Click-to-cancel: Difference between revisions

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The '''click-to-cancel''' (CtC) rule is a [[Federal Trade Commission]] (FTC) rule, specifically [https://www.ecfr.gov/current/title-16/chapter-I/subchapter-D/part-425/section-425.6 16 CFR Part 425.6], which requires that subscription services make it as easy to cancel the service as it was to sign up.<ref>{{Cite web |date=16 Oct 2024 |title=Federal Trade Commission Announces Final “Click-to-Cancel” Rule Making It Easier for Consumers to End Recurring Subscriptions and Memberships |url=https://www.ftc.gov/news-events/news/press-releases/2024/10/federal-trade-commission-announces-final-click-cancel-rule-making-it-easier-consumers-end-recurring |website=Federal Trade Commission |url-status=live |archive-url=http://web.archive.org/web/20260206202338/https://www.ftc.gov/news-events/news/press-releases/2024/10/federal-trade-commission-announces-final-click-cancel-rule-making-it-easier-consumers-end-recurring |archive-date=6 Feb 2026}}</ref> This is designed to combat an anti-consumer practice, where a subscription service makes it very easy to sign up for a service, but requires the customer to jump through hoops to cancel the subscription. The law has been finalized and was initially set to go into effect May 14, 2025.<ref>{{Cite web |date=15 Nov 2024 |title=Federal Trade Commission,16 CFR Part 425, RIN 3084-AB60 |url=https://www.federalregister.gov/documents/2024/11/15/2024-25534/negative-option-rule#p-6 |website=Federal Register |url-status=live |archive-url=http://web.archive.org/web/20250515052212/https://www.federalregister.gov/documents/2024/11/15/2024-25534/negative-option-rule |archive-date=15 May 2025}}</ref> On July 8, the U.S. Court of Appeals for the Eighth Circuit blocked the click-to-cancel provision, reasoning that the FTC erred by not first conducting a preliminary regulatory analysis of the rule's costs and benefits. The analysis must be conducted on any rules that impact the economy by more than $100 million. The FTC can still petition the Supreme Court to review the decision through October 6, 2025 <ref>{{Cite web |last=Fouse-Hopkins |first=Lindsay |date=2025-07-17 |title=Eighth Circuit blocks Click-to-Cancel Rule |url=https://www.clarkhill.com/news-events/news/eighth-circuit-blocks-click-to-cancel-rule/ |url-status=live |access-date=2025-07-17 |website=Clarkhill.com |archive-url=http://web.archive.org/web/20251207032751/https://www.clarkhill.com/news-events/news/eighth-circuit-blocks-click-to-cancel-rule/ |archive-date=7 Dec 2025}}</ref>

==How it works==

The rule prohibits the following:<ref>{{Cite web |date=2024 |title=The FTC’s “Click to Cancel” Rule |url=https://www.ftc.gov/system/files/ftc_gov/pdf/NegOptions-1page-Oct2024-v2.pdf |website=Federal Trade Commission |url-status=live |archive-url=http://web.archive.org/web/20251122050657/https://www.ftc.gov/system/files/ftc_gov/pdf/NegOptions-1page-Oct2024-v2.pdf |archive-date=22 Nov 2025}}</ref><ref name=":0">https://www.govinfo.gov/content/pkg/FR-2024-11-15/pdf/2024-25534.pdf</ref>

The rule prohibits the following:<ref>{{Cite web |date=2024 |title=The FTC’s “Click to Cancel” Rule |url=https://www.ftc.gov/system/files/ftc_gov/pdf/NegOptions-1page-Oct2024-v2.pdf |website=Federal Trade Commission |url-status=live |archive-url=http://web.archive.org/web/20251122050657/https://www.ftc.gov/system/files/ftc_gov/pdf/NegOptions-1page-Oct2024-v2.pdf |archive-date=22 Nov 2025}}</ref><ref name=":0">https://www.govinfo.gov/content/pkg/FR-2024-11-15/pdf/2024-25534.pdf ([http://web.archive.org/web/20251124053133/https://www.govinfo.gov/content/pkg/FR-2024-11-15/pdf/2024-25534.pdf Archived])</ref>

*to misrepresent any material fact made while marketing using a negative option feature

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A "negative-option feature" is defined by the FTC as "a provision in an offer or agreement to sell or provide any goods or services 'under which the customer’s silence or failure to take an affirmative action to reject goods or services or to cancel the agreement is interpreted by the seller as acceptance of the offer'".<ref name=":0" /> In other words, it is a feature of a service, where once a subscription is initiated, the customer will continue to be billed until they actively cancel the subscription.

