Subscription Cancellation Rights: What the Law Actually Says (2026)

You have probably seen the headlines: “Click-to-Cancel is now the law.” The truth is more complicated, and more useful, than the headline.

The FTC Click-to-Cancel rule is not in effect. It was repealed by the Eighth Circuit on July 8, 2025, and a 2026 attempt to restore it is still in the public-comment stage. That means there is no federal click-to-cancel mandate today.

But you are not unprotected. A patchwork of federal, state, and international rules still limits what a company can do when you try to leave.

The US legal stack

Three layers of law apply to digital subscriptions in the United States.

ROSCA (federal, in force)

The Restore Online Shoppers’ Confidence Act (15 U.S.C. §§ 8401-8405) is the strongest federal constraint. It requires clear disclosure, express consent, and a “simple mechanism” to stop future charges. The word “simple” is not defined by ROSCA, which is both a strength and a weakness.

FTC Act Section 5 (federal, in force)

Section 5 prohibits unfair or deceptive acts or practices. A company that advertises “cancel anytime” but buries the cancel button behind three confirmation screens is a credible Section 5 target.

State auto-renewal laws (patchwork, expanding)

Over 40 US states have auto-renewal laws. California, New York, Delaware, and Illinois have the strictest versions. See Subscription Cancellation Laws by State for details.

The FTC Click-to-Cancel timeline (accurate version)

Date	Event	Source
2024-11-15	FTC publishes revised Negative Option Rule	89 FR
2025-07-08	Eighth Circuit repeals the rule in Custom Communications v. FTC	8th Cir.
2025-07-14	Original enforcement date never took effect	—
2026-01-30	FTC submits ANPRM draft to OIRA	FTC
2026-02-12	FTC restores pre-2024 Negative Option Rule text (91 FR 6507)	weaker standard
2026-03-11	FTC publishes ANPRM for public comment (closed 2026-04-13)	FTC

The EU: Directive 2023/2673 and CJEU C-234/25

Directive (EU) 2023/2673 took effect on June 19, 2026. It requires online platforms to offer a dedicated online withdrawal button.

CJEU Case C-234/25 (July 9, 2026) held that personalized-recommendation streaming services are “digital services” under Art. 2(11), not “digital content.” The waiver checkbox used at sign-up is invalid. The 14-day withdrawal right restores automatically.

See EU Subscription Withdrawal Rights for details.

What to do when a service fights your exit

1. Document everything (screenshots, timestamps, confirmation numbers)
2. Cite ROSCA and your state auto-renewal law
3. Dispute the charge with your card issuer
4. File a complaint with the FTC, state AG, or CFPB
5. Consult a lawyer for significant amounts

For the full ranking of which services actually make you fight, see the 2026 Subscription Friction Index.