The FTC announced a “click-to-cancel” rule in October 2024, but those amendments are not the current federal rule. The Eighth Circuit vacated them, and the FTC restored the earlier Negative Option Rule text effective February 12, 2026. In March 2026, the agency separately asked for comment on whether it should adopt rules about online subscriptions and cancellations; that request was not a new final rule.
What the FTC announced in 2024
The FTC’s October 16, 2024 announcement described a final rule intended to make it easier to end subscriptions and memberships sold through “negative option” marketing—arrangements in which a consumer’s silence or failure to act can be treated as acceptance or continuation. The agency said the rule would apply to almost all negative-option programs in any media.
The announced amendments addressed four areas:
- Marketing representations: restrictions on material misrepresentations in promoting or offering a negative-option feature.
- Key disclosures: disclosure of important terms before collecting billing information and charging consumers.
- Consent: informed consent before imposing charges.
- Cancellation: a simple way to cancel that would immediately stop charges.
The FTC also said it removed two provisions from its proposal before issuing the final rule: annual reminders about a subscription’s negative-option feature, and a requirement that sellers ask whether a consumer wanted to hear plan changes or retention reasons before presenting them during cancellation. These details describe the 2024 amendments, not requirements that remain in force today. FTC announcement, October 16, 2024
Why the 2024 amendments are not in force
The Eighth Circuit vacated the 2024 amendments after court review. The FTC’s rulemaking record identifies the procedural problem as the agency’s failure to issue a preliminary regulatory analysis. On February 12, 2026, the FTC issued a conforming rule restoring the Negative Option Rule text as it stood before the 2024 amendments. For that reason, the 2024 click-to-cancel provisions should not be described as current binding federal requirements.
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The rulemaking record also lists a separate step: on March 13, 2026, the FTC issued an advance notice seeking comment on whether to adopt rules concerning online subscriptions and cancellations. The listed comment-period end date was April 13, 2026. An advance notice requests input; it is not an adopted final rule and does not itself establish new cancellation obligations. FTC rulemaking record, RIN 3084-AB84
How to read the rule’s status
| Event | What it means |
|---|---|
| October 16, 2024: FTC announced final click-to-cancel amendments | The agency announced amendments addressing representations, disclosures, consent, and cancellation. |
| After court review: Eighth Circuit vacated the 2024 amendments | Those amendments did not remain operative as the current rule text. |
| February 12, 2026: FTC restored the pre-amendment text | The earlier Negative Option Rule text was restored. |
| March 13, 2026: FTC issued an advance notice | The agency sought comment on whether to adopt rules about online subscriptions and cancellations; this was not a final rule. |
Why the FTC said it acted
In its 2024 announcement, the FTC said it had received more than 16,000 comments after its March 2023 notice of proposed rulemaking. The agency also reported nearly 70 consumer complaints per day on average, compared with 42 per day in 2021. Those are figures reported by the FTC, not independent estimates. FTC announcement, October 16, 2024
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