🔒 Click-to-Cancel Suspended: The Right to Cancel at Risk in the US

Botão de cancelamento em destaque representando simplicidade e transparência ( Featured cancel button representing simplicity and transparency)

Do you still have control over your subscriptions?

Imagine subscribing to a service with one click... only to discover that to cancel, you have to call, wait in line, persist with a customer service representative, fill out forms, and then receive persistent offers to continue. Frustrating, right?

It was precisely to put an end to this type of practice that the Federal Trade Commission (FTC) proposed the click-to-cancel rule : a measure that required companies to make it as easy to cancel subscriptions as it was to sign up. But, to the surprise of many, this rule was suspended by the US courts before it even took effect .

Understand the proposal: what was the click-to-cancel rule?

The FTC's initiative stated that any subscription or auto-renewal plan could only continue if the consumer had access to a simple, direct, and equivalent method to cancel it. This included:

• A clear cancellation button on the website where the purchase was made;

• The prohibition of labyrinthine paths , such as redirections to call centers or insistent chatbots;

• Requirement for explicit customer consent prior to renewal.

In short: a regulatory advance in consumer protection, especially given the explosion of subscription services in recent years (streaming, product clubs, software, etc.).

Why was the click-to-cancel rule suspended?

Despite being widely supported by consumers and experts, the rule was suspended by a decision of the Court of Appeals for the 8th Circuit , in the United States, based on procedural flaws - and not on the merits of the proposal.

The central legal argument was that the FTC failed to conduct a prior economic analysis , which is mandatory for regulations with a financial impact exceeding $100 million annually. The substance of the rule was not rejected; what failed was the technical approval procedure (CHURNKEY, 2025).

What changes with the suspension of click-to-cancel?

With the overturn, the FTC will no longer be able to enforce the rule nationally , and companies are no longer required to modify their systems to allow for easy cancellations — at least for now.

However, some state laws, such as those in California and Massachusetts , continue to require similar practices. In other words, consumers residing in certain states are still protected by local laws, but the rest of the country remains in a kind of legal limbo.

The impact on the consumer: setback or opportunity?

This suspension, for many experts, is a step backward in the fight for greater transparency in consumer relations. Subscriptions that automatically renew without clear authorization, intentionally complicated cancellation systems, and unclear terms of use remain common abusive practices in the United States.

Organizations such as the Electronic Frontier Foundation and the National Consumers League lamented the court decision, highlighting the risk of undermining public trust in online services (WIRED, 2025).

Is there a future for click-to-cancel?

Yes. The FTC can:

1. Appeal the court decision ;

2. Rewrite the proposal , including the required economic analysis;

3. Or wait for Congressional legislation to make the rule legally valid.

Meanwhile, companies that want to maintain customer trust can voluntarily adopt click-to-cancel standards, even without formal obligation.

What can the consumer do?

If you live in the United States, here are some practical tips to avoid falling into these traps:

✅ Prefer services with direct cancellation on the website;

✅ Read the renewal terms before entering your payment details;

✅ Save and record all stages of contracting and cancellation;

✅ Report abusive practices to the FTC or state agencies.

Companies also have a lot to lose

For companies, following standards of clarity and simple cancellation isn't just a future legal requirement—it's a matter of reputation . Consumers dissatisfied with confusing processes don't return. And a bad image spreads quickly online.

Offering easy cancellation can even reduce churn in the long run , as it increases the perception of trust and respect for the customer.

Recommended products and courses

🛒 On Amazon

1. 🔹 Echo Dot (5th Gen) – Use voice commands to manage services and subscriptions.

2. 🔹 Book: “The Membership Economy” – Understand the logic behind subscription services.

3. 🔹 Acer Aspire 5 Notebook – Ideal for digital account control.

🧠 At Hotmart

1. 📘 Course: Total Control of Your Digital Consumption – Learn how to organize subscriptions, reduce expenses and avoid pitfalls.

2. 📗 E-book: “ How to Cancel Any Online Service ” – Practical and updated guide.

3. 🎓 Workshop: Conscious Consumption in the Digital Age – With legal support.

Conclusion: Click-to-cancel may have been suspended, but the fight continues

Although the court ruling has frozen the FTC's rule, the issue remains urgent. The suspension of the click-to-cancel rule does not eliminate the need to protect consumers. On the contrary, it reinforces the importance of well-founded regulations and companies committed to transparent relationships.

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📚 References

CHURNKEY. FTC's Click-to-Cancel Rule Is Officially Dead (for now) . Churnkey, July 11, 2025. Available at: https://churnkey.co/blog/ftc-click-to-cancel . Accessed on: July 15, 2025.

FTC – Federal Trade Commission. FTC Proposes “Click to Cancel” Requirement for Subscription Services . Washington, DC, March 23, 2023. Available at: https://www.ftc.gov/news-events/news/press-releases/2023/03/ftc-proposes-click-cancel-requirement-subscription-services . Accessed: July 15, 2025.

FTC – Federal Trade Commission. Negative Option Rule Final Text . 2024. Available at: https://www.ftc.gov/legal-library/browse/federal-register-notices . Accessed on: July 15, 2025.

WIRED. The FTC's Click to Cancel Rule Could Be Good for Consumers—If It Survives . Wired, March 25 2023. Available at: https://www.wired.com/story/ftc-click-to-cancel-rule/ . Accessed on: 15 Jul. 2025.

NATIONAL CONSUMERS LEAGUE. Consumers Deserve a Way Out: Support for Click-to-Cancel . NCL, 2024. Available at: https://nclnet.org/click-to-cancel . Accessed on: July 15, 2025.

ELECTRONIC FRONTIER FOUNDATION. Digital Consumer Rights and Cancel Culture: Why Click-to-Cancel Matters . EFF, 2024. Available at: https://www.eff.org/issues/click-to-cancel . Accessed on: July 15, 2025.