Is the FTC's Click-to-Cancel rule in effect in 2026?

No. It was vacated in 2025 and a replacement rule is still in the rulemaking process, not yet finalized.

What law protects consumers from hard-to-cancel subscriptions right now?

The Restore Online Shoppers' Confidence Act (ROSCA), plus individual state automatic-renewal laws.

When might a new federal rule take effect?

Based on typical FTC rulemaking timelines following the 2026 ANPRM, a finalized rule is unlikely before 2027 at the earliest.

Click-to-Cancel: What the FTC's Rule Revival Means for You

Published 2026-03-02 · TrimWell Media

Direct answer: The FTC's 2024 Click-to-Cancel rule was vacated by the Eighth Circuit in July 2025 on procedural grounds, and in January 2026 the FTC submitted a new Advance Notice of Proposed Rulemaking to revive it, but no new federal rule is in effect yet; existing protections still come from ROSCA and roughly 30 state automatic-renewal laws.

What the vacated rule would have required

The 2024 Click-to-Cancel rule would have required companies to make cancellation at least as easy as sign-up, offer cancellation through the same medium used to enroll, and disclose all material subscription terms clearly before charging a customer.

Why it was struck down

The Eighth Circuit vacated the rule in July 2025, finding the FTC failed to conduct a required preliminary economic impact analysis during rulemaking — a procedural failure, not a rejection of the rule's substance.

What's happening now

On January 30, 2026, the FTC submitted a draft Advance Notice of Proposed Rulemaking to formally restart the process. A public comment period followed, closing April 13, 2026 with around 100 comments submitted. Based on the typical rulemaking timeline, a finalized rule realistically remains a year or more away.

What protections exist right now

The Restore Online Shoppers' Confidence Act (ROSCA) remains fully in effect and already requires clear disclosure, informed consent, and a simple cancellation mechanism for online negative-option subscriptions — the FTC has continued bringing enforcement actions under it even without the vacated rule. Separately, roughly 30 states have their own automatic-renewal laws, some stricter than the rule that was struck down.

Ready to see your own numbers? Try the free TrimWell Score calculator — no signup, no bank login, results in under a minute.

Frequently Asked Questions

Is the FTC's Click-to-Cancel rule in effect in 2026?: No. It was vacated in 2025 and a replacement rule is still in the rulemaking process, not yet finalized.
What law protects consumers from hard-to-cancel subscriptions right now?: The Restore Online Shoppers' Confidence Act (ROSCA), plus individual state automatic-renewal laws.
When might a new federal rule take effect?: Based on typical FTC rulemaking timelines following the 2026 ANPRM, a finalized rule is unlikely before 2027 at the earliest.