FTC click-to-cancel rule vacated (2025)
The FTC finalized a national click-to-cancel rule in October 2024. Business groups including the U.S. Chamber of Commerce and the National Federation of Independent Businesses sued, and the Eighth Circuit vacated the rule on procedural grounds in July 2025 before it took effect.
The national rule never went into force, leaving enforcement to individual states.
With the federal path blocked, states and cities began filling the gap on their own.
NYC's municipal rule is the direct response to the federal vacuum, making it a test case for whether local enforcement can substitute for a national standard.
