FTC Click-to-Cancel Compliance Checklist
Audit your SaaS cancellation flow against the FTC's 2024 Negative Option Rule. Actionable checklist with statutory citations and practical guidance.
Audit Compliance Score
0% (0 of 5 requirements satisfied)
Equal Ease of Cancellation
FTC 16 C.F.R. § 425.4 (vacated July 2025; best practice)Cancelling online must require no more steps than signing up. If users signed up on web, they must be able to cancel on web.
No Mandatory Phone Calls or Chats
FTC 16 C.F.R. § 425.4(b) (vacated July 2025; best practice)You cannot force a customer who signed up via web/app to call a support line or talk to an agent to complete cancellation.
Explicit Consent Prior to Billing
FTC 16 C.F.R. § 425.3 (vacated July 2025; best practice)Obtain unambiguous affirmative consent specifically to the recurring auto-renewal terms before processing payment.
Clear, Unambiguous Pre-Purchase Disclosure
FTC 16 C.F.R. § 425.2 (vacated July 2025; best practice)Disclose that billing continues until cancelled, the exact recurring amount, frequency, and deadline to cancel.
Immediate Written Confirmation
FTC 16 C.F.R. § 425.5 (vacated July 2025; best practice)Send an immediate confirmation email with timestamp and cancellation reference upon successful cancellation.
About this checklist
In 2024 the Federal Trade Commission adopted amendments to its Negative Option Rule, widely called the 'click-to-cancel' rule. It required businesses to make cancelling a subscription as easy as signing up, to get clear consent before charging, and to stop forcing customers to call or jump through hoops to leave. On July 8, 2025, the U.S. Court of Appeals for the Eighth Circuit vacated those amendments on procedural grounds, so the rule is not in force as of November 2026, and the FTC has started the rulemaking process again. The principles still matter: the FTC continues to bring cases under existing law against hard-to-cancel subscriptions, and several states, including California, have their own automatic-renewal laws. Use this checklist to check your signup and cancellation flows against those principles. It is general information, not legal advice.
How It Works
- 1Review the principles from the vacated 2024 FTC amendments (16 C.F.R. § 425), which still reflect regulator expectations.
- 2Check off each compliance item your cancellation flow currently satisfies.
- 3Identify operational gaps, such as missing confirmation emails or excessive survey friction.
- 4Consult the provided legal guidance notes to bring your product into full compliance.
Worked Practical Example
A SaaS requires users to email support or initiate a chat to cancel an online subscription.
Calculation / Steps
Conflicts with the vacated 16 C.F.R. § 425.4(b) principle (no forced human interaction when signup was online self-serve).
Expected Result
High legal risk; must implement self-serve in-app cancellation to satisfy federal regulations.
Frequently Asked Questions
Is the FTC click-to-cancel rule in effect?+
No. The 2024 amendments were vacated by the Eighth Circuit on July 8, 2025, and the FTC has restarted rulemaking. Existing federal consumer-protection law and state automatic-renewal laws, such as California's, still apply, so easy cancellation remains the safe default.
Can I make customers call to cancel an online subscription?+
It's a bad idea. The vacated federal rule would have banned it, California's law requires online cancellation for customers who signed up online, and regulators treat forced calls as a classic hard-to-cancel tactic. Offer an online cancel option in the same place people signed up.
How does BoolBul maintain FTC compliance?+
BoolBul ensures the 'Cancel Subscription' link is always visible on every modal screen, fails open within 1.5 seconds, and never traps the user in endless loops.
Automate retention on your cancel button
BoolBul keeps a one-click cancel link on every screen of the flow and blocks shaming button labels, so self-service cancellation stays easy.
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