[{"data":1,"prerenderedAt":279},["ShallowReactive",2],{"/blog/ftc-click-to-cancel-rule-voided":3},{"id":4,"title":5,"articleSection":6,"author":7,"body":8,"category":6,"coverBuilder":263,"cta":264,"ctaBody":263,"ctaTitle":263,"dateModified":263,"datePublished":265,"description":266,"draft":267,"extension":268,"hideCover":267,"image":269,"meta":270,"navigation":271,"ogImage":263,"path":272,"readTime":273,"seo":274,"sidebarCta":263,"stem":275,"tags":276,"wordCount":277,"__hash__":278},"blog/blog/ftc-click-to-cancel-rule-voided.md","U.S. appeals court blocks FTC’s ‘click-to-cancel’ rule for recurring subscriptions","News","nick",{"type":9,"value":10,"toc":254},"minimark",[11,30,35,42,55,63,69,79,83,86,89,92,96,99,102,105,109,135,138,142,150,156,159,167,170,174,179,182,231],[12,13,15],"article-action-card",{"variant":14},"blue",[16,17,18,19,24,25,29],"p",{},"This is part of our series on the FTC's \"Click-to-Cancel\" rule. We had put together a ",[20,21,23],"a",{"href":22},"/blog/simple-ftc-compliance-checklist","simple compliance checklist"," for businesses to follow, as well as a rundown on ",[20,26,28],{"href":27},"/blog/ftc-negative-option-rule-free-trials","how free trials were to be affected"," should the rule go into effect.",[31,32,34],"h3",{"id":33},"what-happened","What happened?",[16,36,37,41],{},[38,39,40],"strong",{},"On October 16th, 2024:"," The Federal Trade Commission, which aims to protects America's consumers, announced the \"Click-to-Cancel\" rule.",[43,44,47],"article-figure",{"alt":45,"src":46},"","/images/blog/ftc-click-to-cancel-rule-voided/image-2.webp",[16,48,49],{},[20,50,54],{"href":51,"rel":52},"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=churnkey.co",[53],"nofollow","Source: FTC",[16,56,57,58,62],{},"The rule was designed to make it easier for consumers to cancel subscriptions. You can read Churnkey's explanation of the rule ",[20,59,61],{"href":60},"/blog/ftc-click-to-cancel-rule","here",".",[16,64,65,68],{},[38,66,67],{},"On July 8th, 2025",": U.S. Court of Appeals struck down the rule entirely, just days before it was scheduled to take full effect on July 14.",[43,70,72],{"alt":45,"src":71},"/images/blog/ftc-click-to-cancel-rule-voided/image.webp",[16,73,74],{},[20,75,78],{"href":76,"rel":77},"https://storage.courtlistener.com/recap/gov.uscourts.ca8.110200/gov.uscourts.ca8.110200.00805299841.0.pdf?ref=churnkey.co",[53],"Source: U.S. Court of Appeals",[31,80,82],{"id":81},"why-was-it-struck-down","Why was it struck down?",[16,84,85],{},"Multiple organizations challenged the FTC's rule in court. This included various business groups including the U.S. Chamber of Commerce, alarm companies, press associations, advertising bureaus, and other industry groups.",[16,87,88],{},"The court ruled on procedural grounds.",[16,90,91],{},"Federal law required a preliminary economic analysis to determine if the negative option rule would cost businesses more than $100M a year. The FTC did not to conduct the analysis and so the court blocked the rule.",[31,93,95],{"id":94},"what-does-this-mean-for-businesses","What does this mean for businesses?",[16,97,98],{},"Now that the FTC isn’t making a large, sweeping ruling, laws will go into the hands of individual states.",[16,100,101],{},"If you serve customers who are in the U.S., you will have to comply with each one of the individual states. Many of these laws are inconsistent with one another.",[16,103,104],{},"This could make things more complicated for to manage, especially if you're serving customers in multiple jurisdictions.",[31,106,108],{"id":107},"when-does-your-business-need-to-be-compliant","When does your business need to be