The FTC's click-to-cancel rule, set to go into effect July 14, was vacated on July 8 due to a procedural error.

Closeup of a Cancel process on a computer screen

Subscription models are rising but many stay stuck in unwanted plans due to deceptive sign-ups and hard cancellations.

Key Takeaways

Questionable practices have become common among sellers of subscription-based services.
A new rule would have required sellers to make canceling subscriptions as easy as signing up for them, but it was vacated at the last minute.
To help prevent unwanted subscriptions, audit your accounts monthly, use a subscription tracker, set calendar reminders for free trials and use one payment method for all your subscriptions.

Subscription-based business models have become increasingly popular in recent years. According to a 2024 Bango survey of 5,000 U.S. subscribers, the average subscriber has 4.5 subscriptions, which cost them a total of $77 per month.

But there's a growing problem – many Americans find themselves enrolled and paying for recurring subscription plans they don't want. This is often the result of "negative option" programs (where silence or inaction counts as consent) and tedious cancellation processes.

"I'm not a fan of this at all, and it's one of many reasons why I dedicate so much time to enhancing financial literacy. Business models that rely on customers to be lazy are just wrong to begin with," Jake Falcon, the founder and CEO of Falcon Wealth Advisors, said in an email.

The Federal Trade Commission recently decided it was time to modernize its Negative Option Rule from 1973 and offer American consumers more protection regarding subscriptions. Unfortunately, it was vacated in the eleventh hour.

New Click-to-Cancel Ruling Was Vacated

In October 2024, after receiving more than 16,000 comments from the public, the FTC announced a final click-to-cancel rule.

The new rule amended several aspects of the Negative Option Rule, including requiring sellers to make cancelling a subscription as easy as signing up for one. If you were able to sign up for a subscription online with a click, for example, you should be able to cancel it online with a click.

While the new rule was set to go into effect on May 14, 2025, it was pushed back 60 days to July 14, 2025. Then, on July 8, 2025, it was vacated by the U.S. Court of Appeals for the Eighth Circuit due to a procedural error.

"The FTC's click-to-cancel rule could have improved consumers’ experiences with subscription-based services, memberships and other recurring payment programs. It was designed to ensure fairness and transparency in billing for consumers," Michael Podolsky, CEO and co-founder of PissedConsumer.com, said in an email.

"On our platform, we’ve seen hundreds of reviews where users described how difficult, and even impossible, it is to cancel subscriptions with some service providers. This rule could have been a major step toward protecting users from unclear and often tricky cancellation practices," he said.

What This Means for Americans With Subscriptions

With the new click-to-cancel rule off the table – for now – consumers are left vulnerable to subscription providers that continue to use deceptive practices.

"Subscription-based business models often rely on inertia, making it easy to sign up but difficult to cancel. Without this rule, many Americans will continue to overpay for services they no longer use or need," Falcon said.

When you go to cancel a subscription, for example, you may have to click through multiple pages, answer numerous questions, call in to cancel or select all the services you want to unsubscribe from individually.

Chad Gammon, certified financial planner and owner of Custom Fit Financial, shared a similar sentiment. "I feel like it is a loss for Americans. Subscriptions are easy to forget and difficult to cancel. This rule would have made it easier for consumers to control their subscriptions," he said in an email.

However, if you're struggling with managing subscriptions, there are steps you can take to protect yourself. Falcon suggested the following:

Audit your accounts monthly: Review your bank and credit card statements for recurring charges. You’d be surprised how many “zombie subscriptions” are hiding in plain sight.
Use a subscription tracker: Apps like Rocket Money can help identify and manage recurring expenses.
Set calendar reminders: If you sign up for a free trial, set a reminder to cancel before the billing date.
Use one payment method: Consolidating subscriptions on a single card makes them easier to track and manage.

These steps can help you identify when you're subscribed to a service, and then keep it top of mind so you can promptly cancel it when you no longer need it.

What's Next for the Click-to-Cancel Rule?

There is a need and demand to update legislation around subscriptions, and this rule came very close to passing. Hopefully it'll come around again once the procedural hang-up is resolved.

"The FTC may reconsider this issue in the future and suggest updating guidelines to protect consumers from deceptive billing practices. In the meantime, American consumers should keep a watchful eye on their bank statements and regularly check subscription charges to avoid paying for services they no longer want or need," Podolsky said.

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Click-to-Cancel Could've Made Canceling Subscriptions Easier: Here's How to Protect Yourself Without It