The Federal Trade Commission is pushing to revive rules that would have forced companies to make it just as easy to cancel a subscription as it is to sign up for one. The effort comes after a federal appeals court threw out the agency’s original rule last year on a technicality, not because the underlying idea was wrong, but because the FTC did not follow the proper steps when writing the rule.
On July 8, 2025, the U.S. Court of Appeals for the Eighth Circuit struck down what had become known as the “Click-to-Cancel” rule. The rule would have required businesses offering subscriptions and automatic renewals to streamline the cancellation process and be more upfront with customers about what they were signing up for. The court didn’t disagree with the rule’s goals. Instead, it found that the FTC had failed to follow mandatory procedural requirements under the Administrative Procedures Act. Essentially, the agency skipped steps in its own rulebook
The FTC did not wait long to respond. On January 30, 2026, the agency announced it had submitted a draft notice to the Office of Management and Budget, a required step before any major new federal rule can move forward. The two sitting FTC commissioners each approved the submission. That kind of agreement is notable, as it signals the agency is serious about seeing this through.
Related: Reports of ‘Click-to-Cancel’s Death May Be Premature
Washington law firm Crowell & Moring, which has been closely tracking the case, described the moment plainly: “The submission of the draft [Advanced Notice of Proposed Rulemaking] signals that renewed federal regulation is forthcoming.”
So what happens next? The process is lengthy. Once the OMB finishes its review, the FTC will publish the notice publicly and open a comment period lasting 60 to 90 days. After that, the agency will publish its actual proposed rule text and open another comment period of 30 to 90 days. Reviewing all those public comments could take months. Formal hearings could push the timeline out even further.
The original Click-to-Cancel rule took about three years to become final. This time around, the FTC is expected to move more carefully to avoid the procedural missteps that got the first rule thrown out. That means businesses may have more time before a final rule lands. But they shouldn’t get too comfortable. As Crowell & Moring noted, the FTC still has tools it can use right now. The agency can go after deceptive subscription practices under its existing authority, including Section 5 of the FTC Act and the Restore Online Shoppers’ Confidence Act, without waiting for a new rule to be finalized.
For companies that offer subscriptions (think software platforms, media services, e-commerce retailers, and beyond) this is a moment to pay attention. The regulatory direction is clear, even if the exact finish line is still a few years away.
The exchange for the debt economy
Have you ever signed up for a free trial, forgotten about it, and then watched a charge quietly appear on your credit card months later? You’re not alone. Canceling subscriptions from streaming services to gym memberships to software tools can feel intentionally hard. The federal government tried to fix that. A court stepped in and blocked it. Now the government is trying again.