Yes—but the delay is now a historical step, not the rule’s current status. On May 9, 2025, the Federal Trade Commission (FTC) postponed enforcement of parts of its 2024 “Click-to-Cancel” amendments for 60 days and said the full amendments would be enforced beginning July 14, 2025. On July 8, 2025, the Eighth Circuit vacated those amendments. The FTC restored the pre-amendment Negative Option Rule text effective February 12, 2026, and in March 2026 began a separate rulemaking process on possible subscription and cancellation rules. The FTC has not set a current enforcement date for a newly adopted federal click-to-cancel rule.
What did the FTC’s 60-day delay mean?
In a May 9, 2025 Commission statement, the FTC deferred enforcement of 16 C.F.R. §§ 425.4–425.6 for 60 days. Those provisions were part of the FTC’s 2024 amendments to the Negative Option Rule and addressed disclosures, consent, and cancellation. The Commission said the original compliance period was inadequate given the complexity of compliance.
At the time, the FTC said regulated entities would have to comply with the full amended rule starting July 14, 2025. The Commission’s statement put it this way: “Starting July 14, 2025, regulated entities must be in compliance with the whole of the Rule because the Commission will begin enforcing it.” That sentence records the agency’s announced plan on May 9, 2025; it is not a current enforcement date.
The FTC’s October 16, 2024 announcement described the amendments as covering negative-option marketing across media, including requirements for a simple cancellation mechanism, disclosures of material terms, and informed consent. Then-Chair Lina M. Khan said in that announcement, “Too often, businesses make people jump through endless hoops just to cancel a subscription.” The FTC said the rulemaking received 16,000 comments.
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When was the rule delayed, and what happened next?
| Date | What happened |
|---|---|
| October 16, 2024 | The FTC announced its final “Click-to-Cancel” amendments to the Negative Option Rule. |
| January 19, 2025 | The 2024 amendments’ general effective date, according to the FTC’s May 2025 statement. |
| May 9, 2025 | The FTC announced a 60-day enforcement deferral for sections 425.4–425.6 and said it expected full compliance with the amended rule by July 14, 2025. |
| July 8, 2025 | The Eighth Circuit vacated the 2024 amendments. |
| February 12, 2026 | The FTC’s conforming final rule restoring the Negative Option Rule text that preceded the 2024 amendments took effect. |
| March 13, 2026 | The FTC issued an Advance Notice of Proposed Rulemaking seeking comment on possible rules for online subscriptions and cancellations. |
The July 8 vacatur came before the FTC’s announced July 14, 2025 enforcement date. The agency’s February 2026 conforming rule restored the pre-amendment text; it did not put the vacated amendments back into force.
Independent reader supportYour contribution helps us test, update, and keep practical guides available for everyone.Is there a new federal click-to-cancel enforcement date?
No new enforcement date is established in the cited federal actions. The FTC’s March 13, 2026 advance notice is an invitation to comment on whether the Commission should adopt rules about online subscriptions and cancellations. It is a preliminary rulemaking step, not a final replacement rule. The FTC’s 2026 Unified Agenda lists April 13, 2026 as the comment-period end date.
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For readers trying to understand the headline, the key distinction is between the FTC’s announced 2025 delay and the later legal changes: the delay moved the agency’s planned enforcement date, but the court vacated the amendments before that date arrived. The 2026 action restored the older rule text while the Commission considered whether to propose new requirements.
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