Is Click-to-Cancel Still Law? The FTC Rule's 2026 Status, Explained

The FTC’s “click-to-cancel” rule — formally, the 2024 amendments to the Negative Option Rule — would have required any subscription business to make cancellation as easy as signup: if you subscribed with two taps, you could cancel with two taps. It became one of the most-cited consumer protections on the internet. Then, in July 2025, a federal appeals court vacated it before it ever took effect.

If you have read that the rule “requires” easy cancellation somewhere online, that claim is now out of date. This article is the current state of play: what happened, what the FTC is doing about it, and — most importantly — the protections that still exist regardless.

The timeline

• October 2024 — The FTC adopts the click-to-cancel amendments to the Negative Option Rule, with compliance dates starting mid-2025.
• July 2025 — The Eighth Circuit Court of Appeals vacates the amendments, holding the FTC failed to adequately justify them under its statutory authority. The rule never takes effect.
• March 2026 — The FTC opens a new rulemaking (an Advance Notice of Proposed Rulemaking) to rebuild the requirements on firmer legal ground, requesting public comment on how to structure the new rule.

So as of late 2026: there is no federal click-to-cancel rule in force. A replacement is in progress but will take time — proposed text, comment period, final rule, and almost certainly another court challenge.

What still protects you today

State laws

Several US states have their own automatic-renewal and cancellation laws that never depended on the federal rule. California’s regime is the broadest — it requires online cancellation for online subscriptions and bans dark-pattern retention flows for covered businesses, and other states including New York and Colorado enforce similar requirements. These laws apply based on where you live or where the company operates, without the now-vacated federal layer.

The FTC’s general authority

Losing the specific rule did not leave the FTC powerless. Section 5 of the FTC Act bans unfair and deceptive practices, and the Commission has brought enforcement actions against companies whose cancellation flows were engineered to fail — the theory being that a signup promising “cancel anytime” followed by a phone-tree maze is deceptive, rule or no rule. Expect enforcement to continue while the replacement rule is pending.

Card networks and payment providers

Visa and Mastercard both have subscription rules for merchants: clear billing descriptors, advance reminders for renewals and trials, and cancellation instructions in the reminder. These are contract terms between the merchant and the card network — you invoke them through chargebacks and by reporting the merchant, not in court, but they are a real lever, especially for merchants who ignore every other channel.

The EU and UK

If you are in the EU or UK, consumer rights directives already require prominent trial-conversion disclosures and straightforward withdrawal rights, and the EU’s Digital Services Act and dark-pattern guidance strengthen the position further. The American court fight is not your fight.

What this means for the fine print you actually signed

None of these protections rewrite your contract. The terms of service you accepted still contain the automatic renewal clause and the negative-option billing mechanics; the law only constrains how hostile those clauses are allowed to be. A clause like the one below is still lawful in most of the US as long as the company discloses it:

That excerpt stacks three things worth catching early: renewal by default, phone-only cancellation, and unilateral amendment. Which is the practical takeaway of the whole saga — the rule died in court, but the sixty-second document audit still works exactly as well as it ever did. Search any terms of service for cancel, renew, and continued use before you hand over a card, or run a free ToS-TLDR scan and let the scanner do the searching.