The FTC Click-to-Cancel Rule: What Happened, What's Next, and What You Can Do Right Now
⚠️ The short version: The FTC's Click-to-Cancel rule was struck down by the Eighth Circuit Court of Appeals. It is not currently in effect. Most articles online claim otherwise. This page gives you the accurate picture.
What the rule was
The FTC finalized the Click-to-Cancel rule in October 2024. Its core requirements:
- If you could sign up online, you had to be able to cancel online.
- The cancellation process had to be at least as simple as the sign-up process.
- Companies could not add new steps, hurdles, or retention offers not present during sign-up.
- Companies had to obtain explicit consent before auto-renewing a subscription.
- Free trial conversions required clear disclosure and separate consent.
Enforcement was originally scheduled for May 2025, with some provisions delayed to July 14, 2025.
What happened
The rule was challenged in court by trade groups representing companies that benefit from difficult cancellation processes. The Eighth Circuit Court of Appeals struck it down, finding that the FTC exceeded its rulemaking authority under the specific statutory basis it used.
The FTC has not abandoned enforcement. It continues to bring cases against companies with deceptive subscription practices under Section 5 of the FTC Act, which prohibits unfair and deceptive trade practices. This authority was not affected by the court ruling. The $2.5 billion settlement with Amazon in September 2025 over its "Iliad Flow" cancellation maze was brought under this existing authority — not the Click-to-Cancel rule.
What's happening now
Congress has introduced the Unsubscribe Act, which would codify the Click-to-Cancel rule's core requirements into federal law — as statute rather than FTC rulemaking, which is what the court objected to. The bill is being considered in 2026. Its passage is not guaranteed.
Several states have not waited for federal action. California, Virginia, Colorado, New York, and others have enacted their own automatic renewal and cancellation laws. See our state-by-state guide for specifics.
What protects you right now
Even without the Click-to-Cancel rule, you have real rights:
- FTC Section 5 authority. The FTC can still prosecute companies for deceptive subscription practices. The Amazon settlement proves this authority has teeth — $2.5 billion worth.
- State automatic renewal laws. More than 30 states have laws governing auto-renewals and cancellation. California's is the strongest: if you signed up online, you must be able to cancel online. See the state-by-state guide.
- The Fair Credit Billing Act. If a company charges you after you've requested cancellation, you can dispute the charge with your credit card. You have 60 days from the statement date. See our chargeback guide.
- State attorney general complaints. Your state AG's consumer protection division can investigate companies that make cancellation unreasonably difficult. See how to file a complaint.
- ROSCA (Restore Online Shoppers' Confidence Act). This federal law, which predates the Click-to-Cancel rule, already requires clear disclosure of auto-renewal terms and a simple cancellation mechanism. It remains fully in effect.
What you should do
- Know your state's laws. See our state-by-state guide. If you're in California, Colorado, Virginia, or New York, you have stronger rights than you may realize.
- Document cancellation attempts. Screenshots, dates, confirmation numbers, agent names. If a company gives you trouble, this is your evidence.
- File complaints when companies obstruct cancellation. The FTC uses complaint data to identify patterns. One complaint is weak; a hundred complaints about the same company's cancel flow triggers an investigation. See how to file a complaint.
- Use the chargeback as a last resort. If you've documented your cancellation and the company charges you anyway, your credit card company can reverse the charge. See the chargeback guide.
- For specific cancel instructions, search our database of 100+ services: Cancel database.
Finding all your subscriptions
If you want to audit what you're paying for before you start canceling, we built a guide that covers six methods — none of which require sharing your bank credentials with anyone. See: How to find all your subscriptions.
If you'd prefer a faster path and are comfortable uploading a bank statement to a third-party tool, JustCancel offers a one-time $5 scan that identifies every recurring charge. They report that files are deleted after scanning. We have no financial relationship with them; we recommend them because they do useful work.
Last updated: April 2026. Laws change — check the FTC website and your state legislature for the most current status.