FTC click-to-cancel rule: where it stands
The FTC's 2024 click-to-cancel rule was vacated in July 2025 and rulemaking restarted in 2026. Here's what still protects you when you cancel a subscription.
Updated November 14, 2026 · Not legal advice
A short history
- 2024: the FTC finalized amendments to its Negative Option Rule, often called "click to cancel": cancelling would have had to be as easy as signing up.
- July 2025: the U.S. Court of Appeals for the Eighth Circuit vacated the rule on procedural grounds, just before its main provisions were due to take effect.
- 2026: the FTC began a new rulemaking process on negative-option practices. No replacement rule is in force yet.
What still protects you today
- ROSCA, the federal law requiring clear terms, consent and a simple way to stop recurring charges online — see ROSCA explained.
- Section 5 of the FTC Act, which the FTC continues to use against hard-to-cancel subscriptions.
- State laws, several of which explicitly require online cancellation, such as California and New York. See the state overview.
- Your bank: you can stop recurring ACH payments and dispute card charges.
What to do if a company makes cancelling hard
Document every step, send a written request if needed, and report the company to the FTC and your state attorney general.
FAQ
Is click-to-cancel the law now?
Not at the federal level as of November 2026 — the 2024 rule was vacated. Several states have their own click-to-cancel requirements.
What else are you paying for?
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