Congress Revives Push for Nationwide “Click-to-Cancel” Standard on Subscriptions

Legislation intended to make canceling digital subscriptions as simple as signing up has resurfaced on Capitol Hill, where a bipartisan coalition is promoting a federal “click-to-cancel” mandate. The effort, centered on the newly introduced Unsubscribe Act, seeks to curb practices that automatically renew services and frequently frustrate consumers attempting to opt out.

House and Senate Align on a Single Proposal

The Unsubscribe Act, filed in the House of Representatives in mid-January, mirrors a Senate version first presented last July. Both texts would compel companies to provide a clear, easy-to-find online cancellation mechanism and to secure explicit consent before billing customers after a free or discounted promotional period.

Two additional measures introduced last July—one in each chamber—would broadly restore a Federal Trade Commission rule that was set to take effect in 2024 but never did. Collectively, the initiatives aim to establish uniform federal requirements for businesses that rely on automatically renewing contracts, commonly called “negative-option” agreements.

States Already Moving Ahead

While Congress weighs a nationwide approach, more than half of U.S. states have enacted their own statutes regulating subscription renewals and cancellation procedures. Because those laws are not fully aligned, companies with national footprints must navigate a patchwork of requirements. Legal analysts note that businesses often default to the strictest standard encountered among the various jurisdictions.

The proposed Unsubscribe Act would not override existing state rules. If enacted, companies would need to comply with federal provisions in addition to any applicable state mandates, further complicating regulatory compliance strategies for firms operating coast to coast.

Subscription Spending and Complaint Trends

Recurring digital services have become a fixture of household budgets. According to an April 2025 survey of 2,440 adults conducted online by YouGov for CNET, American consumers spend an average of $1,080 per year on subscriptions. Millennials report the highest outlay at roughly $1,215 annually. Respondents also estimate that $205 of those expenditures cover services they no longer use.

As spending has grown, so have complaints. Federal Trade Commission data show the agency received an average of nearly 70 complaints per day related to subscription issues in 2024, up from about 42 per day in 2021. The grievances commonly cite confusing cancellation processes, unclear disclosures, and surprise charges once promotional pricing expires.

FTC Rule Blocked, Advocacy Groups Respond

The FTC finalized its own click-to-cancel rule in October 2024, intending for it to become effective on July 14, 2025. Days before that deadline, the Eighth Circuit Court of Appeals vacated the regulation on procedural grounds, concluding that the agency had not completed an adequate economic impact analysis. The opinion did not address the substance of the rule itself.

Following the court’s decision, the Consumer Federation of America and the American Economic Liberties Project petitioned the FTC in November 2025 to restart the rulemaking process. The Commission published the petition in the Federal Register on December 3 and accepted public comments through January 2. The agency has not announced whether it will reopen the proceeding.

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Regulatory Enforcement Continues Under Existing Law

Even without a dedicated click-to-cancel regulation, the FTC is pursuing cases under the Restore Online Shoppers’ Confidence Act (ROSCA). In September 2025, the Commission disclosed a $2.5 billion settlement with Amazon, alleging that the company enrolled millions of users in Prime memberships without affirmative consent and erected obstacles to cancellation. On the same day, the FTC reached a $7.5 million settlement with education-technology firm Chegg over similar recurring-billing concerns. Details of ROSCA’s requirements and enforcement history can be found on the agency’s official website.

Key Provisions of the Unsubscribe Act

If enacted, the House and Senate bills would require companies that offer subscription services to:

• Provide a straightforward online method—such as a single click or comparable action—to cancel any subscription initiated online.
• Obtain consumer approval before charging after a free trial or introductory rate ends.
• Send a clear reminder notice before each automatic renewal if the subscription term exceeds one year.
• Maintain easily accessible contact channels, including a toll-free phone number, for customers who prefer to cancel offline.

Violations would be treated as unfair or deceptive acts under the Federal Trade Commission Act, enabling federal and state authorities to seek civil penalties and restitution.

Outlook in Congress

The multi-bill push reflects rare bipartisan agreement on consumer protection. Nonetheless, legislative prospects remain uncertain. Similar proposals in previous sessions stalled amid broader debates about federal rulemaking authority and business compliance costs. Whether the current Congress can reconcile the House and Senate versions and secure floor votes will depend on committee priorities, scheduling pressures, and the evolving regulatory landscape.

For consumers and businesses alike, the result could shape the ease of entering—and exiting—digital subscriptions for years to come.

Crédito da imagem: Maskot | Getty Images