The FTC Negative Option Rule, better known as Click to Cancel, would have required online sellers of subscriptions to disclose renewal terms clearly, get separate consent to the negative option feature, and offer cancellation as easy as signup.
Why the FTC Negative Option Rule Was Rolled Back
The Eighth Circuit vacated the 2024 rule on procedural grounds on July 8, 2025, days before its main compliance date. In February 2026 the FTC formally revised Part 425 back to the narrow 1973 prenotification rule, which covers only prenotification book and merchandise clubs. The FTC has since started a new rulemaking to replace the vacated rule, so similar requirements are likely to return.
What Still Applies to Subscription Websites
Websites selling subscriptions are not off the hook. The Restore Online Shoppers’ Confidence Act (ROSCA, 15 U.S.C. 8401 et seq.) still requires clear disclosure of terms, informed consent before charging, and a simple online cancellation mechanism, and the FTC and state attorneys general actively enforce it. State auto-renewal laws such as California’s also continue to apply, so subscription checkout flows still need clear terms and easy cancellation today.
Source: U.S. Government Publishing Office: 16 CFR Part 425
Report a violation: If you believe a business is violating this law, you can file a complaint at FTC Fraud Report.
