The FTC announces a final 'Click-to-Cancel' rule modernizing consumer protections for recurring subscriptions, requiring businesses to make cancellation as easy as signup and prohibiting deceptive marketing. The content advocates for consumer rights across fair treatment, property protection, effective remedy, and democratic participation, developed through transparent 16,000-comment public process. The FTC's regulatory authority and structural commitment to enforcement provide institutional backing for consumer protection rights.
Does the FTC actually have the power to set rules like this effectively now that Chevron deference isn't a thing? I'd imagine e.g. the New York Times, among others, will quickly sue to stop this, no?
There are so many things like this that have needed fixing for such a long time. The fact that something is happening, even slowly, is so heartening.
If your reaction is wondering if this is legal then you should be interested in the passing of new laws that make it unequivocally legal. Society should be able to govern itself.
My workaround to this has been to email the company telling them I want to cancel. Once I either don't get a reply, or get a reply saying "just call us and we'll cancel!", I dispute the next charge with American Express and have the email record of trying to cancel. I believe they also offer a "stop allowing charges by this merchant" feature that cuts off future charges.
> will require sellers to make it as easy for consumers to cancel their enrollment as it was to sign up.
I am very curious what exactly this means? Is it the number of pages or forms you had to fill out? People you had to talk too?
So if for my internet I had to have someone come out to install it before service would start could they argue that they require someone to physically come out to turn off service? Or a call since a call would be "easier" than someone coming out?
Could they make the signup and cancel process worse at the same time at certain times of the year if there is a certain time of the year where cancelations are high to justify a worse process? Or does this require knowing what the process was like when each customer signed up?
It feels like this could be fairly easily manipulated. Throw in an extra page during sign up just so they can add in an extra "please stay" page when you try to cancel.
> most notably dropping a requirement that sellers provide annual reminders to consumers of the negative option feature of their subscription.
I assume this means sending yearly reminders that a subscription is about to charge and how to cancel? This is fairly disappointing if so.
I really wish they just required what Apple requires on the App Store. It requires 2 clicks, clicking cancel and then confirm. No upselling since it all happens within Apple's Settings.
Then any yearly apps I always get an email about a week or so (not 100% sure of the timing) that it is going to renew soon with instructions on how to cancel.
Nice. I canceled a service recently and I had to "continue to cancel" and click on other such "confirmations" such that I think I proceeded through 7-8 pages before my subscription was actually canceled. Truly manipulative and obtuse. That was Spotify btw. I should have recorded the process, as it was nearly comedic (if it weren't so hostile).
It would be great to see the FTC go against predatory subscription services like Adobe. I'm fuzzy on the exact details, but I think they promoted a yearly subscription that was meant to look like a monthly subscription, where if you cancelled early they would charge you an exorbitant cancellation fee. I'm not sure how these new rules affect them.
One recent idea I've had is that many online subscription services should automatically pause if you stop using it. For example: if I go a full monthly billing cycle without watching Netflix then my subscription should automatically pause and allow me to resume it next time I log-in. There's a ton of money that gets siphoned off to parasitic companies just because people forget to cancel their subscriptions or because they're too busy dealing with life. It might not be viable for all companies, but there's definitely a lot of services where such a thing would be possible, given the huge number of customer analytics they collect. Maybe give people the option to disable such a pause feature if they're really determined to keep paying for a service. But a default where subscriptions automatically pause if you're not using them makes a lot of sense from a user perspective. Of course businesses would probably hate such a ruling because it means they can't scam as much easy money.
They should clean up their act anyway. If other customers are like me I’ve been putting off joining for over a year because they’re so scammy and I don’t want to get locked in.
I even went to sign up and walked out because the price ended up being double what they advertised with weird fees and the base plan not being useable once they explain it.
It seems like all this sketchiness actually hurts these companies. I do ten times more subscriptions when I can go through apple and know I can cancel in 5 seconds.
I once moved towns and needed to cancel my LA Fitness gym membership. I found that they wanted me to go to their website, find the Cancellation Form, print it out, fill it out with my account details, and mail or fax it to their corporate office. I don’t believe there is any way of cancelling it online or over the phone.
