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Appeals Court Vacates FTC’s Click-to-Cancel Rule

The decision reflects the absence of a required economic impact review, leaving no federal requirement for easy online cancellations.

FILE - A person looks at their phone at Seattle–Tacoma International Airport on Sunday, June 1, 2025, in Seattle. (AP Photo/Jenny Kane, File)
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Overview

  • The Eighth Circuit vacated the FTC’s click-to-cancel rule days before its planned enforcement after finding the agency skipped a preliminary analysis for rules exceeding $100 million in annual impact.
  • With the vacatur, companies can still require customers to cancel subscriptions by phone despite allowing online sign-ups and payments, and there is no federal mandate for clear trial end disclosures.
  • Consumer experts advise setting calendar reminders, reviewing account statements frequently and using apps like Rocket Money or Trim to monitor and cancel unwanted subscriptions.
  • The FTC is moving forward with its trial against Amazon, alleging the retailer enrolled consumers in Prime without clear consent and imposed obstacles to cancellation.
  • California’s new click-to-cancel law took effect July 1, offering residents state-level protections for simpler online subscription terminations.