Click-to-Cancel Died in Court. How to Cancel Anyway in 2026

Marisol joined a gym in Queens in March 2024 at $39.99 a month. She signed up at the front desk in about four minutes. When she tried to cancel a subscription she'd stopped using, the gym told her she had to come in person during manager hours or mail a certified letter. (Marisol is a hypothetical, but if you've ever tried to quit a gym, you've met her gym.)

For a few months in 2025, it looked like a federal rule was about to end that kind of runaround for everyone. Then a court threw it out. The good news is that a surprising amount of protection survived, and as of October 1, 2026, people in New York City picked up a new set of rights with real fines behind them. If you've got a subscription you can't seem to escape, you have more power than the cancellation page wants you to think.

What happened to the federal click-to-cancel rule

The Federal Trade Commission finalized its "click-to-cancel" rule on October 16, 2024. The idea was simple: canceling should be as easy as signing up. If you joined online in two clicks, you should be able to leave online in about two clicks. The FTC said at the time that it was getting nearly 70 complaints a day about subscription and auto-renewal practices in 2024, up from 42 a day in 2021.

The rule never got going. On July 8, 2025, the U.S. Court of Appeals for the Eighth Circuit vacated it in full. The judges didn't rule that making cancellation easy was a bad idea. They ruled that the FTC skipped a required step, a preliminary regulatory analysis that the law demands for rules with an economic impact over $100 million a year.

So the FTC is starting over. In March 2026 it published an advance notice of proposed rulemaking, the very first stage of writing a new rule. According to a May 2026 analysis by the law firm Jones Day, comments closed April 13, 2026, and roughly 100 were filed. A proposed rule, another comment period and a final rule all still have to happen. I wouldn't count on a new federal rule before 2027, and even then it could be challenged again.

The federal law that still applies

Most "click-to-cancel is dead" headlines skip the next part. A federal statute called the Restore Online Shoppers' Confidence Act, or ROSCA, has been on the books since 2010, and the court ruling didn't touch it.

ROSCA covers subscriptions you sign up for online. It requires the seller to clearly disclose the terms before taking your billing information, get your express consent before charging you, and give you a "simple mechanism" to stop recurring charges. Its weakness is that it never defines "simple," and it only applies to online transactions. A gym membership you signed at a front desk falls outside it.

The FTC has kept using ROSCA, along with its general power to police deceptive practices, and the penalties have been big. In September 2025, Amazon agreed to pay $2.5 billion to settle FTC claims that it enrolled people in Prime without their consent and made canceling deliberately hard. That broke down into a $1 billion civil penalty and $1.5 billion in customer refunds, capped at $51 per person, which went out between November 12 and December 24, 2025. Before that, Care.com paid $8.5 million in 2024 over similar allegations.

You can't sue under ROSCA on your own, but you can file a complaint at ReportFraud.ftc.gov. Complaint data is one of the ways the agency spots patterns worth investigating. The Amazon lawsuit itself was filed in 2023 and took two years to settle.

Your state probably has its own rules

According to the same Jones Day analysis, roughly 30 states have their own automatic-renewal laws, and some of them go further than the federal rule ever did. The details vary a lot, so look up your own state's version. Three are worth knowing because they set the pace.

California

California's updated Automatic Renewal Law took effect July 1, 2025, for contracts signed or renewed after that date. If you signed up online, the business has to let you cancel online. It also has to send an annual reminder before your plan renews, telling you the price and how to cancel, and it has to notify you clearly of material price or service changes.

The rule I like best covers retention offers. A California business can still pitch you a discount when you try to leave, but only if a prominent "click to cancel" button sits on the same screen the whole time. On the phone, they have to tell you that you can cancel any time by saying "cancel."

New York State

New York's auto-renewal statute, General Business Law § 527-a, requires businesses to offer a way to cancel. If you signed up in person, the business must give you an online option or a phone number. Penalties are modest, though. The state caps them at $100 for a single violation, and even knowing, repeated violations top out at $1,000.

New York City, as of October 1, 2026

New York City's new rule, announced July 10, 2026 by Mayor Zohran Mamdani and Department of Consumer and Worker Protection Commissioner Samuel Levine, took effect October 1. It covers streaming services, gym memberships, subscription boxes and free trials that roll into paid plans.

