What is ftc click-to-cancel rule (negative option rule)?

The FTC's Click-to-Cancel Rule was a 2024 update to the agency's Negative Option Rule that would have required sellers to let consumers cancel a subscription as easily as they signed up for it, among other disclosure and consent requirements. As of August 2026, the rule is not in effect: the Eighth Circuit vacated it in July 2025 on procedural grounds, holding the FTC skipped a required preliminary economic-impact analysis.

This area of law is changing. The description below reflects the position as of 2026-08-22. Check the sources before relying on it.

This status is actively changing. The FTC submitted a new draft rulemaking notice to federal regulatory review in January 2026 to try again, and observers expect any replacement rule to resemble the vacated one substantively since the court's objection was procedural, not about the rule's substance. In the meantime, the FTC continues bringing subscription-cancellation cases under the older Restore Online Shoppers Confidence Act (ROSCA), which was never vacated and remains fully enforceable, so a company can still face FTC action over hard-to-cancel subscriptions even without the vacated rule.

Last reviewed 2026-08-22.