Overview

• The court vacated the FTC’s click-to-cancel rule on procedural grounds just days before its scheduled July 14 enforcement date
• Judges found the agency failed to conduct a required preliminary regulatory analysis for rules with over $100 million in annual economic impact
• The rule aimed to address surging consumer complaints—nearly 70 per day in 2024—by requiring cancellations via the same method used to sign up and banning deceptive negative option practices
• Business groups including the U.S. Chamber of Commerce and major cable and internet providers successfully challenged the rule as arbitrary and procedurally flawed
• FTC must initiate fresh rulemaking with a mandated economic analysis, leaving the future of simplified subscription cancellations uncertain