compliant?",[110,111,112,121,129,132],"ul",{},[113,114,115,120],"li",{},[20,116,119],{"href":117,"rel":118},"https://leginfo.legislature.ca.gov/faces/billTextClient.xhtml?bill_id=202320240AB2863&ref=churnkey.co",[53],"California’s “Auto Renewal Law”"," took effect on July 1",[113,122,123,128],{},[20,124,127],{"href":125,"rel":126},"https://leg.colorado.gov/bills/sb25-145?ref=churnkey.co",[53],"Colorado’s cancellation law"," goes into effect on August 6",[113,130,131],{},"New York’s amended law goes into effect November 5.",[113,133,134],{},"...and so on.",[16,136,137],{},"27 states already have their own laws for subscription cancellations or renewals.",[31,139,141],{"id":140},"how-can-churnkey-help","How can Churnkey help?",[16,143,144,145,149],{},"At ",[20,146,148],{"href":147},"/","Churnkey",", we understand how complicated this could mean for businesses and we’ve built a solution that makes compliance across jurisdictions effortless.",[16,151,152],{},[153,154],"img",{"alt":45,"src":155},"/images/blog/ftc-click-to-cancel-rule-voided/image-3.webp",[16,157,158],{},"Cancel Flow compliance happens in mere clicks within your Churnkey dashboard. It’s up to you to decide how you’d like to comply with the various cancellation laws out there:",[110,160,161,164],{},[113,162,163],{},"Comply with “single-click” laws only in relevant jurisdictions, or…",[113,165,166],{},"…also elect to be “maximally-compliant” in all US states",[16,168,169],{},"We've designed Churnkey to respect your customer, and this is yet another step in that direction.",[31,171,173],{"id":172},"how-to-get-started-with-churnkey","How to get started with Churnkey?",[16,175,176,178],{},[20,177,148],{"href":147}," helps high-volume subscription companies recover 20-40% of the revenue that they would otherwise have lost to churn.",[16,180,181],{},"We have a suite of retention products ranging from:",[110,183,184,190,210,216,222,228],{},[113,185,186],{},[20,187,189],{"href":188},"/feature/cancel-flows","Cancel Flows",[113,191,192,196],{},[20,193,195],{"href":194},"/feature/payment-recovery","Payment Recovery",[110,197,198,204],{},[113,199,200],{},[20,201,203],{"href":202},"/feature/payment-recovery/dunning-campaigns","Dunning",[113,205,206],{},[20,207,209],{"href":208},"/feature/payment-recovery/payment-retries","Precision Retries",[113,211,212],{},[20,213,215],{"href":214},"/feature/customer-health","Customer Health",[113,217,218],{},[20,219,221],{"href":220},"/feature/reactivations","Reactivations",[113,223,224],{},[20,225,227],{"href":226},"/feature/customer-insights-ai","Feedback AI",[113,229,230],{},"...and more to help you tackle churn in the most efficient way.",[16,232,233,236,237,236,243,236,246,253],{},[38,234,235],{},"To get started,"," ",[20,238,240],{"href":239},"/schedule-a-demo",[38,241,242],{},"book a call",[38,244,245],{},"or",[20,247,250],{"href":248,"rel":249},"https://app.churnkey.co/register?ref=churnkey.co",[53],[38,251,252],{},"sign up for an account",". If you have questions about your existing flow, please ask our team.",{"title":45,"searchDepth":255,"depth":255,"links":256},3,[257,258,259,260,261,262],{"id":33,"depth":255,"text":34},{"id":81,"depth":255,"text":82},{"id":94,"depth":255,"text":95},{"id":107,"depth":255,"text":108},{"id":140,"depth":255,"text":141},{"id":172,"depth":255,"text":173},null,"newsletter","2025-07-11","U.S. Court of Appeals struck down the rule entirely, just days before it was scheduled to take full effect on July 14. Now that the FTC isn’t making a large, sweeping ruling, laws will go into the hands of individual states.",false,"md","/images/blog/ftc-click-to-cancel-rule-voided/click-to-cancel-rule-voided.webp",{},true,"/blog/ftc-click-to-cancel-rule-voided","2 min read",{"title":5,"description":266},"blog/ftc-click-to-cancel-rule-voided",[6],496,"MRPP-rlWYkSvgF6rQtQa-aBmjDKP8w2yleUP8b-4_zE",1787075315954]