model provisions in click to cancel legislation
Clear, upfront terms and pricing
Consumers should know what they’re signing up for, how much it will cost, and how to cancel.
Affirmative express consent
Companies should enroll consumers only after consumers have granted clear consent, and without the use of dark patterns.
Regular reminders
For subscriptions that automatically renew, companies should remind consumers about upcoming payments and give them a chance to cancel before imposing charges.
Cancellation that mirrors sign-up
Companies should make cancelling subscriptions as easy as enrolling, including allowing online cancellation when enrollment is online.
No exemptions
No company is above the law. Efforts by gyms, cable companies, and others to gain an unfair advantage and secure special exemptions should be rejected.
Accountability for violations
In order to deter violations and ensure relief for consumers, both enforcers and harmed individuals should be able to challenge subscription traps.
The Federal Trade Commission Rule
States considering Click-to-cancel legislation should ensure that these provisions are codified
In 2024, the FTC finalized its overwhelmingly popular Click to Cancel Rule, which would have required industry wide compliance with many of the model provisions.
In July 2025, a federal appellate court vacated the FTC’s rule on procedural grounds. While the FTC could re-start the years-long rulemaking process, it is unlikely to do so.
Wih no federal rule, consumers are vulnerable unless states take action to ban subscription traps.