The click-to-cancel rule is not limited to electronic services, as the name might suggest. It includes, but is not limited to "Interactive Electronic Media, telephone, print, and in-person transactions."<ref>https://www.federalregister.gov/documents/2024/11/15/2024-25534/negative-option-rule#sectno-citation-425.1 ([http://web.archive.org/web/20250515052212/https://www.federalregister.gov/documents/2024/11/15/2024-25534/negative-option-rule Archived])</ref> The cancellation mechanism must be "at least as simple as consent".<ref>https://www.federalregister.gov/d/2024-25534/p-1164</ref> The customer may not be required to interact with a representative, whether a real human or a chat bot, if the customer was not required to do so when they signed up for the service.<ref>https://www.federalregister.gov/d/2024-25534/p-1166</ref> For services which were signed up for in-person, the seller must allow cancellation online or over the phone.<ref>https://www.federalregister.gov/d/2024-25534/p-1168</ref>

The click-to-cancel rule is not limited to electronic services, as the name might suggest. It includes, but is not limited to "Interactive Electronic Media, telephone, print, and in-person transactions."<ref>https://www.federalregister.gov/documents/2024/11/15/2024-25534/negative-option-rule#sectno-citation-425.1 ([http://web.archive.org/web/20250515052212/https://www.federalregister.gov/documents/2024/11/15/2024-25534/negative-option-rule Archived])</ref> The cancellation mechanism must be "at least as simple as consent".<ref>https://www.federalregister.gov/d/2024-25534/p-1164 ([https://web.archive.org/web/20260223034631/https://unblock.federalregister.gov/ Archived])</ref> The customer may not be required to interact with a representative, whether a real human or a chat bot, if the customer was not required to do so when they signed up for the service.<ref>https://www.federalregister.gov/d/2024-25534/p-1166 ([https://web.archive.org/web/20260223034652/https://unblock.federalregister.gov/ Archived])</ref> For services which were signed up for in-person, the seller must allow cancellation online or over the phone.<ref>https://www.federalregister.gov/d/2024-25534/p-1168 ([https://web.archive.org/web/20260223034713/https://unblock.federalregister.gov/ Archived])</ref>

==Examples of abuse==

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====Planet Fitness====

Prior to state-level laws, Planet Fitness's FAQ stated that "You can fill out a cancellation form at the front desk of your home club, or send a letter (preferably via certified mail) to your club requesting cancellation. Memberships can’t, unfortunately, be cancelled by email or phone"<ref>{{Cite web |title=Frequently Asked Questions |url=https://www.planetfitness.com/about-planet-fitness/customer-service#region-faq-accordion-0 |website=Planet Fitness |url-status=live |archive-url=http://web.archive.org/web/20260101164213/https://www.planetfitness.com/about-planet-fitness/customer-service |archive-date=1 Jan 2026}}</ref>{{UpdateNeeded|date=October 2025|reason=The FAQ has changed since the initial writing of this article version.}} despite allowing online signups. As of Jan 18, 2025, its terms state "our cancellation process may vary from club to club", and that "Some members may also be eligible to cancel their membership online based on their membership type and the location of their home club."<ref>https://archive.ph/~~XSG0Q~~</ref>

