Click to Cancel Laws: Federal Status and State Auto-Renewal Rules

There is no federal click-to-cancel rule in force. The FTC's 2024 "click to cancel" rule was vacated by a federal appeals court on July 8, 2025, and what remains federally is the 1973 Negative Option Rule, which covers only prenotification plans, and ROSCA, which governs subscriptions sold online (15 U.S.C. 8403). The rules most people mean by "click to cancel" now come from state automatic renewal laws: California, for example, requires a business that lets a consumer sign up online to let the consumer cancel exclusively online (Cal. Bus. & Prof. Code 17602(d)(1)).

Those state laws differ in who they cover, what they require and who can enforce them. This page sets out the federal status first, then what state laws require, with named examples and citations.

Information last verified on October 21, 2026. This article has not been reviewed by a licensed lawyer.

Jurisdiction scope: This page covers the federal status of the FTC's Negative Option Rule, ROSCA (15 U.S.C. 8403), federal card and bank dispute rules, and examples of US state automatic renewal laws. It does not cover sector rules set by federal or state utility, telecom or insurance regulators, the law of other countries, or any one company's terms of service.

Your state's subscription cancellation rules

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Checked against the statutes on October 21, 2026. Your contract and any exemptions in the statute decide whether a rule covers you.

Build a cancellation letterAll states

Is there a federal click-to-cancel rule?

No. In 2024 the FTC amended its Negative Option Rule to add what was widely called a click-to-cancel requirement. On July 8, 2025, the Eighth Circuit vacated that rule. The court wrote: "Concluding that the Commission failed to follow procedural requirements under § 22 of the Federal Trade Commission Act ("FTC Act"), 15 U.S.C. § 57b-3(b)(1), we grant the petitions for review and vacate the Rule" (Custom Communications, Inc. v. FTC, No. 24-3137 (8th Cir. 2025)). The defect was procedural: the agency skipped a required preliminary regulatory analysis.

What federal rule is in force now

The vacatur did not leave a blank. In the FTC's own words, "The Eighth Circuit's vacatur reinstated the prior version of the Rule which was first promulgated in 1973." That 1973 rule covers only "prenotification" plans, such as product-of-the-month clubs. It does not reach gym memberships or most subscriptions.

The 2026 advance notice

On March 11, 2026, the FTC asked for public comment on a new negative option rule. Its stated aim is "to help consumers avoid recurring payments for products and services they did not intend to order and to allow them to cancel such payments without unwarranted obstacles." An advance notice of proposed rulemaking is an early step. It is not a proposed rule or a final rule, and it does not create any new obligation for businesses.

ROSCA: the federal law that applies to online subscriptions

For subscriptions sold online with automatic charges, federal law still sets three requirements under ROSCA (15 U.S.C. 8403): clear disclosure of the terms, the consumer's express informed consent, and a way out. The statute's own words for the last one are that the seller "provides simple mechanisms for a consumer to stop recurring charges from being placed on the consumer's credit card, debit card, bank account, or other financial account."

That requirement is phrased in general terms. The state laws below are where specific cancellation methods are spelled out.

The FTC has brought ROSCA claims in court. On August 20, 2025 it sued the operators of LA Fitness, alleging that they made cancelling gym memberships exceedingly difficult; the case is pending, and its claims are allegations, not findings. For what that chain's own page says about cancelling, see how to cancel an LA Fitness membership.

What state automatic renewal laws require

Many states have an automatic renewal law, and some regulate only one sector. The common elements are disclosure, consent, a cancellation method, reminders and free-trial rules, but each law covers only the offers it defines. The examples below show how much they vary.

Disclosure and consent before the first charge

• California: an offer with a free gift or trial must clearly explain the price charged after the trial, and the business must say how to cancel and allow cancellation before the consumer pays (Cal. Bus. & Prof. Code 17602(a)(1), (a)(3)).
• Vermont: a covered contract cannot renew automatically unless its renewal terms were in bold type, the consumer separately opted in, and the seller sent a notice 30 to 60 days before the renewal, termination or cancellation-notice date, whichever comes first (9 V.S.A. 2454a(a)(1)-(3)).
• Maine: the seller must clearly disclose the cancellation methods, charges and refund policy and get the consumer's express consent by checkbox, signature or similar action (10 M.R.S. 1210-C(2)).
• Oregon: a business may not charge without the consumer's affirmative consent to the renewal terms (ORS 646A.295(1)(b)).

