> For the complete documentation index, see [llms.txt](https://help.flycode.com/llms.txt). Markdown versions of documentation pages are available by appending `.md` to page URLs; this page is available as [Markdown](https://help.flycode.com/subscription-compliance/regulatory-rules.md). # Regulatory Rules What the FTC Click-to-Cancel rule required and its current status, whether it applies to existing subscriptions, what counts as a dark pattern in cancellation flows, and a fast test for whether your c The headline rule is simple: cancelling has to be as easy as signing up. The legal landscape behind it has moved, so this page covers what the FTC rule said, where it stands, and the state and international rules that apply regardless. This is general information, not legal advice. ## What exactly is the FTC's Click-to-Cancel rule, and when does it apply? The FTC's Negative Option Rule, known as Click-to-Cancel, was finalized in October 2024. It required that cancelling a subscription be as easy as signing up, through the same channel: one-click (or equivalent) online cancellation, clear upfront disclosure of price and renewal terms, and explicit, separate consent to recurring billing. It applied to all US businesses offering automatic renewals. Status: in July 2025 the US Court of Appeals for the Eighth Circuit vacated the rule on procedural grounds before its main provisions took effect, so the federal Click-to-Cancel rule is not currently in force. The obligations have not disappeared, however. The FTC continues to enforce the Restore Online Shoppers' Confidence Act (ROSCA), which already requires clear disclosure, express informed consent and simple cancellation mechanisms for online subscriptions, and it has brought cases under it. State automatic renewal laws, led by California's (strengthened effective July 2025), New York's and others, impose click-to-cancel style requirements of their own, and the UK's Digital Markets, Competition and Consumers Act and EU consumer rules do the same for those markets. Treat the vacated rule's standard as the practical baseline and check with counsel for your jurisdictions. ## Does this apply to subscriptions started before the rule goes into effect? Under the state laws and ROSCA that currently apply, yes: the rules govern how you handle renewals and cancellations going forward, not just new sign-ups. If you are billing a customer on a recurring basis, they are entitled to the disclosure and cancellation standards in force where they live, regardless of when they first subscribed. Some state laws also require a renewal reminder notice for longer-term plans and after free trials. ## What's considered a "dark pattern" under these laws? Any interface or copy designed to confuse, delay or discourage cancellation. Common examples regulators cite: hidden or hard-to-find cancel buttons; forcing the customer to phone or chat when they signed up online; long forced scrolls or multi-step retention flows before the cancel option appears; unclear or buried renewal terms and pricing; pre-checked consent boxes; and manipulative wording such as double negatives ("Don't cancel my subscription") or guilt-inducing button labels. Offering a retention discount is allowed, provided it is a single, skippable step. ## What's a fast way to check if our cancellation flow is compliant? Try the hallway test: hand your flow to someone new on your team and ask them to cancel a subscription in two clicks from the account page. If they get lost, are buried in text, are pushed to a support form or phone line, or cannot find the option without help, the flow is not compliant in spirit and probably not in law. Then check the sign-up side: is the price, renewal frequency and cancellation method stated plainly before the customer consents, and is consent to recurring billing a separate, unchecked action? ## Related * [Legal & Tracking Requirements](https://help.flycode.com/subscription-compliance/legal-and-tracking-requirements) * [Can FlyCode fix subscription-status anomalies Stripe sometimes misses?](https://help.flycode.com/flycode-and-stripe/what-flycode-adds-to-stripe) --- # Agent Instructions This documentation is published with GitBook. GitBook is the documentation platform designed so that both humans and AI agents can read, navigate, and reason over technical content effectively. Learn more at gitbook.com. ## Querying This Documentation If you need additional information that is not directly available in this page, you can query the documentation dynamically by asking a question. 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