The FTC's Click-to-Cancel Rule Is Dead. Your State's Isn't

The rule was supposed to be simple: if a company lets you sign up for a subscription with one tap, it has to let you cancel with one tap. On July 8, 2025, a federal appeals court threw it out. That didn't end the fight over subscription cancellations. It just scattered it across a dozen statehouses.

The Eighth U.S. Circuit Court of Appeals vacated the Federal Trade Commission's "click-to-cancel" rule days before it was set to take effect, ruling that the agency skipped a legally required economic-impact analysis before finalizing it. The court never touched the substance of the rule — whether canceling a subscription should be as easy as buying one. It only struck down the process that produced it. That distinction is why the idea didn't die with the ruling.

It just moved to Hartford, Albany, Baton Rouge and, this month, New York City.

Connecticut just became the newest state with the rule

On July 1, a Connecticut law took effect requiring companies to notify consumers before an automatic renewal kicks in and to give them a cancellation process no harder than the sign-up process. Attorney General William Tong laid out the rule at a press conference in Hartford on July 12, flanked by the state's consumer protection commissioner and two legislative leaders.

"Businesses don't get to profit by trapping consumers in subscriptions they no longer want. Connecticut is putting consumers back in control with strong new 'click to cancel' rights. Businesses that fail to comply may be engaging in unfair trade practices, and we will not hesitate to enforce the law."

William Tong, Connecticut Attorney General

Violations fall under the state's Unfair Trade Practices Act, which allows fines on top of any refunds owed. Public utilities, internet providers, banks and insurance companies are exempted. Senate Majority Leader Bob Duff, at the same press conference, put the state's position more bluntly than most officials bother to: We are no longer waiting for Congress. We have abandoned that many years ago.

Which states have their own click-to-cancel laws?

Connecticut is not an outlier. It's the sixth or seventh entry in a list that's grown fast since the federal rule collapsed. Arkansas, Massachusetts, New York and Maine all passed their own versions between last August and January; Colorado tightened its existing automatic-renewal law the same month Arkansas' took effect. Minnesota requires any business offering an online account to also offer online cancellation. Louisiana's version, the "Click to Cancel Act," doesn't arrive until January 1, 2027, and carves out an exemption for businesses under 50 employees or under $5 million in annual revenue, a carve-out none of the earlier states bothered with.

New York City added its own penalty schedule on top of the state's

New York City's Department of Consumer and Worker Protection finalized a local click-to-cancel rule that takes effect October 1, mirroring the state law's disclosure and cancellation requirements but adding its own enforcement layer. A business found in violation is on the hook for the amount charged after a customer's first attempt to cancel, plus civil penalties that escalate: $525 for a first violation, $1,050 for a second, $3,500 for a third and beyond. The city estimates the rule will save residents up to $162.5 million a year: real money for people who forgot to cancel a streaming trial or a meal-kit box, multiplied across 8.3 million residents.

Is the FTC's click-to-cancel rule still in effect?

No — but the agency hasn't abandoned it, either. On January 30, the FTC opened a new rulemaking process aimed at fixing the procedural defect the Eighth Circuit flagged, rather than rewriting the rule's substance. Public comments on that advance notice closed April 13. Companies watching the docket generally expect any revived rule to look close to the one that got thrown out, just with the economic-impact paperwork attached this time. In the meantime, the commission is still bringing enforcement actions over autorenewal practices under existing consumer-protection law. The rule is gone; the agency's interest in the subject isn't.

What happens if a company won't let you cancel online?

It depends entirely on your zip code, which is the strange part of where this has landed. A subscriber in California or Maine has had cancellation protections on the books for a while. A subscriber in Connecticut got them this month. A subscriber in most of the remaining states is still relying on a credit-card dispute or a call center's patience, because no state or federal rule requires anything different yet.

None of the state laws requires identical mechanics. Louisiana's version, unusually, doesn't specifically mandate online cancellation at all; it just bars a company from making the process "unreasonably burdensome," which leaves phone and email as acceptable alternatives. That's a lower bar than New York's or Connecticut's, and it's already drawing criticism from consumer advocates who wanted a uniform standard rather than eight slightly different ones.

It's part of a broader pattern of the FTC losing rulemaking fights in court and states picking up the pieces. The commission's separate rule on hidden ticket and hotel fees has faced its own compliance fights, and its drip-pricing crackdown only ended up covering two industries after industry pushback carved out the rest. Subscription cancellation is just the newest front in the same fight over who gets to define "unfair" pricing practices: Washington or each state capital on its own.

What that patchwork means in practice: read your state's rule before assuming a national standard protects you, because for now, there isn't one.