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Efforts in Congress to create a federal “click to cancel” rule — intended to make canceling subscriptions as easy as it is to sign up for them — have ramped up.
A bipartisan House bill called the Unsubscribe Act was introduced in mid-January as a companion to a Senate measure proposed in July. Among other provisions, it would require companies that offer subscriptions to provide easy cancellations and to get consumers’ approval before charging them after a free or reduced-cost period.
The measure joins two other bills floated in July — one in each the House and Senate — that generally would reinstate a click-to-cancel rule from the Federal Trade Commission that didn’t take effect last year as scheduled due to a federal appeals court striking it down. The FTC’s rule was similar to the Unsubscribe Act.
Alongside the congressional push, more than half of states now have some sort of law on the books that is similar in theme to the Unsubscribe Act and the FTC’s rule, said Gonzalo Mon, a partner with the law firm of Kelley Drye & Warren in Washington.
“This does seem to be a bipartisan issue, and a lot of regulators are concerned about consumers getting into subscriptions without knowing all the details,” Mon said.
U.S. adults spend $1,080 yearly on subscriptions
So-called “negative option” subscription contracts — those that automatically renew unless canceled by consumers — have generated a growing number of complaints over time as their prevalence and usage have increased. While these subscriptions are easy to sign up for, they can be difficult to cancel.
In 2024, the FTC received an average of nearly 70 consumer complaints per day, up from 42 daily in 2021, according to the agency.
Each year, U.S. adults spend an average of $1,080 on subscriptions, according to a 2025 survey by CNET, a media website focused on consumer technology. By generation, millennials spend the most annually: $1,215. The survey was conducted online in late April by YouGov and involved 2,440 adults.
The average spent annually on subscriptions consumers no longer use is $205, according to the survey.
Consumer groups push back against canceled FTC rule
The FTC finalized its click-to-cancel rule in October 2024 under the Biden administration. It was quickly challenged in court by a range of business and trade groups, including the U.S. Chamber of Commerce and the National Federation of Independent Businesses.
About a week before the rule was scheduled to take effect last year on July 14, the Eighth Circuit Court of Appeals vacated it on procedural grounds, “not the merit of the rule,” Mon said. Among the issues was that the FTC did not perform a proper economic impact analysis, Mon said.
In November, two advocacy groups — the Consumer Federation of America and the American Economic Liberties Project — petitioned the FTC to renew the rulemaking process for the click-to-cancel rule.
“The American public continues to need robust protection against unfair and deceptive ‘subscription traps’ — the ubiquitous subscription practices that hook consumers into purchasing products or services with recurring charges and that are nearly impossible to cancel,” the petition says.
The FTC published the petition in the Federal Register on Dec. 3, with a public comment period lasting through Jan. 2.
At this point, it’s unclear whether the agency will restart the rulemaking process for its click-to-cancel rule.
FTC’s battle against cancellation practices continues
Either way, the FTC has continued to challenge subscription cancellation practices under a different authority, the Restore Online Shoppers’ Confidence Act.
In September, the FTC announced two settlements related to subscription cancellation practices. The agency reached a $2.5 billion settlement with Amazon over allegations that the company enrolled millions of consumers in Prime subscriptions without their consent and made it difficult for consumers to cancel.
Separately, the agency reached a $7.5 million settlement with education-tech provider Chegg over allegations that it was difficult for consumers to cancel recurring subscriptions and that it failed to honor consumers’ cancellation requests.
Because companies offering subscriptions are likely to do business across the country, they are dealing with a patchwork of state laws that are not exactly identical.
“To the extent that companies are operating nationwide … they’re figuring out what the most restrictive laws are and are tailoring their practices to those,” Mon said.
However, “the Unsubscribe Act would not preempt state laws, so companies would have to comply with both” federal and state laws, Mon said.
It’s uncertain whether the congressional proposals will gain traction or languish in committee.
