Written & reviewed by External Legal AI · Published July 2, 2026
Yes — and if the company makes it hard, the law is still mostly on your side, just not the law most articles describe. The FTC's much-publicized "click-to-cancel" rule was struck down by a federal appeals court in July 2025 before its cancellation requirements ever took effect. What actually protects you today is an older federal statute called ROSCA, a growing stack of state auto-renewal laws, and your card's dispute rights when charges keep landing after you cancel.
Status check — as of 2026-07-02
FTC click-to-cancel rule (2024 Negative Option Rule) — vacated by a federal court
The Eighth Circuit struck the rule down on July 8, 2025 — days before its cancellation provisions were to take effect — so its cancel-as-easily-as-you-signed-up mandate never became enforceable, though the FTC opened a new rulemaking in 2026 to replace it. Custom Communications, Inc. v. FTC, No. 24-3137 (8th Cir. July 8, 2025)
ROSCA (federal law on online subscription sign-ups) — in effect
The Restore Online Shoppers' Confidence Act still requires clear disclosure, your express consent before recurring charges, and a simple mechanism to stop them — it's the law behind the FTC's $2.5 billion Amazon Prime settlement in September 2025. 15 U.S.C. § 8403 — Restore Online Shoppers' Confidence Act
State auto-renewal laws — in effect
A growing majority of states have their own auto-renewal statutes — California's, among the strongest, requires an online cancellation path for online sign-ups — and they apply regardless of what happened to the federal rule. Cal. Bus. & Prof. Code § 17602 — Automatic renewal offers
The FTC's 2024 Negative Option Rule would have required sellers to make canceling as easy as signing up. On July 8, 2025 — days before the cancellation provisions kicked in — the Eighth Circuit vacated the entire rule on procedural grounds, so that one-click mandate isn't enforceable law. The FTC started a fresh rulemaking in 2026, but for now there is no single federal easy-cancel requirement.
The Restore Online Shoppers' Confidence Act, on the books since 2010, still governs online subscription sign-ups: the seller must clearly disclose the recurring charge before taking your billing information, get your express informed consent, and provide a simple mechanism to stop the charges. The FTC enforces it aggressively — Amazon paid $2.5 billion in 2025 to settle claims over its Prime enrollment and cancellation flow.
Most states now have automatic-renewal statutes, and several are stronger than federal law: California requires an online cancellation method for anything you signed up for online, and a number of states require reminder notices before a renewal or after a free trial converts. These state laws were untouched by the federal rule's vacatur — they're the live protection, enforced by state attorneys general and, in some states, private lawsuits.
Use the cancellation path the service advertises, and screenshot the confirmation screen or save the confirmation email — the date matters. If no path works (dead links, endless chat queues, 'call to cancel' lines that never answer), cancel in writing to the company's support or billing address and keep a copy. A documented cancellation attempt is what turns later charges into disputable ones.
Charges billed after a documented cancellation are disputable. On a credit card, the Fair Credit Billing Act gives you at least 60 days from the statement containing the charge to dispute it in writing. On a debit card or bank account, federal law lets you revoke authorization for recurring electronic payments and place a stop-payment order with your bank. Say the same thing to both: 'I canceled on this date — these charges are unauthorized.'
Subscription traps — hidden auto-renewals, free trials that convert silently, cancellation mazes — are classic unfair-practice territory. Reports to ReportFraud.ftc.gov and your state attorney general build the enforcement record, and a company facing a state UDAP claim often refunds quickly once a complaint is documented.
More on this topic: the Consumer Rights hub
NotALawyer.com provides general legal information, not legal advice.