Online cancellation for online sign-ups

This is the core of what people call click to cancel, and the states word it differently:

• California: a business that lets a consumer sign up online must let the consumer cancel exclusively online, at will, through a prominent direct link or button or a ready-made termination email, without steps that obstruct or delay cancellation (Cal. Bus. & Prof. Code 17602(d)(1)).
• New York: a business must let a consumer cancel at any time through the same medium used to sign up, with a mechanism as easy to use as the sign-up, so a consumer who joined online can cancel online (N.Y. Gen. Bus. Law 527-a(1)(d), (d-1)).
• Illinois: a consumer who accepted an automatic renewal or continuous service offer online must be allowed to cancel exclusively online, for example by a ready-made termination email or a cancellation link (815 ILCS 601/10(b-5)).
• Maryland: the cancellation mechanism must be at least as easy as signing up and available through the same medium, without having to deal with a live or virtual representative unless one was used to sign up (Md. Code, Com. Law 14-1329(b)(3)(ii)).
• Connecticut: a business that entered into an automatically renewing agreement online must let the consumer stop the renewal or end the service online without any offline step. Since July 1, 2026 a business may also offer a phone number shown on its website, but a phone number does not replace the online option (Conn. Gen. Stat. 42-158ff(e)(1), (e)(2)).
• Minnesota: a seller whose website has profile or subscription management must put a clear, plain-language termination option on the site, using a checkbox or button (Minn. Stat. 325G.60 subd. 2).

Colorado's version works differently. Its statute says a business complies with Colorado's easy-cancellation duty by giving a consumer who signed up online a one-step online cancellation link, available right after a reasonable authentication step (C.R.S. 6-1-732(1)(d.7), (2)(d)(I)). That is written as a compliance safe harbor: a business that offers the link meets the duty.

Some laws reach only part of the market. Idaho's covers automatically renewing subscriptions entered into over the internet, where the agreement was entered into or renewed on or after January 1, 2023, so a subscription made offline is outside its text (Idaho Code 48-603G). Vermont's covers only contracts with an initial term of one year or longer that renew for more than a month, so monthly plans fall outside it (9 V.S.A. 2454a).

Phone lines, retention offers and other obstacles

Several states address the cancellation call and the "are you sure" offer:

• California: a business must answer cancellation calls promptly and return voicemail requests within one business day, and may make a retention offer only if the consumer can still cancel right away (Cal. Bus. & Prof. Code 17602(c), (e), (f)).
• Connecticut: a retention pitch on a cancellation call is allowed only after telling the caller they can cancel at any time by saying cancel (Conn. Gen. Stat. 42-158ff(b)(1)(A), (e)(2)(C), (e)(3), (e)(4)).
• New York: a business may not obstruct or unreasonably delay a cancellation, for example by hanging up or giving false information about how to cancel (N.Y. Gen. Bus. Law 527-a(1)(e)).
• Virginia: a consumer cannot be forced to talk to a live or virtual agent to cancel unless sign-up also required one (Va. Code 59.1-207.46(B)(4)-(7)).
• Minnesota: after receiving a cancellation the seller may not use abusive tactics or make retention offers without the consumer's permission (Minn. Stat. 325G.57 subd. 2(3)(ii); 325G.58 subd. 4; 325G.59).
• Colorado: any retention offer during online cancellation must sit beside a visible cancel link, and the cancellation must then be processed promptly (C.R.S. 6-1-732(2)(d)(II), (2.5)).

Renewal reminders

Reminder rules are where the state laws differ most. A few examples:

Oregon's law sets no pre-renewal reminder, but a business must give clear notice of a material change in terms, with how to cancel, before the change takes effect (ORS 646A.295(3)). Connecticut has required an annual reminder naming the subscription, how to cancel and the charges since July 1, 2026 (Conn. Gen. Stat. 42-158ff(d)).

Free trials

Free trials get their own notice rules in several states:

• New York: for a free trial longer than a month, the business must send a reminder 3 to 21 days before the cancellation deadline for the first charge (N.Y. Gen. Bus. Law 527-a(1)(a), (h)).
• Minnesota: for free trials over 30 days the seller must notify the consumer 5 to 30 days before the trial ends (Minn. Stat. 325G.57 subd. 4).
• Utah: for a free trial, the business must send a notice at least three days before the trial ends giving the end date, the price after the trial, and how to cancel (Utah Code 13-70-201(2)).
• Illinois: for a free trial or promotional period of 15 days or longer the business must notify the consumer at least 3 days before the cancellation deadline (815 ILCS 601/10(a-5)).
• Maryland: for a free trial over 14 days, the notice of the renewal, price and cancellation methods goes out 3 to 21 days before renewal (Md. Code, Com. Law 14-1329(c)).

