Click to cancel rule revived

Photo Credit: Spotify

Lawmakers are once again pushing to enact the Click-to-Cancel Consumer Protection Act, aiming to resurrect the Federal Trade Commission (FTC) previously halted.

This comes just weeks after a federal appellate court blocked the FTC’s ‘click-to-cancel’ regulation, citing procedural errors in its rule-making process. The rule was set to take effect on July 14, 2025 and would have required companies to allow customers to cancel a subscription as easily as they can sign up.

The rule was part of the FTC’s crackdown on so-called ‘negative opinion’ marketing, sought to address unfair and deceptive practices that trap consumers in unwanted recurring payments. Many digital businesses use redirects, pauses, or multiple screens that make it harder to cancel than to subscribe to their services. The regulation was designed to make clear disclosures mandatory and to streamline the cancellation process.

However, the U.S. Court of Appeals for the Eighth Circuit determined that the FTC failed to conduct a legally required preliminary regulatory analysis, which is essential for rules projected to impact the national economy by over $100 million. In response, Democratic lawmakers including Seth Magaziner (RI-2) and Brad Sherman (CA-32) have introduced a new bill in Congress to codify the rule.

Most music subscription services like Amazon Music, Apple Music, and Spotify are less likely to be affected by these proceedings. These DSPs offer a straight-forward cancellation process without retention measures intended to re-route the customer from subscribing. Services like SiriusXM and TuneIn may be impacted, since those services offer those seeking to cancel Premium memberships the ability to pause instead.

“An examination of over 16,000 public comments clearly indicates what should be evident: Businesses should not be permitted to entrap consumers in expensive subscriptions by complicating the cancellation process—wasting consumers’ time and money while hindering competition,” wrote Sen. Klobuchar and six other lawmakers in a letter urging swift reinstatement of the rule.