Observed Signal · Dec 11, 2025 · Policy Update · Source: State of Streaming · Impact: 4/5 · Sentiment: Neutral
Advocates Petition FTC to Reinstate Click-to-Cancel Rule
Two consumer advocacy organizations—the Consumer Federation of America and the American Economic Liberties Project—have petitioned the U.S. Federal Trade Commission to restart rulemaking on a “click-to-cancel” requirement that would require subscription cancellations to be as easy as signups. The rule had been finalized by the FTC in 2024 but was struck down by a federal appeals court on procedural grounds, with the court finding the agency lacked a proper economic analysis. The original legal challenge was led by business and advertising groups including the Chamber of Commerce and the Interactive Advertising Bureau. The petition seeks renewed rulemaking; the FTC has opened a public comment period (through January 2) on the filing. The agency continues to rely on other authorities such as ROSCA to pursue deceptive subscription practices.
A major U.S. regulator (FTC) is being petitioned to re-open rulemaking on subscription cancellation practices; a revived rule would affect subscription billing UX, compliance costs, enforcement risk, and could set precedent across digital subscription and app-store ecosystems.
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Key Takeaways & Evidence Grounding
- The Consumer Federation of America and the American Economic Liberties Project filed a petition asking the FTC to revive the "click-to-cancel" rule.
- An FTC "click-to-cancel" rule finalized in 2024 was struck down by a federal appeals court due to a procedural flaw related to economic analysis.
- The original legal challenge to the rule was brought by a coalition that included the Chamber of Commerce and the Interactive Advertising Bureau.
- FTC Chair Andrew Ferguson was a dissenting vote on the original 2024 regulation.
- The FTC opened a public comment period on the new petition, which is open through January 2.
Connected Companies & Entities
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Related Market Signals & Shifts
Recent verified developments and strategic activity across this market segment.
NYC Adopts Click-to-Cancel Rule for Subscriptions
New York City will require businesses that offer automatic renewals or continuous subscriptions to provide a cancellation method as easy as the method used to enroll, effective October 1, 2026. Finalized by the city’s Department of Consumer and Worker Protection and championed by Mayor Zohran Kwame Mamdani’s administration, the rule covers cable, streaming, gyms and other recurring services. Enforcement includes civil penalties starting at $525 per violation and restitution for consumers. The city estimates annual consumer savings between $21.5 million and $162.5 million. Industry groups have warned of legal challenges and operational burdens for smaller providers, while advocates call the measure a major consumer-protection advance.
Bad UX Is Often a Business Decision
This analysis argues that many harmful user experiences — especially subscription cancellation flows — are deliberate business decisions rather than accidental design failures. The author describes how product teams optimise for acquisition and retention metrics, creating one‑way funnels that make it easy to join but deliberately hard to leave. The piece cites Amazon’s internally named “Iliad Flow” Prime cancellation maze and screenshots submitted in FTC litigation as an example, and summarises regulatory findings showing widespread dark patterns across subscription products. It lists enforcement outcomes and fines (Amazon, Epic Games, Google/YouTube, HelloFresh) and explains the U.S. FTC’s Click‑to‑Cancel rule effort (later vacated on procedural grounds). The author recommends reframing dark patterns as business risk, brand trust erosion and legal liability to make them visible in product reviews and governance.
US suspends Microsoft, Adobe from green card labor program
The Trump administration has suspended Microsoft, Adobe, and six other major tech firms—Capgemini, Cognizant, HCL, Infosys, Tata, and Wipro—from the U.S. Permanent Labor Certification program, which facilitates green cards for skilled foreign workers. Secretary of Labor Keith Sonderling cited active federal investigations and alleged fraud, noting that no new or pending applications from these companies will be accepted. Vice President JD Vance accused Microsoft of replacing laid-off workers with H-1B visa holders. Microsoft defended its practices, stating that most U.S. employees are American and that 80% of its H-1B petitions were for existing employees. The announcement was made during a White House summit on H-1B fraud, and the administration also plans to investigate nine universities, including Harvard, Yale, and Stanford, over student visa program abuse.
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