Prior to state-level laws, Planet Fitness's FAQ stated that "You can fill out a cancellation form at the front desk of your home club, or send a letter (preferably via certified mail) to your club requesting cancellation. Memberships can’t, unfortunately, be cancelled by email or phone"<ref>{{Cite web |title=Frequently Asked Questions |url=https://www.planetfitness.com/about-planet-fitness/customer-service#region-faq-accordion-0 |website=Planet Fitness |url-status=live |archive-url=http://web.archive.org/web/20260101164213/https://www.planetfitness.com/about-planet-fitness/customer-service |archive-date=1 Jan 2026}}</ref>{{UpdateNeeded|date=October 2025|reason=The FAQ has changed since the initial writing of this article version.}} despite allowing online signups. As of Jan 18, 2025, its terms state "our cancellation process may vary from club to club", and that "Some members may also be eligible to cancel their membership online based on their membership type and the location of their home club."<ref>https://www.planetfitness.com/about-planet-fitness/customer-service#region-faq-accordion-0 ([https://web.archive.org/web/20260405060509/https://www.planetfitness.com/about-planet-fitness/customer-service#region-faq-accordion-0 Archived])</ref>

As of June 10, 2025, Planet Fitness (https://www.planetfitness.com/) requires billing (credit card and bank account) information before clearly and conspicuously disclosing material terms of its negative option in violation of [https://www.ecfr.gov/current/title-16/chapter-I/subchapter-D/part-425 FTC 16 CFR Part 425.4].

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"Free-to-pay" is a technical term for free trials with a negative-option feature.<ref>https://www.ftc.gov/system/files/documents/public_statements/1598063/negative_option_policy_statement-10-22-2021-tobureau.pdf ([http://web.archive.org/web/20251209002749/https://www.ftc.gov/system/files/documents/public_statements/1598063/negative_option_policy_statement-10-22-2021-tobureau.pdf Archived])</ref> In many cases, rather than providing a free trial with no strings attached, and only billing the customer if they decide to sign up, the vendor collects payment information as a prerequisite of the free trial, and automatically bills the customer if they fail to affirmatively cancel the trial (a negative-option feature).

While it does not outright prohibit this practice, the click-to-cancel rule partially alleviates these issues by requiring clear disclosures and consent. According to state AGs, "advertisements for free-to-pay conversion offers often lure consumers by promising a 'free' benefit while failing to clearly and conspicuously disclose future payment obligations".<ref>https://www.federalregister.gov/d/2023-07035/p-83</ref> The FTC also states that:<ref>https://www.federalregister.gov/d/2023-07035/p-87 ([https://web.archive.org/web/20260216014934/https://unblock.federalregister.gov/ Archived])</ref><blockquote>Other studies reveal similar trends. TINA noted the FBI's internet Crime Complaint Center recorded a rise in complaints about free trial offers, growing from 1,738 in 2015 to 2,486 in 2017, with losses totaling more than $15 million. Similarly, a 2019 Bankrate.com survey cited by NCL found that 59% of consumers have signed up for “free trials” that automatically converted into a recurring payment obligation “against their will.” In NCL's view, these data point to “a troubling, and costly problem for American consumers.” </blockquote>

While it does not outright prohibit this practice, the click-to-cancel rule partially alleviates these issues by requiring clear disclosures and consent. According to state AGs, "advertisements for free-to-pay conversion offers often lure consumers by promising a 'free' benefit while failing to clearly and conspicuously disclose future payment obligations".<ref>https://www.federalregister.gov/d/2023-07035/p-83 ([https://web.archive.org/web/20260223034831/https://unblock.federalregister.gov/ Archived])</ref> The FTC also states that:<ref>https://www.federalregister.gov/d/2023-07035/p-87 ([https://web.archive.org/web/20260216014934/https://unblock.federalregister.gov/ Archived])</ref><blockquote>Other studies reveal similar trends. TINA noted the FBI's internet Crime Complaint Center recorded a rise in complaints about free trial offers, growing from 1,738 in 2015 to 2,486 in 2017, with losses totaling more than $15 million. Similarly, a 2019 Bankrate.com survey cited by NCL found that 59% of consumers have signed up for “free trials” that automatically converted into a recurring payment obligation “against their will.” In NCL's view, these data point to “a troubling, and costly problem for American consumers.” </blockquote>

