Click-to-cancel

Click-to-cancel is the principle that a consumer must be able to cancel a subscription or other recurring charge at least as easily as they signed up, through the same medium, for example online in a few clicks if they enrolled online.

This entry describes the rules; it is not legal advice.

The FTC rule. On October 16, 2024, the Federal Trade Commission voted 3-2 to finalize amendments to its Negative Option Rule, widely called the click-to-cancel rule. It prohibited misrepresentations, required clear disclosure of material terms before collecting billing information, required express informed consent before charging, and required a simple mechanism to cancel and stop charges through the same medium used to sign up. The final version dropped two proposals: annual reminders, and limits on presenting save offers.

Vacated. On July 8, 2025, the US Court of Appeals for the Eighth Circuit vacated the amendments in Custom Communications, Inc. v. FTC, holding that the FTC had not done the preliminary regulatory analysis that section 22 of the FTC Act requires. Effective February 12, 2026, the FTC restored the text of 16 CFR Part 425 as it stood before the 2024 amendments.

Status as of September 26, 2026. No federal click-to-cancel rule is in force. The FTC published an advance notice of proposed rulemaking in the Federal Register on March 13, 2026, asking whether to amend or replace the Negative Option Rule, including how to treat save attempts. The FTC’s rule page lists no later step.

What still applies. The Restore Online Shoppers’ Confidence Act (ROSCA) requires online sellers of negative option plans to disclose material terms before collecting billing information, obtain express informed consent, and provide simple mechanisms to stop recurring charges, and the FTC enforces it. States have their own laws. California’s Automatic Renewal Law requires online cancellation for consumers who enrolled online and, when a business shows a retention offer during online cancellation, a prominent “click to cancel” link or button next to it.

For agents. Simple online cancellation makes cancelling something a customer’s agent can do directly. The business still needs evidence that the agent may cancel that account, and both sides benefit from a record of when the request was made and honored.