Why ‘Click-to-Cancel’ Still Matters – and Why the FTC Should Try Again

For years, consumers have signed up for subscriptions—sometimes intentionally, sometimes not—only to later discover that getting out is far harder than getting in. From hidden autorenewals to labyrinthine cancellation processes, deceptive subscription practices continue to cost consumers time, money and trust.

That’s why TINA.org filed a comment today supporting the Consumer Federation of America (CFA) and the American Economic Liberties Project’s (AELP) petition urging the FTC to renew its “click-to-cancel” rulemaking.

This isn’t new ground for us. TINA.org has long sounded the alarm on subscription ruses, published a multitude of ad alerts, and filed several complaints with regulators on this topic—leading to six regulatory enforcement actions cumulatively resulting in more than $6 million in civil penalties and consumer redress. We have also submitted detailed comments during the FTC’s prior rulemaking and filed an amicus curiae brief in the Eighth Circuit supporting the FTC’s authority to protect consumers in this space.

Ultimately, the Eighth Circuit Court of Appeals determined that the FTC had failed to satisfy mandatory procedural requirements under the FTC Act before finalizing the Click-to-Cancel Rule. Crucially, the court did not weigh in on the merits of the rule itself. Which raises an obvious question: Why not try again?

The Problem Hasn’t Gone Away

The FTC’s Negative Option Rule was originally designed for a very different marketplace—one of mail-order clubs and paper forms, not one-click enrollments and app-based subscriptions. Today’s digital environment allows companies to enroll consumers with minimal friction while burying cancellation methods behind multiple screens or confusing prompts that subtly steer people away from opting out.

As we’ve documented before, these practices aren’t just annoying—they’re harmful. And they’re mounting. Consumers routinely report being charged for services they didn’t knowingly agree to, or being unable to cancel without hours of effort or extra sums of money. The result is a system where businesses profit from inertia and confusion rather than genuine consumer choice.

A Recent Example: Homeaglow

In September, TINA.org filed a complaint against Homeaglow, an online home-cleaning platform used by nearly 100,000 U.S. households across the country, after identifying a number of deceptive marketing practices—including a highly misleading autorenewal program.

Homeaglow falsely advertises $19 house cleanings to draw consumers in, then pushes them through a rushed sign-up process that obscures material terms. Many consumers unknowingly enroll in expensive monthly autorenewal subscriptions, and those who attempt to cancel within the first six months face cancellation fees that can run into the hundreds of dollars.

By the time we filed our complaint, nearly 3,000 consumers had lodged complaints with the FTC. State regulators, TINA.org and third-party review sites have all received similar reports. (The Better Business Bureau alone has received 2,600+ consumer complaints.) A clear Click-to-Cancel rule would make it far easier for the FTC to address this kind of widespread harm.

The Current Tools Are Not Enough

To its credit, the FTC has brought numerous enforcement actions targeting deceptive subscription practices. But its currently available tools are not enough, as evidenced by the staggering number of consumers who consistently report falling victim to these traps. In fact, the FTC reports receiving thousands of complaints regarding negative option and recurring subscription practices each year—dozens every day.

In addition, enforcement is inherently reactive and it happens after consumers are harmed and often years after problematic practices become widespread. Clear, enforceable rules matter because they set expectations upfront—for both businesses and consumers. The FTC’s proposed Click-to-Cancel Rule was a meaningful attempt to do just that: It required, among other things, cancellation mechanisms that are at least as easy to use as the methods consumers use to sign up.

Industry opposition and subsequent legal challenges stalled that effort. But the underlying consumer harm didn’t disappear.

Why Renewed Rulemaking Is Necessary

CFA and AELP’s petition makes a straightforward case: The FTC should renew its Click-to-Cancel rulemaking. TINA.org agrees.

Without explicit requirements, companies can continue to defend burdensome cancellation processes as technically compliant—even when they clearly undermine consumer understanding and choice. A renewed rulemaking would give the FTC the opportunity to clarify standards, close loopholes, and adapt the rule to the realities of modern digital commerce.

Importantly, this isn’t about punishing legitimate subscription businesses. It’s about ensuring that consent is real, cancellations are meaningful, and competition happens on fair terms—not through trickery or design manipulation.

Stay tuned for updates.