===Adobe===

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+{{Cleanup}}
 The '''click-to-cancel''' (CtC) rule is a [[Federal Trade Commission]] (FTC) rule, specifically [https://www.ecfr.gov/current/title-16/chapter-I/subchapter-D/part-425/section-425.6 16 CFR Part 425.6], which requires that subscription services make it as easy to cancel the service as it was to sign up.<ref>{{Cite web |date=16 Oct 2024 |title=Federal Trade Commission Announces Final “Click-to-Cancel” Rule Making It Easier for Consumers to End Recurring Subscriptions and Memberships |url=https://www.ftc.gov/news-events/news/press-releases/2024/10/federal-trade-commission-announces-final-click-cancel-rule-making-it-easier-consumers-end-recurring |website=Federal Trade Commission |url-status=live |archive-url=http://web.archive.org/web/20260206202338/https://www.ftc.gov/news-events/news/press-releases/2024/10/federal-trade-commission-announces-final-click-cancel-rule-making-it-easier-consumers-end-recurring |archive-date=6 Feb 2026}}</ref> This is designed to combat an anti-consumer practice, where a subscription service makes it very easy to sign up for a service, but requires the customer to jump through hoops to cancel the subscription. The law has been finalized and was initially set to go into effect May 14, 2025.<ref>{{Cite web |date=15 Nov 2024 |title=Federal Trade Commission,16 CFR Part 425, RIN 3084-AB60 |url=https://www.federalregister.gov/documents/2024/11/15/2024-25534/negative-option-rule#p-6 |website=Federal Register |url-status=live |archive-url=http://web.archive.org/web/20250515052212/https://www.federalregister.gov/documents/2024/11/15/2024-25534/negative-option-rule |archive-date=15 May 2025}}</ref> On July 8, the U.S. Court of Appeals for the Eighth Circuit blocked the click-to-cancel provision, reasoning that the FTC erred by not first conducting a preliminary regulatory analysis of the rule's costs and benefits. The analysis must be conducted on any rules that impact the economy by more than $100 million. The FTC can still petition the Supreme Court to review the decision through October 6, 2025 <ref>{{Cite web |last=Fouse-Hopkins |first=Lindsay |date=2025-07-17 |title=Eighth Circuit blocks Click-to-Cancel Rule |url=https://www.clarkhill.com/news-events/news/eighth-circuit-blocks-click-to-cancel-rule/ |url-status=live |access-date=2025-07-17 |website=Clarkhill.com |archive-url=http://web.archive.org/web/20251207032751/https://www.clarkhill.com/news-events/news/eighth-circuit-blocks-click-to-cancel-rule/ |archive-date=7 Dec 2025}}</ref>
 ==How it works==
-The rule prohibits the following:<ref>{{Cite web |date=2024 |title=The FTC’s “Click to Cancel” Rule |url=https://www.ftc.gov/system/files/ftc_gov/pdf/NegOptions-1page-Oct2024-v2.pdf |website=Federal Trade Commission |url-status=live |archive-url=http://web.archive.org/web/20251122050657/https://www.ftc.gov/system/files/ftc_gov/pdf/NegOptions-1page-Oct2024-v2.pdf |archive-date=22 Nov 2025}}</ref><ref name=":0">https://www.govinfo.gov/content/pkg/FR-2024-11-15/pdf/2024-25534.pdf</ref>
+The rule prohibits the following:<ref>{{Cite web |date=2024 |title=The FTC’s “Click to Cancel” Rule |url=https://www.ftc.gov/system/files/ftc_gov/pdf/NegOptions-1page-Oct2024-v2.pdf |website=Federal Trade Commission |url-status=live |archive-url=http://web.archive.org/web/20251122050657/https://www.ftc.gov/system/files/ftc_gov/pdf/NegOptions-1page-Oct2024-v2.pdf |archive-date=22 Nov 2025}}</ref><ref name=":0">https://www.govinfo.gov/content/pkg/FR-2024-11-15/pdf/2024-25534.pdf ([http://web.archive.org/web/20251124053133/https://www.govinfo.gov/content/pkg/FR-2024-11-15/pdf/2024-25534.pdf Archived])</ref>
 *to misrepresent any material fact made while marketing using a negative option feature
@@ Line 11: / Line 13: @@
 A "negative-option feature" is defined by the FTC as "a provision in an offer or agreement to sell or provide any goods or services 'under which the customer’s silence or failure to take an affirmative action to reject goods or services or to cancel the agreement is interpreted by the seller as acceptance of the offer'".<ref name=":0" /> In other words, it is a feature of a service, where once a subscription is initiated, the customer will continue to be billed until they actively cancel the subscription.
