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>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</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>https://www.federalregister.gov/d/2024-25534/p-6</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}}</ref>

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}}</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}}</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}}</ref>

==How it works==

The rule prohibits the following:<ref>https://www.ftc.gov/system/files/ftc_gov/pdf/NegOptions-1page-Oct2024-v2.pdf</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}}</ref><ref name=":0">https://www.govinfo.gov/content/pkg/FR-2024-11-15/pdf/2024-25534.pdf</ref>

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

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===Gym memberships===

Gym memberships are a notorious example of being significantly more difficult to cancel than they were to sign up for. While some states, such as California<ref>https://leginfo.legislature.ca.gov/faces/billCompareClient.xhtml?bill_id=202320240AB2863&showamends=false</ref> already had laws analogous to CtC, gym locations outside of those locations have continued to make it easy to sign up, yet difficult to cancel.

Gym memberships are a notorious example of being significantly more difficult to cancel than they were to sign up for. While some states, such as California<ref>{{Cite web |date=2024 |title=AB-2863 Automatic renewal and continuous service offers |url=https://leginfo.legislature.ca.gov/faces/billCompareClient.xhtml?bill_id=202320240AB2863&showamends=false |website=California Legislative Information}}</ref> already had laws analogous to CtC, gym locations outside of those locations have continued to make it easy to sign up, yet difficult to cancel.

====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>https://www.planetfitness.com/about-planet-fitness/customer-service~~/membership~~-~~faqs~~</ref> 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> ~~As of Feb 17, 2025, the link to the "[https://www.planetfitness.com/about-planet-fitness/contact-us Member Services department]" leads to a 404 page.~~

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}}</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>

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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-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>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</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>https://www.federalregister.gov/d/2024-25534/p-6</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}}</ref>
+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}}</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}}</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}}</ref>
 ==How it works==
-The rule prohibits the following:<ref>https://www.ftc.gov/system/files/ftc_gov/pdf/NegOptions-1page-Oct2024-v2.pdf</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}}</ref><ref name=":0">https://www.govinfo.gov/content/pkg/FR-2024-11-15/pdf/2024-25534.pdf</ref>
 *to misrepresent any material fact made while marketing using a negative option feature
@@ Line 16: / Line 16: @@
 ===Gym memberships===
-Gym memberships are a notorious example of being significantly more difficult to cancel than they were to sign up for. While some states, such as California<ref>https://leginfo.legislature.ca.gov/faces/billCompareClient.xhtml?bill_id=202320240AB2863&showamends=false</ref> already had laws analogous to CtC, gym locations outside of those locations have continued to make it easy to sign up, yet difficult to cancel.
+Gym memberships are a notorious example of being significantly more difficult to cancel than they were to sign up for. While some states, such as California<ref>{{Cite web |date=2024 |title=AB-2863 Automatic renewal and continuous service offers |url=https://leginfo.legislature.ca.gov/faces/billCompareClient.xhtml?bill_id=202320240AB2863&showamends=false |website=California Legislative Information}}</ref> already had laws analogous to CtC, gym locations outside of those locations have continued to make it easy to sign up, yet difficult to cancel.
 ====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>https://www.planetfitness.com/about-planet-fitness/customer-service/membership-faqs</ref> 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> As of Feb 17, 2025, the link to the "[https://www.planetfitness.com/about-planet-fitness/contact-us Member Services department]" leads to a 404 page.
+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}}</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>
 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].