After the Eighth Circuit vacated the amended Negative Option Rule on July 2, 2025, the FTC issued an Advance Notice of Proposed Rulemaking on March 11, 2026 seeking comment on reviving disclosure and easy-cancellation requirements for auto-renewals and subscriptions. Enforcement against negative-option sellers has continued in parallel at both the FTC and state AG level.
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FTC revives 'Click-to-Cancel' subscription rulemaking (March 2026)
Why this matters for founders
Subscription and SaaS founders should make canceling as easy as signing up and keep renewal disclosures clear now — a formal rule is being rebuilt and enforcement hasn't paused.
Source: U.S. Federal Trade Commission
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