A US appeals court blocks the FTC's “click-to-cancel” rule that would have taken effect on July 14, saying it didn't conduct a preliminary cost-benefit analysis
A U.S. appeals court blocked a rule that would have required businesses to make it as easy to cancel subscriptions …
ReutersJody Godoy
Context & Ripple Effects
The FTC’s subscription-cancellation initiative moved from a 2023 proposal to a final rule in 2024, then had its enforcement date pushed to July after the agency’s earlier enforcement delay. The court’s intervention stops that rollout at the point it was meant to begin.
The ruling matters beyond cancellation flows because it turns on the FTC’s rulemaking process, rather than on whether subscription exits should be simpler. It follows the agency’s finalization of the cancellation standard and leaves the policy’s future dependent on a procedurally sounder path.
First-order effects
Businesses that would have had to align cancellation and sign-up journeys by July 14 no longer face that rule taking effect on that schedule.
The FTC cannot enforce this version of the rule after the appeals court found its preliminary cost-benefit analysis inadequate.
Second-order effects
Subscription businesses retain their existing cancellation designs for now, while compliance work tied specifically to the blocked federal requirement can be paused or reassessed.
The FTC will face pressure to strengthen the economic and procedural record behind any renewed cancellation rule, extending uncertainty for companies seeking a uniform federal standard.
Third-order effects
If procedural challenges continue to derail federal consumer-protection rules, regulatory outcomes may hinge increasingly on agencies’ administrative records as much as on the underlying consumer-harm theory.
The episode reinforces a broader contest over whether subscription retention practices are governed through prescriptive federal rules or through narrower, case-by-case enforcement.
The trend: Subscription-bet accountability is increasingly being shaped by the durability of agencies’ rulemaking process, not only by the consumer protections they seek to impose.
have I mentioned lately that grotesque levels of U.S. corruption means we genuinely no longer have federal consumer protection standards or corporate oversight? [embedded post]
“US court strikes down ‘click-to-cancel’ rule designed to make unsubscribing easier” — Good! I was worried if I wanted to cancel something it would only take a click. — Courts know I need to call customer service, wait 28 hours on hold, put in my PIN, get lost in a phone-tre…
You know what? @governor.ca.gov or someone would be smart to challenge this under the Supreme Court's ruling on Nationwide Injunctions and get another court to allow it in California. Play by the GOP's rules for once and fight dirty. It would look good for 2028 [embedded post]
Court voids FTC “click-to-cancel” rule that would have made it as easy to cancel online subscriptions as it is to start them. “Pre-business” should not mean “anti-consumer.” thehill.com/policy/techn...
To write regulations, the government has to jump through certain hoops. They judges are claiming the FTC didn't jump through the hoops in exactly the right way.
Over 16k Americans weighed in on the click-to-cancel rule, overwhelmingly supporting our effort to end subscription traps. The rule was set to go into effect in May but this @FTC slow-walked it—and now a court has tossed it out, claiming industry didn't get enough of a say. Any…
And now, after Republican FTC Commissioners delayed the Click to Cancel rule from going into effect earlier this year, Republican judges have sided with the Chamber of Commerce and killed it off altogether.
This rule would allow anyone to cancel a subscription with as many clicks as it takes to sign up, sometimes as few as one or two clicks. Your friendly FTC is now acting on behalf of the big companies who want to make it as difficult as possible to unsubscribe.
The FTC asked for party-specific vacatur, but 8th Circuit invalidated the “Click to Cancel” Rule. The decision goes to the issue reserved by the majority in Trump v. CASA at p.11 n.10—the answer to which was suggested by Justice Kavanaugh: Universal relief is available under APA …
The FTC's click-to-cancel rule, which would have made it much easier for consumers to get rid of unwanted online subscriptions, isn't going into effect for one reason: the Biden FTC cut corners and didn't follow the law. Process matters.
@MeadorFTC Then fix it! An overwhelming majority of people want this rule in place. Complete nonsense that we have to jump through hoops to cancel a subscription or credit card. It should be as easy to cancel as sign up.
Just terrible. Lina Khan's FTC saved Americans $billions and returned $100s of millions directly to them. Now Trump's FTC is trying to undo all progress made for consumers. Btwn merger settlements and the 8th circuit ruling on click to cancel, Trump is making life more expensive.
It's bad enough that the Trump FTC has done nothing to bring down costs for Americans. Now, by slow-walking the massively popular Click-to-Cancel Rule, they've ensured that hardworking people will keep getting stuck with subscriptions. More from @nhegde and @LeeHepner 👇 [image]
All-Republican CA8 panel (GHWB/Trump/Trump) kills the Biden FTC's Click-to-Cancel rule so that Trump's FTC doesn't have to take the political heat for rescinding something popular. https://storage.courtlistener.com/ ... [image]
Garbage In, Garbage Out once again for the Khan FTC. The click to cancel rule goes down and consumers are left without protection because it played fast and loose with the law, skipping required regulatory analysis and evading cost-benefit analysis.