The Federal Trade Commission (“FTC”) set out to modernize the Negative Option Rule promulgated in 1973, now referred to as the “Click to Cancel” rule (the “Rule”), to make it easier for consumers to cancel recurring subscriptions and memberships.[1] We previously provided an in-depth discussion of the Rule in an earlier blog post, which is available here. The Rule was scheduled to take effect on July 14, 2025 after the original compliance date of May 14, 2025 was extended.[2] However, on July 8, 2025, the Eighth Circuit vacated the Rule on the grounds of procedural deficiencies.[3]Continue Reading Eighth Circuit Says Not So Fast to FTC’s “Click to Cancel” Rule


