Is Click to Cancel Still in Effect? The 2026 FTC Status

No. The FTC Click-to-Cancel rule is not in effect. It was repealed on July 8, 2025, and the replacement is still in the public-comment phase.

What the Click-to-Cancel rule was

The FTC revised Negative Option Rule (November 15, 2024, 89 FR) would have required a simple cancellation path, the same channel as sign-up, and no mandatory phone call.

Why it was repealed

The Eighth Circuit vacated the entire rule in Custom Communications, Inc. v. FTC on July 8, 2025, for failure to conduct the Section 22 preliminary regulatory analysis. The July 14 enforcement date never arrived.

What the FTC did next

• January 30, 2026: ANPRM draft submitted to OIRA
• February 12, 2026: Pre-2024 Negative Option Rule restored (91 FR 6507) — weaker, no cancellation-path requirements
• March 11, 2026: ANPRM published for public comment (closed April 13, 2026)

What actually protects you today

ROSCA (15 U.S.C. §§ 8401-8405) remains the strongest federal protection. It requires clear disclosure, express consent, and a “simple mechanism” — but “simple” is undefined.

FTC Act Section 5 prohibits deceptive flows. Amazon Prime (2023) and Uber (2025) were both brought under this theory.

State auto-renewal laws are the most immediately enforceable rules in many states. See Subscription Cancellation Laws by State.

The honest timeline

Milestone	Status
FTC Click-to-Cancel (revised Negative Option Rule)	Repealed July 8, 2025. Not in effect.
Pre-2024 Negative Option Rule restored	In effect since February 12, 2026 (weaker)
FTC ANPRM (new rulemaking)	Public comment closed April 13, 2026. Next steps TBD.
ROSCA	In force. Primary federal protection.
State auto-renewal laws	Expanding. Strongest immediate lever in many states.
EU Directive 2023/2673	In force since June 19, 2026 (EU only)

For the full ranking, see the 2026 Subscription Friction Index. For EU rights, see EU Subscription Withdrawal Rights.