cancelled. For credit cards, the CFPB says to send a written billing-error notice within 60 days after the charge appeared on your statement. If you need the money back for a renewal you simply forgot, our guide to getting a refund for an auto-renewal covers Apple, Google Play and merchants.
• Report it. You can report a company to the FTC at ReportFraud.ftc.gov or to your state attorney general.

For service-by-service steps, including phone-only lines and gyms, see how to cancel any subscription.

Where a tracker helps, and where it doesn't

The law decides how hard a company may make leaving. It does nothing about forgetting, and forgetting is how most unwanted renewals happen. In a 2022 C+R Research survey, 42% of respondents said they had stopped using a subscription but forgot they were still paying for it.

Subgrove is a manual subscription list that sends a push or email reminder before each renewal, so you can decide while cancelling is still free. It does not cancel anything for you, and it doesn't connect to your bank. If you aren't sure what you're paying for, start with finding forgotten subscriptions, then set reminders using cancel before the renewal, not after.

Frequently asked questions

Is the FTC click-to-cancel rule in effect? No. The Eighth Circuit vacated it on 8 July 2025, and in February 2026 the FTC restored the older rule text, which covers only prenotification plans. In March 2026 the FTC asked for comments on a possible new rule. As of October 2026 it has not proposed one.

Was the rule struck down because cancellation traps are legal? No. The court vacated it because the FTC did not issue a preliminary regulatory analysis, which the FTC Act requires for rules with an annual economic effect of $100 million or more. ROSCA and state laws still apply.

What federal law protects me when I cancel an online subscription? ROSCA, 15 U.S.C. § 8403. It requires clear disclosure, express informed consent and "simple mechanisms" to stop recurring charges for subscriptions sold online. The FTC used it in its 2025 Amazon Prime settlement.

Does California still have click-to-cancel? Yes, under state law. AB 2863 amended California's Automatic Renewal Law for contracts made or renewed from 1 July 2025, requiring cancellation in the same medium you used to sign up.

What about New York? New York's General Business Law § 527-a, amended in 2025, requires cancellation through the same medium you used to consent, plus advance notice of some renewals, trial conversions and price increases.