It mostly mirrors state law, with a few sharper edges. Businesses have to let you cancel the same way you signed up. If you joined in person, they must offer an online way to cancel, "such as a website or email," and a phone line alone doesn't satisfy the rule anymore. They also can't make you pay to ship back something they gave you for free.

The money part is what gives it teeth. A violation costs the business $525 the first time, $1,050 the second time and $3,500 for each one after that. And if a company keeps billing you after you try to cancel, it owes you back everything it charged from your first cancellation attempt onward.

Go back to Marisol. Say she emails the gym on October 2, 2026 asking to cancel, and the gym ignores her and bills her $39.99 on October 15 and again on November 15. Under the city rule, the gym owes her $79.98, and she can report it to the city's consumer protection department (call 311 or file online at nyc.gov). Under the old status quo, she'd have been mailing a certified letter and hoping.

How to cancel a stubborn subscription, step by step

Laws help most when you've created a paper trail that shows you tried. This is the sequence I'd follow.

Start by finding out how you signed up and where you're being billed. App subscriptions often bill through Apple or Google rather than the company itself, and you cancel those in your phone's subscription settings. If the charge comes from the company directly, look for the cancel option in account settings first. Search "[company name] cancel" if you can't find it, since many companies bury the link several menus deep.

Whatever channel you use, document it. Take a screenshot of the cancellation confirmation, save the email, or write down the date, time and rep's name if you called. If a chat agent keeps steering you toward a discount, type "I want to cancel" plainly and screenshot the conversation. In California and New York City, that first documented attempt is what starts the clock on what you're owed.

If the business won't let you cancel, put it in writing. Send an email to customer support saying you're canceling as of today's date and you don't authorize further charges. Name your state's auto-renewal law if you know it. Most companies fold at this point, because a written refusal on their end creates exactly the evidence a regulator wants.

Then watch your next statement. If you get charged anyway, you have two separate tools.

When they bill you anyway: your card is your backup

The first tool is a credit card dispute. Under the Fair Credit Billing Act, a charge for something you canceled or didn't agree to can be disputed as a billing error. You have 60 days from the date the statement with the charge was sent to dispute it in writing, and the issuer has to investigate. Send your screenshots and your cancellation email along with it. Debit cards are weaker here because they fall under a different law, which is one more reason to put subscriptions on a credit card.

The second tool is cutting off the payment method. You can ask your issuer to block future charges from that merchant, though not every bank will. Getting a new card number doesn't always work either, because Visa and Mastercard run updater services that can pass your new number to merchants you already pay. A virtual card number, set up with a spending limit or locked to one merchant, is more reliable: when you want out, you close that number and the merchant has nothing to charge.

Blocking the card doesn't cancel the contract, so a business can still send you to collections for "unpaid" fees on a membership you never formally canceled. Do the written cancellation first, then block the card, so you have proof you ended the contract before the payments stopped.

Where to complain so it counts

If a company drags its feet, the complaint routes depend on where you live. File with the FTC at ReportFraud.ftc.gov for any online subscription. File with your state attorney general, since state AGs enforce the auto-renewal laws. In New York City, file with the Department of Consumer and Worker Protection. And if the problem involves your bank or card issuer refusing a valid dispute, the Consumer Financial Protection Bureau still takes complaints at consumerfinance.gov.

It feels like shouting into the void, and sometimes it is. I'd still file. Regulators can't act on a pattern nobody reports, and the FTC's own tally of nearly 70 subscription complaints a day is part of why this issue keeps coming back.

Bottom Line

The federal click-to-cancel rule is gone for now, but ROSCA, roughly 30 state laws and your credit card's dispute rights are still in force. New York City's rule, live since October 1, 2026, is the strongest yet, with refunds owed from your first cancellation attempt. Pick one subscription that's been hard to quit and do this:

1. Find out how you signed up and where you're billed (App Store, Google Play or the company directly), then try to cancel through that same channel today.
2. Screenshot or save every cancellation attempt with the date, and send a short written cancellation email if the button doesn't work.
3. Check your next statement. If the charge shows up, dispute it in writing with your card issuer within 60 days and attach your proof.
4. Move your remaining subscriptions to a credit card or a merchant-locked virtual card number so the next breakup is easier.