-The click-to-cancel rule is not limited to electronic services, as the name might suggest. It includes, but is not limited to "Interactive Electronic Media, telephone, print, and in-person transactions."<ref>https://www.federalregister.gov/documents/2024/11/15/2024-25534/negative-option-rule#sectno-citation-425.1 ([http://web.archive.org/web/20250515052212/https://www.federalregister.gov/documents/2024/11/15/2024-25534/negative-option-rule Archived])</ref> The cancellation mechanism must be "at least as simple as consent".<ref>https://www.federalregister.gov/d/2024-25534/p-1164</ref> The customer may not be required to interact with a representative, whether a real human or a chat bot, if the customer was not required to do so when they signed up for the service.<ref>https://www.federalregister.gov/d/2024-25534/p-1166</ref> For services which were signed up for in-person, the seller must allow cancellation online or over the phone.<ref>https://www.federalregister.gov/d/2024-25534/p-1168</ref>
+The click-to-cancel rule is not limited to electronic services, as the name might suggest. It includes, but is not limited to "Interactive Electronic Media, telephone, print, and in-person transactions."<ref>https://www.federalregister.gov/documents/2024/11/15/2024-25534/negative-option-rule#sectno-citation-425.1 ([http://web.archive.org/web/20250515052212/https://www.federalregister.gov/documents/2024/11/15/2024-25534/negative-option-rule Archived])</ref> The cancellation mechanism must be "at least as simple as consent".<ref>https://www.federalregister.gov/d/2024-25534/p-1164 ([https://web.archive.org/web/20260223034631/https://unblock.federalregister.gov/ Archived])</ref> The customer may not be required to interact with a representative, whether a real human or a chat bot, if the customer was not required to do so when they signed up for the service.<ref>https://www.federalregister.gov/d/2024-25534/p-1166 ([https://web.archive.org/web/20260223034652/https://unblock.federalregister.gov/ Archived])</ref> For services which were signed up for in-person, the seller must allow cancellation online or over the phone.<ref>https://www.federalregister.gov/d/2024-25534/p-1168 ([https://web.archive.org/web/20260223034713/https://unblock.federalregister.gov/ Archived])</ref>
 ==Examples of abuse==
@@ Line 19: / Line 21: @@
 ====Planet Fitness====
-Prior to state-level laws, Planet Fitness's FAQ stated that "You can fill out a cancellation form at the front desk of your home club, or send a letter (preferably via certified mail) to your club requesting cancellation. Memberships can’t, unfortunately, be cancelled by email or phone"<ref>{{Cite web |title=Frequently Asked Questions |url=https://www.planetfitness.com/about-planet-fitness/customer-service#region-faq-accordion-0 |website=Planet Fitness |url-status=live |archive-url=http://web.archive.org/web/20260101164213/https://www.planetfitness.com/about-planet-fitness/customer-service |archive-date=1 Jan 2026}}</ref>{{UpdateNeeded|date=October 2025|reason=The FAQ has changed since the initial writing of this article version.}} despite allowing online signups. As of Jan 18, 2025, its terms state "our cancellation process may vary from club to club", and that "Some members may also be eligible to cancel their membership online based on their membership type and the location of their home club."<ref>https://archive.ph/XSG0Q</ref>
