The Cancel Button You Think Is Required Is Not

The rule that would have made cancelling as easy as subscribing does not exist. The FTC announced it in October 2024, a court struck it down, and the Commission’s own March 2026 filing refers to “the vacated 2024 Rule”.

Which matters for every page we have published this season about what a device costs after you buy it, because all of them assume you can leave.

What happened, in four steps

October 2024	The FTC announces a final Click-to-Cancel rule. Cancelling had to be as easy as signing up.
In court	A federal court vacates it.
March 2026	The FTC opens an advance notice asking whether and how it should act at all.
Today	No federal click-to-cancel requirement is in force.

Every step from the Commission’s own publications, read 5 September 2026.

The gap between what people believe and what is true

The rule was announced loudly, covered everywhere, and entered public memory as a thing that happened. The vacatur was covered far less, and the reopening of the rulemaking barely at all.

So a large number of people believe there is a legal requirement that a subscription be cancellable in the same number of clicks it took to start. There is not, and the FTC’s own numbers suggest the underlying problem never went away: more than 100,000 complaints in five years about deceptive enrolment, difficult cancellation and unauthorised billing.

What is actually left

Three things, and none of them is a click-to-cancel button.

The older Negative Option Rule still exists. It is narrow, and it is not the 2024 rule. What the FTC is now consulting on is precisely whether to replace or extend it.

State law has not gone anywhere. Several US states have their own automatic renewal statutes that operate regardless of the federal position, and they are where a real obligation is most likely to be found today.

General prohibitions on deception still apply. A company that makes cancellation deliberately obstructive is exposed under law that predates any of this. What is missing is the specific, bright-line requirement.

Why this belongs on a tech site

Because subscriptions are now attached to hardware rather than sold separately, and the decision to accept one is made in the same minute as the decision to buy a doorbell or a console.

Our own count of what a household pays in a year came to $339.80 at the cheapest tiers across five categories. The ease of leaving any of them is not a legal guarantee. It is a design choice each company makes, and the regulator is currently asking the public whether it should be otherwise.

What to actually do

• Assume cancelling is harder than subscribing, and find out how before you start, not after. The path is usually documented in the help pages.
• Prefer the tier or the store that lets you cancel where you signed up. A subscription bought through an app store can usually be stopped there in a few taps, which is a stronger practical protection than any rule currently in force.
• Diary the renewal date. It is the one defence that works regardless of what the seller’s cancellation flow looks like.
• Check your own state’s automatic renewal law if a company will not let you leave. That is where an enforceable obligation is most likely to sit today.
• Comment if you have a view. The FTC’s notice is an open consultation, which is the rarest thing on this page: a regulator explicitly asking.