Why Canceling a Subscription Still Isn't Easy
The FTC's click-to-cancel rule was struck down in 2025 and still hasn't come back — which is why quitting some subscriptions still means picking up the phone.
Amazon just finished paying out part of a $2.5 billion settlement for making Prime too hard to quit. The claims window closed July 27. And the federal rule that was supposed to make every subscription that easy to cancel everywhere else? It doesn't exist. It got thrown out by a court in 2025, and more than a year later, it still hasn't come back.
That gap is why some streaming services, gym memberships and software subscriptions still make you call a phone line, sit on hold, and talk a representative out of keeping your money — while others let you cancel in two taps. The difference isn't really about customer service philosophy. It's about which federal and state rules happen to apply to that specific company, and whether the FTC's stalled "click-to-cancel" rule ever survives its second attempt.
What happened to the FTC's click-to-cancel rule?
The FTC finalized the rule in October 2024, after more than 16,000 public comments. It would have required that canceling a subscription take no more effort than signing up for one — if you subscribed with two clicks online, the FTC said, canceling should take two clicks, not a phone call. Too often, businesses make people jump through endless hoops just to cancel a subscription,
then-Chair Lina Khan said when the rule was announced. Nobody should be stuck paying for a service they no longer want.
It never took effect. In 2025, the U.S. Court of Appeals for the Eighth Circuit vacated the rule entirely, ruling that the FTC hadn't completed the economic-impact analysis federal law requires before adopting a rule of that size. The vote to finalize it in the first place had been close, 3-2, with commissioners Melissa Holyoak and Andrew Ferguson dissenting — Ferguson now chairs the agency that's trying to bring a version of it back.
Is there any rule protecting subscribers right now?
A narrower one. The Restore Online Shoppers' Confidence Act, a 2010 law usually called ROSCA, still requires online sellers to disclose subscription terms clearly, get a customer's affirmative consent before charging them, and provide a "simple mechanism" to stop the charges. But ROSCA only covers transactions made online, and it never defines what counts as "simple" — which leaves plenty of room for a company to argue that a mandatory retention call qualifies.
The FTC has leaned on that gap and on Section 5 of its own founding statute, which bars "unfair or deceptive" business practices generally, to keep pursuing companies even without the vacated rule in force. It won an $8.5 million settlement against Care.com in 2024 over billing and cancellation practices, then followed with the Amazon case: a $1 billion civil penalty plus $1.5 billion in refunds to an estimated 35 million customers the agency said had been enrolled in Prime without clear consent or blocked from canceling it, the largest civil penalty the FTC has ever collected for a rule violation. In a newer case against the telehealth company NextMed, the agency alleged the same three failures the vacated rule targeted — poor disclosure, no real consent, hard-to-find cancellation — simply repackaged as ordinary Section 5 violations.
The subscription business itself is worth the fight. Streaming, software, meal kits, supplement clubs and gym memberships together generate tens of billions of dollars a year in recurring US revenue, and every retained subscriber who meant to cancel but didn't is pure margin.
Will click-to-cancel come back?
Maybe, but not the same way. In March 2026 the FTC's Bureau of Consumer Protection opened a new rulemaking process — an Advance Notice of Proposed Rulemaking, the step before a formal draft rule — asking whether to revive pieces of the vacated version, write something narrower, or carve out different treatment for different industries. Comments closed April 13; the agency is still working through them, and any new rule would need to clear the same economic-analysis requirement that sank the last one.
Until then, the safest assumption for a subscriber is the same one that applied before 2024: check your state law first. California's Automatic Renewal Law, for instance, already requires an annual reminder disclosing the renewal date, the price and how to cancel — protections a lot of the rest of the country doesn't have. Everywhere else, the honest answer to "why do I have to call to cancel this" is: because right now, mostly, a company still can make you.
Daybreak Wire has tracked other quiet consumer-protection gaps this year, including why some gift cards expire and others don't depending entirely on which state you're standing in when you buy one.
