Correction: The FTC Click-to-Cancel Rule Is Not in Effect
Correction — 26 August 2026
This article originally stated that the FTC’s click-to-cancel rule was “now fully in effect” and listed rights it “guarantees”. That was wrong. The Eighth Circuit Court of Appeals vacated the rule in July 2025 — before this article was published — and it has never taken effect. We have left the URL live and corrected the content rather than quietly deleting it.
We published something inaccurate about consumer law, and people may have acted on it. Here is what is actually true.
What we got wrong
The original version of this article told you that the FTC’s click-to-cancel rule had taken effect in early 2026, that companies could no longer force you to phone to cancel, and that you had five specific guaranteed rights. None of that was correct.
The FTC did finalise the rule in October 2024. But in July 2025 the Eighth Circuit vacated it in full, on the grounds that the Commission had failed to produce a preliminary regulatory analysis required under Section 18 of the FTC Act. The court held that the missing step could not be cured after the fact.
So when this article was written in March 2026, the rule had already been dead for eight months. We did not check, and we should have.
Where the rule stands now
The FTC restarted the process. It submitted a draft Advance Notice of Proposed Rulemaking on 30 January 2026 and opened public comment on 11 March 2026, closing 13 April 2026. An Advance Notice is the earliest stage of federal rulemaking — a new rule is plausible, but it is years rather than months away.
What actually protects you
ROSCA, the Restore Online Shoppers’ Confidence Act, remains fully in force and was unaffected by the court decision. It requires clear disclosure of material terms before billing details are taken, express informed consent, and a simple mechanism to stop recurring charges. The FTC continues to enforce it, with recent settlements reaching $60 million.
California AB 2863, effective 1 July 2025, contains close to what the federal rule would have required: express affirmative consent to auto-renewal separate from the terms of service, disclosure before billing information is collected, genuine click-to-cancel, and coverage of free-trial conversions. Many national companies apply it to all customers rather than build two flows.
We have written a full, accurate replacement: Is Click-to-Cancel Actually Law? What Really Happened to the FTC Rule — including what to say to a company that makes cancelling difficult.
Why we left this page up
Deleting it would have been easier and would have looked better. But this URL has been indexed and shared, and anyone who read the original deserves to find the correction at the same address rather than a 404.
We also think a company whose entire pitch is “we do not do the shady thing” does not get to quietly memory-hole its own mistakes.
This is general information, not legal advice. For a specific dispute, speak to a qualified attorney or your state attorney general’s office.