Introduction to the “Click to Cancel” Rule
Efforts in Congress to create a federal “click to cancel” rule have gained momentum, aiming to make canceling subscriptions as straightforward as signing up for them. A bipartisan House bill, known as the Unsubscribe Act, was introduced in mid-January, complementing a Senate measure proposed in July. This legislation would require companies offering subscriptions to provide easy cancellation options and obtain consumer approval before charging them after a free or reduced-cost period.
The Unsubscribe Act joins two other bills presented in July, one in the House and one in the Senate, which generally aim to reinstate a click-to-cancel rule from the Federal Trade Commission (FTC) that was struck down by a federal appeals court last year. The FTC’s rule was similar to the Unsubscribe Act, emphasizing the need for transparency and ease in subscription cancellation processes.
Consumer Spending on Subscriptions
U.S. adults spend an average of $1,080 yearly on subscriptions, according to a 2025 survey by CNET, a media website focused on consumer technology. Millennials spend the most annually, with an average of $1,215. Notably, the average spent annually on subscriptions that consumers no longer use is $205, highlighting the need for clearer and more accessible cancellation processes.
The prevalence of “negative option” subscription contracts, which automatically renew unless canceled by consumers, has led to a growing number of complaints. In 2024, the FTC received an average of nearly 70 consumer complaints per day, up from 42 daily in 2021, underscoring the urgency for regulatory action.
Regulatory Efforts and Challenges
The FTC finalized its click-to-cancel rule in October 2024 under the Biden administration but was quickly challenged in court by business and trade groups. The Eighth Circuit Court of Appeals vacated the rule on procedural grounds, citing the lack of a proper economic impact analysis. Despite this setback, the FTC has continued to challenge subscription cancellation practices under different authorities, such as the Restore Online Shoppers’ Confidence Act.
In September, the FTC announced settlements with Amazon and Chegg over allegations of deceptive subscription practices, including enrolling consumers in subscriptions without consent and making cancellations difficult. These actions demonstrate the agency’s ongoing commitment to protecting consumers from unfair subscription practices.
State Laws and the Need for Federal Regulation
More than half of the states now have laws that require companies to provide easy cancellation options for subscriptions, similar to the Unsubscribe Act and the FTC’s rule. However, these state laws are not uniform, creating a patchwork of regulations that companies must navigate. The Unsubscribe Act, if passed, would not preempt state laws, meaning companies would need to comply with both federal and state regulations.
Experts like Gonzalo Mon, a partner with the law firm of Kelley Drye & Warren in Washington, note that this issue has bipartisan support, reflecting a broader concern for consumer protection. As Mon observes, companies operating nationwide must currently adhere to the most restrictive state laws, but a federal rule would provide clarity and consistency.
Conclusion and Further Action
The push for a federal “click to cancel” rule highlights the complexities and challenges associated with subscription services. As consumers increasingly rely on these services, the need for transparent, accessible, and fair cancellation processes becomes more pressing. While the outcome of the current congressional proposals is uncertain, the ongoing efforts by the FTC and state legislatures indicate a commitment to addressing consumer concerns.
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Smart Tip for Readers
To avoid unwanted subscription charges, regularly review your subscription services and cancel any that you no longer use. Setting reminders or using budgeting apps can help track and manage your subscriptions more effectively.
