The numbers don’t look great. CNET says the average American dumps over $1,30 a year on subscriptions. Roughly $252 of that gets tossed out. Wasted. Unused. That figure actually went up from last year’s $1,08 spend and $204 waste. We are paying for things we don’t touch.
Canceling should be easy. It’s not. Some companies build walls just to keep you paying.
The federal path closed recently. In July, a court tossed out the FTC’s Click to Cancel rule. The regulation would have forced companies to make canceling as easy as signing up. Simple symmetry. Fair. But the court said the FTC skipped a mandatory economic analysis for rules costing over $1 million to implement.
So the rule died. But it’s not dead in the water.
“The FTC is working on a revised regulation to create uniform rules nationwide,” Brian Goodrich of Holland & Knight says. He’s seen the plans. The goal remains the same: clarity.
Washington is slow. Statehouses aren’t.
Look locally
If your credit card keeps getting dinged, check your state laws. Do this now. Log into your state legislature portal. Search for automatic renewal acts.
Several states already have teeth.
Some forbid automatic renewal without consent. Others demand upfront clarity: price, duration, and exactly how to quit. California requires you to actually say yes before renewing. Maryland passed HB0107 in June 2024—note the year correction, not 2026—mandating easy, cheap cancellation before renewal. Colorado’s 2025 SB25-144 insists on online cancellation buttons. Connecticut, Massachusetts, New York? They all have similar shields.
Goodrich notes that Colorado specifically demands a cancellation link on any retention offer. No hiding behind “contact support.”
The ghost of rules past
The federal government isn’t entirely hands-off, though. One law has lingered since 2010.
It’s the Restore Online Shoppers’ Confidence Act (ROSCA).
“ROSCA covers the negative option model,” Goodrich explains. That means the company treats your silence as a yes. Dangerous logic. While ROSCA is narrower than the dead Click to Cancel rule, it hits hard where it matters: internet transactions, free trials, recurring charges.
Here’s what it demands.
– Show the price, billing date, and cancellation policy before taking card details.
– Provide a clear way to confirm sign-up.
– Keep consumer data from third parties.
The killer clause? Section 5.
It bans deceptive acts. Goodrich says the FTC interprets this to mean canceling must be as easy as signing up. If you signed up online, you can quit online. Same click, same speed.
Violations bring penalties. The FTC has used ROSCA against Uber and Chegg. Section 6 lets state attorneys general enforce it, too.
We still don’t have perfect parity between signing up and quitting. The landscape is a patchwork of state laws and old federal acts. Is it enough? Maybe. Or maybe it’s just enough to make the fight exhausting.
