The FTC’s Click-to-Cancel Rule Is Gone. Other Laws Are Not

Update, 6 October 2026. This page said the FTC’s consultation was open and suggested commenting. It closed on 13 April 2026. It also said no federal click-to-cancel requirement was in force, which went too far: a 2010 federal law already requires “simple mechanisms” to stop recurring charges on subscriptions sold online. Both are corrected, and the page is reworked around what still applies, including California’s cancel-online rule.

The FTC’s click-to-cancel rule is not in effect: a federal appeals court vacated it in 2025, and in February 2026 the FTC restored its rule as it stood before 2024. What still covers cancelling is older and narrower, a 2010 federal law for online sign-ups plus state and city rules such as California’s and New York City’s.

What happened to the rule

When	What happened
16 October 2024	The FTC announces a final “click-to-cancel” rule: cancelling must be as easy as signing up, for almost all subscriptions “in any media”
2025	The Eighth Circuit vacates it, calling the FTC’s missing preliminary regulatory analysis “procedurally insufficient”
12 February 2026	The FTC restores its Negative Option Rule “as it existed before” the 2024 rule took effect
13 March – 13 April 2026	An advance notice asks whether to amend the rule; comments close on 13 April
6 October 2026	The FTC’s rule page lists nothing newer than the March notice

From the FTC’s press releases and rule page, and two Federal Register documents, read 6 October 2026.

The court did not rule on whether cancelling should be easy. It vacated the rule over procedure: the February 2026 Federal Register notice says the Eighth Circuit found the FTC’s failure to issue a preliminary regulatory analysis “procedurally insufficient”.

The March notice asked the public whether to keep the current rule, adopt “provisions of the vacated 2024 Rule”, or try alternatives to regulation such as education. The FTC’s own case for acting is in the same release: more than 100,000 complaints in five years about negative options and related practices.

What still covers cancelling

Law	Who it covers	What it requires
Restore Online Shoppers’ Confidence Act (federal, 2010)	Subscriptions “sold in a transaction effected on the Internet”	“Simple mechanisms” to stop recurring charges, plus clear terms and express consent before billing
FTC Negative Option Rule (1973, restored 2026)	“Prenotification negative option plans”, per its name	Its pre-2024 text; the 2024 rule’s cancellation clause is gone
California Business and Professions Code § 17602	Automatic renewals offered to consumers in California; the online clause applies to contracts from 1 July 2025	If you accepted online, cancel “exclusively online, at will”, by a prominent link or button or a ready-made email
New York City rule (from 1 October 2026)	Consumers in New York City	Cancel through the medium you signed up with, as easily

The federal floor is ROSCA, the 2010 law, and it is narrower than the rule that was struck down. It covers only sales made on the internet, and it asks for “simple mechanisms” without saying they must be online or as quick as the sign-up. The 2024 rule would have set that test for almost every subscription “in any media”.

California spells out what the online route has to look like. A business that let you accept an automatic renewal online has to let you end it online, “without engaging any further steps that obstruct or delay” it, through “a prominently located direct link or button” in your account or settings, or a termination email it formats for you. It may still ask you to log in first, and it may show a discount offer, as long as you can still cancel.

New York City’s own rule, in force since 1 October 2026, requires cancellation through the same medium you used to sign up, and as easily, but only for consumers in the city. It adds renewal reminders too. This page does not cover other states’ laws; check your own.

Why this belongs on a tech site

Subscriptions now come attached to hardware, 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, and the two big VPNs we checked renew at more than the price they advertise.

How easily you can leave each of those depends on how you signed up and where you live, not on one national rule.

What to do if you need to cancel

• Start where you signed up. The website, app or store you subscribed through is the first place to look for the cancel option.
• Look in account settings. If you are in California and signed up online, the law requires an online way out there, as a link, a button or a termination email.
• Diary the renewal date when you subscribe. It works whatever the cancellation flow looks like.
• Keep the evidence. Screenshots of a cancellation attempt and any confirmation email are what a complaint needs.
• Report a company that blocks you to the FTC at ReportFraud.ftc.gov, which the FTC names for reporting bad business practices. In New York City, complaints go to the city’s consumer department through 311.

Questions people ask

Is the FTC click-to-cancel rule in effect?

No. The Eighth Circuit vacated it in 2025, and on 12 February 2026 the FTC restored its Negative Option Rule as it stood before 2024. A 2010 federal law still requires “simple mechanisms” to stop recurring charges on subscriptions sold online.

What happened to the FTC click-to-cancel rule?

The FTC announced it on 16 October 2024. Industry groups challenged it, and the Eighth Circuit vacated it because the FTC had not issued a preliminary regulatory analysis. In March 2026 the FTC asked whether to write a new rule; comments closed on 13 April 2026.

Can I still comment on the FTC click-to-cancel rule?

Not on the March 2026 notice: its Federal Register entry says comments had to be received by 13 April 2026. If the FTC proposes a new rule, that proposal would open its own comment period.

Is there a law that a company must let me cancel online?

For subscriptions sold online, the federal Restore Online Shoppers’ Confidence Act requires “simple mechanisms” to stop recurring charges, without saying they must be online. California goes further: if you signed up online, you must be able to cancel online, by a link, a button or a ready-made email.

Does California require a cancel button?

Close to it. Since 1 July 2025, for subscriptions accepted online, California’s section 17602 requires “a prominently located direct link or button” in your account or settings, or an “immediately accessible termination email” the business provides.

What can I do if a company will not let me cancel?

Start where you signed up, and in California look for the online cancel link or button the law requires for online sign-ups. Keep screenshots and any cancellation emails. You can report the company to the FTC at ReportFraud.ftc.gov, and in New York City to the city’s consumer department through 311.