You don’t need to be a lawyer to run a compliant subscription. You need to know the handful of rules that shape the signup and the cancel button, and to have counsel check your version. This is an operator’s summary as of September 2026, not legal advice. The rules differ by state and change often.

Federal: the rule that didn’t happen, and the law that did

The Federal Trade Commission adopted its “click to cancel” rule on October 16, 2024, by a 3–2 vote. It would have required canceling to be as easy as signing up. On July 8, 2025, the US Court of Appeals for the Eighth Circuit vacated the whole rule, not on its content but on procedure: the FTC had skipped a required preliminary analysis of its economic impact. In February 2026 the FTC formally restored its older rule, and in March 2026 it asked for public comment on starting again. As of September 2026, no new rule has been proposed Published.

None of that made hard-to-cancel subscriptions legal. The Restore Online Shoppers’ Confidence Act, passed in 2010, still applies to anything sold online on a recurring basis. It requires three things Published:

1. Clear terms before billing informationThe seller must clearly and conspicuously disclose all material terms before collecting the customer’s billing details.
2. Express, informed consentThe seller must get the customer’s express informed consent before charging.
3. A simple way to stopThe seller must provide simple mechanisms for the customer to stop recurring charges.

The FTC and the Justice Department have kept enforcing it Published:

The states

• California amended its automatic renewal law in 2024; the changes apply to subscriptions entered into, amended or extended on or after July 1, 2025. Customers who signed up online must be able to cancel online, at will, without steps that obstruct or delay them. You may show a save offer online only if a “click to cancel” button, or words to that effect, is displayed continuously next to it. Price changes need notice 7 to 30 days ahead. Keep proof of each customer’s consent for at least three years, or one year after the subscription ends if that’s later Published. The law also requires an annual reminder. The text covers annual agreements and continuous service agreements, and the Attorney General’s summary reads more broadly still; confirm the current wording with counsel. The safe practice is a yearly reminder to every California subscriber.
• Minnesota, from January 2025 Reported: once a customer asks to cancel, you can’t present a save offer unless they first agree to hear one, and you may ask that only once per attempt. You may describe pausing or downgrading. Continuous subscriptions need a written notice at least once a year Published.
• New York amended its law in 2025, effective around November 2025 Reported. Canceling must be as easy as the way the customer agreed and available through the same medium. You may present a discount or retention offer, but not with unreasonable conditions. A price increase needs the customer’s consent, or a cancellation window of at least 14 days after the charge with a prorated refund Published.

Other states have their own versions. Build to the strictest one you sell into, which for most brands means California’s cancel button and Minnesota’s ask-first rule.

The card networks

Visa has required since April 2020 that merchants selling subscriptions with a free trial or introductory price get the cardholder’s express consent at signup, send a confirmation that includes a simple way to cancel, and send a reminder at least seven days before the trial or introductory price ends and the recurring charge begins Published. Mastercard introduced a similar rule for free trials of physical products in 2019 Reported. These rules bind you through your payment processor, whatever any state says.

Design the signup and the cancel path as if a regulator will screen-record them. One might.

The operator’s checklist

1. An unchecked choiceSubscribing is a separate, active choice: a toggle or button the customer selects, never a box that comes pre-checked.
2. Terms beside the buttonPrice per delivery, how often, what the price becomes after any introductory offer, and how to cancel, next to the subscribe button, before the card is entered.
3. A confirmation with the terms and a cancel linkSent straight after signup.
4. A reminder before the price changesAt least seven days before an introductory price ends, and before any price increase, within the notice window your strictest state requires.
5. Cancel online, where they signed upIn the customer account, found without searching, finished in a few taps.
6. Save offers that ask first and show the exitAsk once per attempt whether they’d like to hear options; show a clear cancel button beside any offer; if they decline, let them cancel.
7. A yearly reminderTo every subscriber: what they’re subscribed to, how often and how much they pay, and how to cancel.
8. RecordsKeep proof of consent (what the customer saw and chose, and when) for at least three years, or one year after the subscription ends if that’s later.

Do this

• Screen-record your own signup and cancellation on a phone. Send both recordings to counsel with the checklist above, and ask which states you sell into have rules beyond it.