+Prior to state-level laws, Planet Fitness's FAQ stated that "You can fill out a cancellation form at the front desk of your home club, or send a letter (preferably via certified mail) to your club requesting cancellation. Memberships can’t, unfortunately, be cancelled by email or phone"<ref>{{Cite web |title=Frequently Asked Questions |url=https://www.planetfitness.com/about-planet-fitness/customer-service#region-faq-accordion-0 |website=Planet Fitness |url-status=live |archive-url=http://web.archive.org/web/20260101164213/https://www.planetfitness.com/about-planet-fitness/customer-service |archive-date=1 Jan 2026}}</ref>{{UpdateNeeded|date=October 2025|reason=The FAQ has changed since the initial writing of this article version.}} despite allowing online signups. As of Jan 18, 2025, its terms state "our cancellation process may vary from club to club", and that "Some members may also be eligible to cancel their membership online based on their membership type and the location of their home club."<ref>https://www.planetfitness.com/about-planet-fitness/customer-service#region-faq-accordion-0 ([https://web.archive.org/web/20260405060509/https://www.planetfitness.com/about-planet-fitness/customer-service#region-faq-accordion-0 Archived])</ref>
 As of June 10, 2025, Planet Fitness (https://www.planetfitness.com/) requires billing (credit card and bank account) information before clearly and conspicuously disclosing material terms of its negative option in violation of [https://www.ecfr.gov/current/title-16/chapter-I/subchapter-D/part-425 FTC 16 CFR Part 425.4].
@@ Line 29: / Line 31: @@
 "Free-to-pay" is a technical term for free trials with a negative-option feature.<ref>https://www.ftc.gov/system/files/documents/public_statements/1598063/negative_option_policy_statement-10-22-2021-tobureau.pdf ([http://web.archive.org/web/20251209002749/https://www.ftc.gov/system/files/documents/public_statements/1598063/negative_option_policy_statement-10-22-2021-tobureau.pdf Archived])</ref> In many cases, rather than providing a free trial with no strings attached, and only billing the customer if they decide to sign up, the vendor collects payment information as a prerequisite of the free trial, and automatically bills the customer if they fail to affirmatively cancel the trial (a negative-option feature).
-While it does not outright prohibit this practice, the click-to-cancel rule partially alleviates these issues by requiring clear disclosures and consent. According to state AGs, "advertisements for free-to-pay conversion offers often lure consumers by promising a 'free' benefit while failing to clearly and conspicuously disclose future payment obligations".<ref>https://www.federalregister.gov/d/2023-07035/p-83</ref> The FTC also states that:<ref>https://www.federalregister.gov/d/2023-07035/p-87 ([https://web.archive.org/web/20260216014934/https://unblock.federalregister.gov/ Archived])</ref><blockquote>Other studies reveal similar trends. TINA noted the FBI's internet Crime Complaint Center recorded a rise in complaints about free trial offers, growing from 1,738 in 2015 to 2,486 in 2017, with losses totaling more than $15 million. Similarly, a 2019 Bankrate.com survey cited by NCL found that 59% of consumers have signed up for “free trials” that automatically converted into a recurring payment obligation “against their will.” In NCL's view, these data point to “a troubling, and costly problem for American consumers.” </blockquote>
+While it does not outright prohibit this practice, the click-to-cancel rule partially alleviates these issues by requiring clear disclosures and consent. According to state AGs, "advertisements for free-to-pay conversion offers often lure consumers by promising a 'free' benefit while failing to clearly and conspicuously disclose future payment obligations".<ref>https://www.federalregister.gov/d/2023-07035/p-83 ([https://web.archive.org/web/20260223034831/https://unblock.federalregister.gov/ Archived])</ref> The FTC also states that:<ref>https://www.federalregister.gov/d/2023-07035/p-87 ([https://web.archive.org/web/20260216014934/https://unblock.federalregister.gov/ Archived])</ref><blockquote>Other studies reveal similar trends. TINA noted the FBI's internet Crime Complaint Center recorded a rise in complaints about free trial offers, growing from 1,738 in 2015 to 2,486 in 2017, with losses totaling more than $15 million. Similarly, a 2019 Bankrate.com survey cited by NCL found that 59% of consumers have signed up for “free trials” that automatically converted into a recurring payment obligation “against their will.” In NCL's view, these data point to “a troubling, and costly problem for American consumers.” </blockquote>
 ===Adobe===