So instead of doing that all of that, I called my credit card company and asked them to block all future charges from the company. It worked like a charm.
Past canceling, there are so many problems with subscription programs. Too many products are unusable without a subscription that offer no additional value. Or disabling the subscription cripples product features that have no dependency on the remote service. Or they can 'alter the deal' at any point where what you get for what you pay can change despite the fact the product hasn't.
Ideally 'the market' would punish such companies but it seems to do the opposite in that once a dark pattern becomes mainstream, everyone quickly adopts it, and consumers don't really get any real choices.
When people try and say that regulating stuff like this is impossible, I often think about how unreasonably great the regulations around “Unsubscribe” links in emails are.
There really seems to be no loophole or workaround despite there being huge incentive for there to be one. Every time I click an “Unsubscribe” link in an email (it seems like they’re forced to say “Unsubscribe” and not use weasel words to hide the link) I’m either immediately unsubscribed from the person who sent me the email, or I’m taken to a page which seemingly MUST have a “remove me from all emails” option.
The level of compliance (and they can’t even do malicious compliance!) with this is absurd. If these new rules work anything like that, they’ll be awesome. Clearly regulating behavior like this is indeed possible.
What surprises me is that I don’t see any comments here from people lamenting that their business will be negatively affected by this. Surely there are founders or engineers on HN involved with companies that will lose profit if they allow their customers to cancel their services.
Any kindergartner with a good heart would tell you immediately that the companies targeted by this rule are doing it wrong. That there are so-called professional adults who enjoy any level of respect or status in society running said businesses is a joke.
The nice thing about this is that most companies already have everything in place to do it, because California has had this rule for a few years. So all they have to do is remove the "not in California" filter.
The New York Times can suck a lemon, 40 minutes of my life, multiple calls and transfers to cancel a subscription. Hopefully this will be meaningfully enforced.
The problem is actually in the payment system itself. A credit card number + expiry + ccv + name is essentially like giving out a username + password to your money. We hand out the same username / password to everybody and everything works on the honor system after that. At any given time there are likely hundreds of companies that have your username/password and can charge whatever they want at any time. If anything looks fishy, is up to you to investigate and get charges reversed.
Instead, I should be able to seamlessly create new credentials per vendor with expiration and limits. I should also be able to stop payment at any time.
Chevron deference is about statutory interpretation so it really depends on the statue they are doing it under and any ambiguities that arise around the ability to do this. It may be clearly covered or it may not be, we would have to look. And if there are ambiguities it may go the way of the FTC, but since Chevron is gone, not automatically.
The rule wasn't adopted with unanimity and one of the FTC Commissioners (Melissa Holyoak) issued a dissenting statement that basically - with Chevron - will serve as a blueprint for contesting its adoption. [0] If the past is a guide to the future, it can be expected that the 5th Circuit will be the first out of the gate with a ruling.
Agreed. The fact that multiple companies are springing up with the main selling point being "help you cancel subscriptions you thought you already cancelled" should be a wake up call to the legislature that this problem has gotten out of hand.
> I believe they also offer a "stop allowing charges by this merchant" feature
If they have this it's another reason to use them for automatic billing. I have tried to do this with a VISA card and they said they cannot do it; the only way to prevent future charges would be to close that account entirely and even then I might still get billed for some period of time.
This is good to know. I had Dropbox billing through PayPal and could never cancel charges in anyway through the Dropbox site. Realized I had to disassociate PayPal and the recurring charge said “payment failed”. Finally effectively canceled.
LPT: if you're not a customer but you get their mailing advertisements and want them to stop, create an account with them on their website then update your address to their headquarters.
If you call and tell them to stop, they will only stop for 2 years then resume. Or resume when you take your vehicle to someplace that (re)sells your information to them.
AmEx is great for this. I've used it twice, no issues that I can tell. I had my personal card attached to a BrowserStack account that used a work email address. Forgot to cancel it when I left the job and BrowserStack support was completely useless. One chat session with AmEx later and I receive no more charges from BrowserStack.
Of course I have to remember that they are blocked on that card, should I ever need an account again in the future.
