Thought Leadership
Subscriptions After “Click-to-Cancel” Was Vacated: Still Do It.
Yes, the US Eighth Circuit vacated the FTC’s Negative Option Rule on July 8, 2025. But friction-filled cancellation still draws lawsuits under existing laws (like ROSCA) and state UDAP statutes. Many brands are implementing simple, same-channel cancellation - and keeping notifications and renewal receipts simple - because it’s defensible and better for long-term LTV.
Pair that with the FTC’s junk-fee rule, which targets deceptive or hidden charges. Support teams should align billing scripts, proactive credits, and fee disclosures to reduce regulatory and chargeback risk.
What to operationalize:
Single-step cancel (or as few steps as possible) with confirmation receipts.
Renewal reminders that are plain language, with dates and amounts.
Save offers that are compliant (no dark patterns, clear terms), routed to agents for complex cases.
Audit trails: timestamps for request/confirmation, retention of the last 6–12 months.
Get a concrete, prioritized plan - Request a Regulatory Readiness Assessment.
Talk with Sirius Support about scaling customer service without adding fixed overhead.
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