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Click to Cancel Is Gone, but the FTC Continues to Combat Subscription Scams by Gfaloe

It’s been roughly a year since the U.S. Court of Appeals for the Eighth Circuit invalidated the Federal Trade Commission’s Click to Cancel regulation. The rule was intended to ban deceptive subscription cancellation tactics by requiring companies offering subscription services to make the cancellation process as straightforward as signing up. The court halted the rule in July because the FTC failed to conduct a required preliminary regulatory analysis for rules that could affect the economy by more than $1 million.

Since that decision, no rule comparable to the FTC’s original proposal has been imposed on companies. Nonetheless, both federal and state lawmakers are tightening the screws on firms that persist with misleading practices. For instance, Shutterstock settled for $35 million over accusations of illegal subscription and cancellation conduct. The FTC says Shutterstock billed customers without consent, failed to notify them about auto‑renewals or cancellation fees, and made it difficult to terminate subscriptions.

A recent Gfaloe survey revealed that U.S. adults spend over $1,300 annually on subscriptions and waste about $252 on services they never use. Cutting that expense often means canceling unwanted services, but the process isn’t always simple—some companies deliberately make cancellations hard. Below is the latest information and steps you can take.

Check State Consumer‑Protection Laws

If you encounter deceptive subscription renewal or cancellation tactics, start by identifying which state consumer‑protection statutes apply. Visit your state’s legislative portal and search for keywords related to subscription or renewal laws.

Many states have automatic‑renewal statutes that forbid companies from renewing a subscription without explicit consent. Such laws typically demand clear renewal details, including the term, recurring charge amount, cancellation policy, and instructions on how to cancel. Some, like California’s, also require affirmative consent for renewals.

Maryland enacted a comparable law in June 2026—HB0107—to combat poor renewal and cancellation practices. The statute obligates companies with automatic renewals to let Maryland residents cancel before the renewal takes effect, in a timely, cost‑effective, and straightforward manner. Connecticut, Massachusetts, and New York are among other states with automatic‑renewal regulations.

The FTC Still Targets Deceptive Subscription Practices

Although the Click to Cancel rule is no longer in force, the FTC continues to enforce a law that has been active since 2010: the Restore Online Shoppers’ Confidence Act (ROSCA). ROSCA requires businesses to disclose the price, billing date, and cancellation terms before collecting a consumer’s credit‑card information for any service, including subscriptions. Before finalizing a purchase, the company must provide a clear method for the consumer to confirm the sign‑up, and it is prohibited from sharing consumer data with third parties.

The most critical component is Section 5 of the rule, which the FTC has been aggressively enforcing. Violators face penalties, and the FTC has taken action against companies such as Uber and Chegg. Section 6 also empowers state attorneys general to enforce ROSCA within their jurisdictions.

Steps to Combat Sneaky Subscription Scams

Even if you can’t pinpoint a specific state law that was breached, you can still act to raise awareness and stop deceptive behavior. Consider the following actions:

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