This feels like one of those things that could be solved on the payment end with something like a unique payment ID for each subscription, rather than giving a CC number. Then you just enable or disable payment IDs (perhaps for a limited time, e.g., "create a payment ID that works for Netflix for the next three months but not after that"), rather than relying on vendors to decide whether they feel like charging you or not.
> could they argue that they require someone to physically come out to turn off service?
In the case of in-person consent the rule requires that they also offer an online or telephone cancellation option.
> Could they make the signup and cancel process worse at the same time [...]
"must be at least as easy to use as the mechanism the consumer used
to consent to the Negative Option Feature.". I read that it must hold true for every specific consumer based on how hard it was for them to consent.
The rules also sets general restrictions to the online and phone options in addition to the "at least as easy" restriction. For Online the cancellation option must be "easy to find" and explicitly bars forced interaction with representatives or chatbots during cancellation unless they were part of the sign-up process. For Telephone the cancellation must be prompt, the number must be answered or accept voice messages, must be available during normal business hours, and must not be more costly than a call used to sign up.
The FTC has rule making authority but it will certainly be litigated.
My expectation is a case will quickly be brought in the Northern District of Texas, they'll rule it unlawful (following Commissioner Holyoak's lead), then it'll get bumped up to the 5th Circuit on appeal and they'll issue a stay.
I don't expect to see this rule take affect anytime soon, if ever.
> One recent idea I've had is that many online subscription services should automatically pause if you stop using it.
Cool idea, but probably tough to enforce what “using it” means. I could see companies start sending newsletters to customers and calling that engagement
Yeah Spotify removed one of my family members from my 5-person subscription (only using 3 slots) so I immediately cancelled my subscription and had to deal with a lot of manipulative tactics to not cancel. This kind of behaviour 1, shouldn't be legal and 2, shouldn't be rewarded. I have plenty of Spotify alternatives, so this kind of behavior ultimately signals a floundering company resorting to hacks.
Conversely there is a gym in my town that was a month to month subscription with moments notice cancellation. They'd even pro-rate your remaining time back to you. I ended up joining and cancelling those gyms a lot through college years, but I'm much more willing to rejoin if it was easy to cancel.
If you setup a "payment agreement" between yourself, the gym (or any similar service), and your credit card, you should be able to cancel that agreement and the subsequent services that agreement entailed through your credit card. The byzantine and manipulative things that gyms do are, in part, because we basically let them control the cancellation process.
If you can sign up for the gym online, then you need to be able to cancel online. That's how this rule is meant to work for all kinds of merchants. Gyms would still be free to pull their usual car-salesman shenanigans on cancellation if they're willing to only take new subscriptions on location and not online, too.
> I think they promoted a yearly subscription that was meant to look like a monthly subscription, where if you cancelled early they would charge you an exorbitant cancellation fee. I'm not sure how these new rules affect them.
I don't think it's the same situation. What Adobe was doing was offering a yearly subscription, charged monthly. If you tried to cancel, it would ask for payment to either cover the rest of the sub or to cover the "savings" that the user had obtained by selecting an annual sub rather than a true monthly (can't remember what exactly it tried to charge). It was deceptive as hell, but it's probably not covered by this rule.
The worst part is it poisons the whole business model for me. Even if your company could restrain itself from these tactics I won't know that until it is to late and even if I did research it there isn't any reason it couldn't change to be awful from being OK. The end result is I turn my nose at the very idea because subscription services are fine with me as an idea but in practice I just don't want to waste the energy dealing with them.
For every "you" avoiding subscriptions, there's an idiot like me who has had several $5-10/mo. subscriptions for years because I keep hitting the "call customer service to cancel" wall and procrastinating.
It absolutely does. I got bit by the NYT back when they had call-to-cancel, and I won't subscribe to any company that doesn't have an unsubscribe button. I just search "bla company unsubscribe," and if it's call to cancel, I won't subscribe.
When people buy an app on the app store they kind of expect it to work in perpetuity. This would be fine, but the environment changes and people still expect it to keep working. It is reasonable to expect an app I bought on my iPhone 4 using iOs 4 (or whatever it was) to work in perpetuity on that phone and that OS. It is less reasonable to expect it to run on my iPhone 16 on iOs 18, but that is what people expect.
