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.