FTC Opens New Rulemaking to Revive the Click-to-Cancel Subscription Rule

Published 2026-03-12 · TrimWell Media News

The Federal Trade Commission has formally restarted its effort to regulate subscription cancellation practices. According to Sidley Austin, the FTC submitted a draft Advance Notice of Proposed Rulemaking (ANPRM) concerning its Negative Option Rule to the Office of Information and Regulatory Affairs on January 30, 2026.

The move follows the Eighth Circuit’s July 2025 decision vacating the FTC’s 2024 "Click-to-Cancel" rule on procedural grounds. Coverage from Wiley noted the FTC formally announced the ANPRM on March 11, 2026, opening a public comment period that closed April 13 with roughly 100 comments submitted.

Analysis from Jones Day emphasized that even without a finalized rule, the FTC has continued enforcement under the existing Restore Online Shoppers’ Confidence Act (ROSCA), and that approximately 30 states already have their own automatic-renewal laws in place.

Based on the pace of past FTC rulemaking, a finalized replacement rule likely remains well over a year away, meaning ROSCA and state law continue to be the primary protections available to consumers in the meantime.

Read more on what these protections mean for you in our Click-to-Cancel explainer.

Sources: Sidley Austin, Wiley, Jones Day.