The other thing that app stores did was dramatically lower the price point of software. In 2000, you could go to the store and expect to pay $50+ for an "app". Now, $9.99 is considered a higher price point, and we expect it to be maintained in perpetuity.
Given those constraints, a subscription model is actually pretty reasonable.
Add in that the investors in many companies are hyper focused on MRR, and subscriptions are the only viable way for a startup to work.
Man, I remember when Amazon Prime first started, I signed up for the free trial to get free shipping on something. Of course, I forgot about it and didn’t cancel, but then I got an email from Amazon saying, “hey, you didn’t cancel your prime subscription but you also haven’t used it at all, so we are going to not charge you and cancel it for now. Here is how you easily restart your subscription if you end up needing it”
It was such a wonderful feeling that clearly impacted me so much I remember it some 20 years later. I gained SO MUCH loyalty to Amazon after that, and sure enough, I restarted my prime subscription a bit later when I got a better job and started ordering more stuff. They made so much more money off me because they sacrificed those few dollars for one month of my subscription fee to show me they weren’t just trying to make me forget to cancel.
Amazon today would never do that, of course, but man I think more companies should if they want long term, loyal, customers.
You're overthinking it. If there's any confusion, it will go to court, and reasonable humans will decide that, actually, the form being in a filing cabinet in the basement isn't actually reasonable.
It is up to the company to not pursue you for the money. Contractually, you probably still owe them the money, unless there is a clause in the contract that says that non-payment is a way to cancel the membership. They could legally pursue that, or sell it to someone else to pursue.
Not paying is not the same thing as not owing. Many companies will just let it drop. Some won't
Content explicitly advocates for consumer protection, using strong language to frame subscription cancellation barriers as unfair practices. Chair Khan's statement emphasizes dignity and freedom from exploitation.
FW Ratio: 60%
Observable Facts
Commission Chair Lina M. Khan states: 'Too often, businesses make people jump through endless hoops just to cancel a subscription. The FTC's rule will end these tricks and traps, saving Americans time and money.'
The rule 'will require sellers to make it as easy for consumers to cancel their enrollment as it was to sign up.'
The Commission voted 3-2 to approve the final rule, with Commissioners Melissa Holyoak and Andrew N. Ferguson voting no.
Inferences
The framing of subscription practices as 'tricks and traps' advocates for treating consumer manipulation as an unfair practice.
The FTC positions itself as a protector of consumer dignity against deceptive business design.
The rule explicitly requires 'a simple mechanism to cancel the negative option feature and immediately halt charges,' providing direct, effective remedy for contract violations.
FW Ratio: 50%
Observable Facts
The rule 'require[s] sellers to provide a simple mechanism to cancel the negative option feature and immediately halt charges.'
The rule prohibits 'failing to provide a simple mechanism to cancel the negative option feature and immediately halt charges.'
Inferences
Immediate cessation of charges upon cancellation provides concrete, effective remedy for consumers.
The 'simple' mechanism requirement ensures remedy is practically accessible, not just theoretically available.
The rule's core requirement—'make it as easy to cancel as to sign up'—explicitly enforces equal treatment. Prohibition on misrepresentation ensures equal protection under marketing law.
FW Ratio: 50%
Observable Facts
The rule requires 'make it as easy for consumers to cancel their enrollment as it was to sign up.'
The rule prohibits 'misrepresenting any material fact made while marketing goods or services with a negative option feature.'
Inferences
The equal-ease-of-cancellation principle directly operationalizes equal treatment in contract termination.
Misrepresentation prohibition protects equality of information access.
The rule protects consumers' property (money) from being taken through 'tricks and traps' of difficult cancellation. Explicitly addresses 'failing to provide a simple mechanism to cancel' that leads to ongoing unwanted charges.
FW Ratio: 50%
Observable Facts
Chair Khan states: 'Nobody should be stuck paying for a service they no longer want.'
The rule addresses 'tricks and traps' that cause businesses to obtain continued payment through difficult cancellation.
Inferences
Preventing forced payment through manipulative design protects property rights against unjust taking.
