The FTC Click-to-Cancel Rule Failed — Why Canceling Subscriptions Is Still a Nightmare in 2026

What Was the Click-to-Cancel Rule?

In October 2024, the FTC finalized the Negative Option Rule — commonly known as the "click-to-cancel" rule. The idea was simple and long overdue:

• If you can sign up online, you must be able to cancel online — no phone calls, no chatbots designed to waste your time, no "retention specialists"
• Clear disclosure of all subscription terms before you agree
• Express consent required before any recurring charge
• Simple cancellation — as easy as signing up

It was supposed to take effect on May 14, 2025, then was delayed to July 14, 2025.

It never took effect.

What Happened: The Court Struck It Down

On July 8, 2025 — just six days before the rule was set to take effect — the U.S. Court of Appeals for the Eighth Circuit vacated the entire rule on procedural grounds.

The court found that the FTC hadn't followed proper procedures in issuing the rule. Companies and trade organizations argued the FTC exceeded its authority and that the rule was "arbitrary and capricious" because it applied too broadly across the entire economy.

The companies won. Consumers lost.

Who Fought Against It?

Some of the biggest trade organizations in America lobbied against the rule — groups representing the exact industries where cancellation is hardest:

• The U.S. Chamber of Commerce
• The Internet Association (representing big tech companies)
• Media and telecom industry groups
• Fitness industry associations (gyms are notoriously hard to cancel)

Their argument? That requiring a simple cancel button would be too "burdensome" and "impractical."

Meanwhile, the average American spends $219/month on subscriptions — $133 more than they think they do, according to C+R Research.

The Worst Offenders: Companies That Still Make Canceling Impossible

Without the FTC rule, these companies continue to use dark patterns to trap customers:

🔴 Requires Phone Call to Cancel

• SiriusXM — infamous for aggressive retention calls
• AAA — must call, can't cancel online
• Xfinity — phone or in-store only for most services

🔴 Requires In-Person Visit

• Planet Fitness — must visit in person or send certified mail
• Gold's Gym — same in-person requirement
• LA Fitness — certified mail or in-person

🔴 Uses "Retention Maze" Dark Patterns

• Adobe Creative Cloud — early termination fee up to 50% of remaining subscription
• New York Times — must chat with agent, multiple "are you sure?" screens
• Amazon Prime — paid $1 billion in FTC settlement over dark pattern signups

See our full Dark Patterns Hall of Shame ranking the 15 worst companies.

What Can You Actually Do in 2026?

Without federal protection, you're on your own. But there are concrete steps:

1. Find Every Subscription You're Paying For

Most people have 3-5 subscriptions they've completely forgotten about. Upload your bank statement to JustCancel and we'll find every recurring charge in seconds — plus give you direct cancel links for each one.

2. Use Direct Cancel Links

Many companies bury their cancel page deep in their settings. We maintain direct cancel links for 1,100+ services so you can skip straight to the cancellation page.

3. Know Your Rights by State

While the federal rule failed, California's automatic renewal law (ARL) still requires companies to provide an online cancellation method for California residents. Several other states have similar protections:

• California — must offer online cancellation
• New York — requires clear cancellation disclosures
• Illinois — automatic renewal disclosure requirements
• Vermont — one of the strongest consumer protection states

4. Dispute Unauthorized Charges

If a company won't let you cancel and keeps charging you, you have the right to dispute the charge with your bank. Under the Fair Credit Billing Act, you have 60 days to dispute unauthorized recurring charges.

5. Document Everything

Screenshot your cancellation attempts. If a company makes it unreasonably difficult, you can file complaints with:

• Your state attorney general
• The FTC (they still investigate individual companies)
• The CFPB
• The Better Business Bureau

The Bottom Line

The click-to-cancel rule was the most consumer-friendly regulation proposed in years. It was killed by the same companies that profit from making cancellation difficult.

Until Congress acts (don't hold your breath), the best defense is knowing exactly what you're paying for and having the tools to cancel quickly. That's exactly why we built JustCancel — upload a bank statement, see every subscription, get cancel links. $5 once, no recurring fee. Because at least one company should make it easy.