Who enforces these laws

Whether you can sue under one of these laws, or only complain, depends on the state:

• Colorado: only the Attorney General and district attorneys can enforce the section, so a consumer's route is a complaint to them rather than a private lawsuit under it (C.R.S. 6-1-732(6)).
• Maryland: a violation is an unfair, abusive or deceptive trade practice, but the section does not create a private right of action (Md. Code, Com. Law 14-1329(g), (h)).
• New York: the Attorney General can seek an injunction, restitution and civil penalties; the section itself gives consumers no private lawsuit (N.Y. Gen. Bus. Law 527-a(2), (3)).
• North Dakota: an aggrieved person may sue for an injunction or restitution plus attorney fees (N.D.C.C. 51-37-02(4), 51-37-04, 51-37-06).
• Maine: a seller found in violation over unauthorized subscription or membership charges must refund or credit three times the unauthorized amount, unless the violation was an error that the seller fully refunded (10 M.R.S. 1210-D).
• Unconditional gifts: in California, Minnesota, Oregon and Virginia, goods sent without the consumer's affirmative consent are treated as an unconditional gift (Cal. Bus. & Prof. Code 17603; Minn. Stat. 325G.61; ORS 646A.295(5); Va. Code 59.1-207.47).

States with a sector rule or no general law

Not every state has a general automatic renewal law. New Jersey has no general automatic renewal law; one rule covers property service contracts such as extended warranties that run 12 months or longer, and another requires online cancellation only for health club memberships sold online (N.J.S.A. 56:12-95.5; 56:8-42.1). Maine's law covers only listed online services (online periodicals, media players, mobile apps, social networking, internet games and online software) plus for-profit health club memberships (10 M.R.S. 1210-C). Kansas, Montana, Texas and West Virginia have no general automatic renewal statute.

Louisiana: new rules starting January 1, 2027

Louisiana's current law requires a business to clearly disclose how to cancel in the initial contract, offer, or with delivery, but sets no particular cancellation method (La. R.S. 9:2716(B)). If a contract is renewed in violation of the disclosure rules, it reverts to a 30-day renewal on the same terms, unless the business shows written compliance procedures, an error, and a full refund or credit (9:2716(C), (E)).

Starting January 1, 2027, Act 830 of 2026 adds a cancellation duty for businesses with at least 50 employees and at least $5 million in annual gross revenue, counting parents, subsidiaries and affiliates. Those businesses must give Louisiana consumers a cost-effective, timely and easy-to-use cancellation mechanism, online or by email, phone or another commonly used method, that is not unreasonably burdensome or designed to deter cancellation and stops future charges. The Attorney General may impose civil penalties of up to $500 per violation after a 30-day cure period, with willful or repeated violations excepted (La. R.S. 51:3303(A)(7), (D); 51:3304; 51:3305). A business below either threshold is outside the new duty.

Gym memberships and auto-renewal laws

A gym membership that renews automatically can be covered twice: by your state's gym act and by its automatic renewal law, each within its own scope. Minnesota's automatic renewal law names health club contracts among what it covers (Minn. Stat. 325G.56 to 325G.63). Maine's covers for-profit health club memberships entered into or renewed on or after January 1, 2026 (10 M.R.S. 1210-C). In California, when the gym law itself gives a right to cancel, you may cancel in person, by email from an address on file or by first-class mail (Cal. Civ. Code 1812.84(c)), and if you accepted an auto-renewing gym membership online, the automatic renewal law also requires an online way to end it (Cal. Bus. & Prof. Code 17602(d)(1)).

Gym acts also have their own renewal limits. Pennsylvania's Health Club Act and Maryland's health club law both bar automatic renewal clauses unless the agreement gives a renewal option you must accept. For the full gym picture by state, see how to cancel a gym membership.

Streaming, apps, boxes and other subscriptions

The same state law applies to a streaming service, an app, a meal kit or a subscription box as to any other automatic renewal, as long as the offer falls inside that law's scope. The scope is the thing to check, because the exemptions differ:

• California's law exempts utilities and telecom services regulated by the CPUC, FCC or FERC, insurers, alarm companies, banks and credit unions, and regulated service contract sellers (Cal. Bus. & Prof. Code 17600-17606).
• Connecticut's law does not cover national audiovisual streaming services, along with utility, telecom and FERC regulated services, insurers, banks and credit unions (Conn. Gen. Stat. 42-158ff).
• New York's law excepts local franchise services such as cable (N.Y. Gen. Bus. Law 527-a).
• Utah's law covers contracts that renew into a paid term longer than 45 days, so monthly plans are outside it (Utah Code 13-70-101).

Whatever the product, keep a screenshot of the cancellation confirmation. For a subscription offer that looks like a trap from the start, see scams and fraud.

