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The FTC’s 2024 “click to cancel” rule was vacated in July 2025, so its new requirements should not be treated as currently operative. In March 2026, the agency began a new inquiry into whether and how to amend its Negative Option Rule; that request for comment did not reinstate the vacated amendments. For consumers facing a free-trial conversion or unwanted recurring charge, the FTC’s practical advice remains to check the terms and cancellation deadline, keep a reminder, monitor statements, and dispute an unauthorized charge if the company will not resolve it.
What the FTC’s “click to cancel” rule would have required
On October 16, 2024, the Federal Trade Commission announced amendments to its Negative Option Rule. The FTC said the measure was intended to cover almost all negative-option programs across media. A negative-option arrangement bills a consumer automatically unless they take action to stop it.
As announced, the amendments included requirements to disclose material terms before collecting billing information, obtain express informed consent to the negative-option feature, avoid material misrepresentations, and provide a simple cancellation method that would stop recurring charges. The Commission vote was 3-2. These describe the 2024 amendments as announced, not requirements that consumers or businesses should assume are in force now. FTC announcement, October 16, 2024
Why those 2024 requirements are not current law
The FTC’s 2026 rulemaking materials say the Eighth Circuit vacated the amended rule in July 2025. That means the 2024 amendments did not remain in effect as a new federal rule after the court’s decision. The vacatur is not the same as a finding that every subscription practice is lawful: other laws or rules may apply to particular conduct, but the sources cited here do not establish how those provisions apply to any specific company or transaction. FTC Negative Option Rule library · FTC advance notice of proposed rulemaking
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What the FTC asked about in 2026
In March 2026, the FTC requested public comment on whether and how to amend its Negative Option Rule. The agency sought information on consumer understanding of offer terms, enrollment without express informed consent, obstacles to cancellation, how common these practices are, possible regulatory approaches, and potential costs and benefits. The comment deadline was April 13, 2026. The available official materials establish that an inquiry began, not that a replacement final rule was adopted; they do not establish what action, if any, the FTC took after the deadline.
The agency’s framing recognizes that subscriptions can benefit consumers and the marketplace by lowering transaction costs and providing uninterrupted service, while also raising concerns about unwanted enrollment and cancellation barriers. FTC Bureau of Consumer Protection Director Christopher Mufarrige said, “Neither consumers nor competition are protected when consumers are enrolled in programs that they either do not want or cannot cancel.” FTC release, March 2026
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How a free trial can turn into recurring charges
A free trial may ask for card details up front so a business can charge the consumer if they do not cancel before the trial ends. A trial box that becomes monthly shipments and a magazine subscription that renews automatically are examples of negative-option arrangements described by the FTC. If the offer charges shipping or another fee, it is not entirely free; check the actual terms rather than relying on the headline offer. FTC consumer guidance, September 2024
Before you sign up for a free trial offer
- Find the full terms. Confirm the trial’s length, the amount and frequency of charges after it ends, and any fees due before then.
- Check how and when to cancel. Locate the cancellation instructions and deadline before entering payment details; do not assume that deleting an app or account ends billing.
- Look for preselected boxes. Review selections and consent choices so you know what you are agreeing to.
- Research the company and its cancellation policy. If the instructions or terms are difficult to find, treat that as a reason to pause before enrolling.
- Save the deadline. Put a cancellation reminder on a calendar if you do not want the subscription to continue. A free digital reminder works just as well as a paper calendar.
How to stop a subscription and respond to an unwanted charge
- Follow the business’s cancellation instructions before the deadline. Keep a record of the date and any confirmation you receive.
- Watch your card statements. Check credit- and debit-card activity for charges you do not recognize or that continue after cancellation.
- Ask the company to resolve an unauthorized charge. If it will not resolve the issue, the FTC advises disputing the charge with your card issuer.
- Report suspected fraud. The FTC directs consumers to ReportFraud.ftc.gov.
What complaint numbers can—and cannot—tell you
When announcing the 2024 amendments, the FTC said it received nearly 70 consumer complaints per day on average in 2024, compared with 42 per day on average in 2021. Those figures are the agency’s reported complaint averages for those years. Complaint counts are not a measure of how many consumers experienced a problem, because they count reports received rather than establishing the total prevalence of unwanted subscriptions or billing practices. FTC announcement, October 16, 2024
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