The 'simple mechanism' and 'immediately halt charges' requirements prevent ongoing property loss to non-consensual billing.
The rule was developed through extensive public notice-and-comment process (16,000+ comments), demonstrating commitment to fair and public hearing principle.
FW Ratio: 50%
Observable Facts
The rule followed 'a notice of proposed rulemaking which resulted in more than 16,000 comments from consumers and federal and state government agencies, consumer groups, and trade associations.'
The Commission vote was 3-2, with 'Commissioners Melissa Holyoak and Andrew N. Ferguson voting no' and separate statements published from Commissioner Slaughter and Commissioner Holyoak.
Inferences
The 16,000-comment process demonstrates broad public participation and fair hearing opportunity.
Publication of dissenting and separate statements shows transparency in government decision-making.
The rule development included extensive public participation: 16,000+ comments from diverse stakeholders (consumers, government agencies, advocacy groups, trade associations). Transparency about dissenting views.
FW Ratio: 50%
Observable Facts
The rule development included 'more than 16,000 comments from consumers and federal and state government agencies, consumer groups, and trade associations.'
Dissenting statements from Commissioners Holyoak and Slaughter were published alongside the rule announcement.
Inferences
The 16,000-comment process demonstrates meaningful opportunity for citizens to participate in regulatory decision-making.
Publication of dissenting views shows commitment to democratic process transparency.
The rule prohibits 'misrepresenting any material fact' in marketing and requires 'clearly and conspicuously disclose material terms,' protecting the right to accurate information.
FW Ratio: 50%
Observable Facts
The rule prohibits sellers from 'misrepresenting any material fact made while marketing goods or services with a negative option feature.'
The rule requires sellers 'to clearly and conspicuously disclose material terms prior to obtaining a consumer's billing information.'
Inferences
The misrepresentation prohibition protects consumers' right to truthful information about subscription features.
The clear disclosure requirement supports freedom of information by ensuring comprehensible access to material contract terms.
The rule balances consumer protection with business interests: 'While negative option marketing programs can be convenient for sellers and consumers...' Also explicitly preserved seller communication rights regarding plan modifications.
FW Ratio: 50%
Observable Facts
The text states: 'While negative option marketing programs can be convenient for sellers and consumers, the FTC receives thousands of complaints...'
The final rule dropped a prohibition that would have blocked sellers from 'telling consumers seeking to cancel their subscription about plan modifications or reasons to keep to their existing agreement.'
Inferences
The balanced framing acknowledges legitimate interests of both consumers and businesses.
The preservation of seller communication rights shows the rule prioritizes cancellation freedom while respecting some business communication.
The rule requires 'consumers' informed consent to the negative option feature before charging them,' protecting financial autonomy and freedom from unwanted interference.
FW Ratio: 50%
Observable Facts
The rule requires sellers 'to get consumers' informed consent to the negative option features before charging them.'
Inferences
Mandatory informed consent protects consumers' autonomy over their financial accounts and privacy of payment information.
The rule protects human dignity indirectly by preventing manipulation and deception. Disclosure requirements support dignity through informed decision-making.
FW Ratio: 50%
Observable Facts
The rule requires sellers to 'provide important information before obtaining consumers' billing information and charging them.'
Inferences
Clear disclosure supports human dignity by respecting consumers' capacity to reason about their own financial obligations.
The rule explicitly addresses 'an increasingly digital economy,' showing awareness of global, interconnected commercial practices and their cross-border impact.
FW Ratio: 50%
Observable Facts
The rule addresses the context of 'an increasingly digital economy where it's easier than ever for businesses to sign up consumers for their products and services.'
Inferences
The rule's digital economy framing reflects recognition of international commerce and the need for harmonized consumer protection standards.
FTC's regulatory authority and enforcement structure provide institutional foundation for rights protection. Links to legal resources and enforcement mechanisms support structural implementation.
Chair Khan: 'Too often, businesses make people jump through endless hoops just to cancel a subscription. The FTC's rule will end these tricks and traps, saving Americans time and money.'
appeal to authority
Quote from Commission Chair Lina M. Khan; government official authority framing throughout.
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