Disputing charges after you cancel

When charges continue after a cancellation, federal rules give you a route through your card issuer or bank:

• Credit card: a written billing-error notice must reach the card issuer, at the address it gives for billing errors, "no later than 60 days after the creditor transmitted the first periodic statement that reflects the alleged billing error" (12 CFR 1026.13(b)).
• Debit card or bank transfer: an oral or written error notice must reach the bank within 60 days after it sent the statement that first shows the charge (12 CFR 1005.11(b)(1)(i)).
• Stopping future debits: you can tell your bank to stop a preauthorized electronic payment, orally or in writing, at least three business days before the payment is scheduled. If you call, the bank may require written confirmation within 14 days, and an unconfirmed oral stop order then lapses (12 CFR 1005.10(c)(1)-(2)).

Some state laws add their own refund rule. In Tennessee, if a business charges without the consumer's affirmative consent, it must refund the charge when the consumer asks within seven days of the charge (Tenn. Code Ann. 47-18-133, as amended by Pub. Ch. 835 (2024)).

You can report a problem to the Federal Trade Commission, to the Consumer Financial Protection Bureau for a card or bank issue, or to your state attorney general. A demand letter and the small claims court finder can help with a refund the business will not pay.

How to cancel a subscription and keep proof

Cancel through the channel the law and the terms give you, then keep evidence:

• Save the confirmation email or a dated screenshot of the final cancellation screen.
• If you cancel by phone, note the date, time and any confirmation number.
• If you send a letter, keep a copy and the mailing receipt. The cancellation letter generator drafts one and adds your state's automatic renewal rule where there is one; see its pages for California, Colorado and Louisiana.
• Check your next statement. If a charge posts anyway, the 60-day dispute windows above start running from that statement.

Automatic renewal laws by state

The table below shows each state's automatic renewal rule, split by region, with a link to that state's page in the letter generator.

Related

• How to cancel a gym membership: state laws and a letter
• Cancellation letter generator
• How to cancel a Planet Fitness membership
• How to cancel an LA Fitness membership
• How to cancel a Crunch Fitness membership
• How to cancel an Anytime Fitness membership
• Scams and fraud

This page provides general legal information about subscription cancellation under US federal law and state automatic renewal laws as of October 21, 2026. It is not legal advice. For advice about your own contract, contact a lawyer licensed in your state or your state attorney general's consumer protection office.

Last updated: October 21, 2026.

Frequently Asked Questions

Is the FTC click-to-cancel rule in effect?

No. The Eighth Circuit vacated the FTC's 2024 click-to-cancel rule on July 8, 2025 (Custom Communications, Inc. v. FTC, No. 24-3137). The 1973 rule that came back covers only prenotification plans.

What did the FTC do in 2026?

On March 11, 2026 the FTC asked for public comment on a new negative option rule. An advance notice of proposed rulemaking does not create any new obligation for businesses.

Which federal law covers online subscriptions?

ROSCA (15 U.S.C. 8403). For subscriptions sold online with automatic charges, it requires clear disclosure of the terms, the consumer's express informed consent and simple mechanisms to stop recurring charges.

Do state laws require online cancellation?

Some do, within their scope. California, New York and Illinois, for example, require online cancellation for a consumer who signed up online (Cal. Bus. & Prof. Code 17602(d)(1); N.Y. Gen. Bus. Law 527-a(1)(d); 815 ILCS 601/10(b-5)).

Does a click-to-cancel law apply to my gym membership?

It can, if the membership falls inside the law's scope. Minnesota's automatic renewal law names health club contracts, and Maine's covers for-profit health club memberships entered into or renewed on or after January 1, 2026 (Minn. Stat. 325G.56 to 325G.63; 10 M.R.S. 1210-C).

When does Louisiana's click-to-cancel law take effect?

Starting January 1, 2027, for businesses with at least 50 employees and at least $5 million in annual gross revenue, counting parents, subsidiaries and affiliates (La. R.S. 51:3303(A)(7)).

Do I have to get a renewal reminder before I am charged?

Only where a state law requires one and your plan fits its trigger. Illinois, for example, requires written notice 30 to 60 days before the cancellation deadline for contracts of 12 months or more that renew for more than a month (815 ILCS 601/10(b)).

What if I keep getting charged after cancelling a subscription?

Dispute the charge with your card issuer or bank within 60 days of the statement that first shows it (12 CFR 1026.13(b); 12 CFR 1005.11(b)(1)(i)). For a bank debit, a stop-payment order must reach the bank at least three business days before the scheduled payment (12 CFR 1005.10(c)).