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A lot of advice written in 2025 tells you that US companies must now let you cancel a subscription as easily as you started it. That is not currently the position, and if you are budgeting for software it is worth knowing why.
What happened to "click to cancel"
The Federal Trade Commission made a rule on subscriptions and negative-option plans — widely called the click-to-cancel rule — that would have required exactly that. On 8 July 2025, days before it was due to take effect, the US Court of Appeals for the Eighth Circuit vacated it in full. The court's reasoning was procedural: the FTC had not carried out a preliminary regulatory analysis that was required because the rule's economic impact crossed the threshold for a major rule under Section 18 of the FTC Act.
Vacated means gone, not paused. The rule does not apply.
What the FTC is doing about it
The Commission restarted the process. It sent a draft Advance Notice of Proposed Rulemaking for review on 30 January 2026, announced on 11 March 2026 that it was seeking public comment, and set a comment deadline of 13 April 2026. As of the date on this page, what any replacement rule will actually say is not settled.
So the honest answer to "is click-to-cancel the law?" is: it was made, it was struck down, and a replacement is being written. Anyone telling you otherwise is working from old notes.
What still applies
This is the part that matters, because the gap is smaller than it sounds.
The Restore Online Shoppers' Confidence Act (ROSCA) is untouched and still enforced. It requires a seller with a recurring charge to disclose all material terms clearly before taking your billing information, to obtain your express informed consent to the subscription, and to provide a simple mechanism to stop the recurring charges.
The FTC also retains its general power over unfair or deceptive practices under Section 5 of the FTC Act, and has continued bringing cases against subscription sellers.
Separately, a number of US states have their own automatic-renewal statutes with their own notice and cancellation requirements. Those are state law and sit outside the federal rule entirely, so the Eighth Circuit's decision did not touch them. Which ones apply to you depends on where you and the seller are; we have not researched individual states and will not guess at them here.
What to do before you sign
You cannot rely on a rule that does not exist, so read the terms:
- Does it renew automatically, and for how long? A one-year plan that rolls into another full year is common.
- Is there a notice period? Some contracts require you to give notice 30 or 60 days before the renewal date, which means the moment to act is well before the date you have in your calendar.
- How do you actually cancel? If the answer is "email your account manager" rather than a button, plan for it to take time.
- Put the notice date in a calendar, not the renewal date. The renewal date is too late.
This page describes what published sources say about the current rules. It is not legal advice, and we are not lawyers. For a decision that matters, ask one.