IN EFFECT since December 29, 2010
Last verified against primary sources:
FTC Negative Option / ROSCA (Auto-Renewal)
US-Federal · Effective December 29, 2010
Online subscriptions must provide clear disclosure, express consent, and easy cancellation (ROSCA + ~30 state auto-renewal laws). The FTC 'click-to-cancel' rule was vacated in July 2025.
Overview
The FTC's amended Negative Option ('Click-to-Cancel') Rule was vacated in full by the 8th Circuit on July 8, 2025, on procedural grounds and is not in effect. The substance is still required under ROSCA and ~30 state auto-renewal laws (California, Colorado, New York, Massachusetts) - clear disclosure, informed consent, and simple cancellation. The FTC restarted rulemaking (ANPRM January 30, 2026; comments due April 13, 2026); a reissued rule is likely 2026 or later. California's amended auto-renewal law is treated by many as the de facto national standard.
Official text: https://www.ftc.gov/legal-library/browse/rules/negative-option-rule
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