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45 days.
That is how long you have, as of today, May 30, 2025, until the FTC's click-to-cancel rule reaches its extended compliance date of July 14. If you sell a telehealth membership that renews every month, this is the checklist week.
I am not an attorney, and this is educational content, not legal advice. What follows is a plain-English map of what the rule asks for, so you can walk into your attorney's office with the right questions instead of a blank page.
What does the click-to-cancel rule actually require?
Start from the source (I wrote the first version of this story in Click-to-Cancel Is Final). The FTC announced the final rule on October 16, 2024, describing it as requiring sellers to make it as easy for consumers to cancel their enrollment as it was to sign up.1 The agency said the rule applies to almost all negative option programs in any media.1 A negative option is any arrangement where silence or inaction is treated as consent to keep charging, which is exactly how an auto-renewing membership works.
The four pillars
According to the FTC and the Federal Register notice, the rule centers on four things:12
- No misrepresentations. Sellers may not misstate material facts when marketing a negative option feature.
- Clear disclosure of material terms. Before you obtain the consumer's billing information, you must clearly and conspicuously disclose the material terms of the negative option feature.
- Express informed consent. You must get the consumer's express informed consent to the negative option feature before charging them.
- Simple cancellation. You must offer a simple mechanism to cancel that immediately halts charges.
What the final rule dropped
The final rule does not include the proposed annual reminder requirement. It also dropped a prohibition on mentioning plan modifications or reasons to stay when a consumer is trying to cancel without first asking whether they want to hear them.1 That does not make aggressive save tactics a good idea. It means the rule's text is narrower than the proposal.
What is the compliance timeline?
Dates matter here, and they have moved.
The sequence
- Oct 16, 2024FTC announces the final rule
- Nov 15, 2024Published in the Federal Register
- Jan 14, 2025Rule becomes effective
- May 9, 2025FTC votes to extend the deadline 60 days
- Jul 14, 2025Extended compliance date
The rule was published in the Federal Register on November 15, 2024 and became effective January 14, 2025. The Federal Register notice set May 14, 2025 as the compliance date for the disclosure, consent and cancellation provisions.2 On May 9, 2025, the FTC voted to extend that deadline by 60 days, to July 14, 2025.3
Why you should still verify
Rules like this can be challenged, revised and delayed. Confirm the current status with your attorney before you rely on any date in this article, including this one.
Does it apply to telehealth?
The FTC's language is broad: almost all negative option programs, in any media.1 The Federal Register notice also notes that the Commission declined to exclude business-to-business transactions.2 A cash-pay telehealth membership that bills monthly and renews until canceled looks like a standard negative option program.
Whether any specific feature of your program is treated differently is a question for counsel. What I can say is that "we are healthcare" is not a reason to skip the checklist.
The compliance checklist
Work through this in order. Each item is a question to ask, not a legal conclusion.
1. Disclosure
- Are the price, billing frequency, renewal terms and cancellation method stated clearly and prominently before the patient enters card details?
- Is the first charge, any trial period and the date billing begins explained in plain words, not buried in a link?
- Do your ads, landing pages and checkout say the same thing? A mismatch is a misrepresentation waiting to happen.
2. Consent
- Does the patient take a clear, separate action that says they agree to recurring billing, such as an unchecked box with plain wording next to the pay button?
- Is that consent recorded with a timestamp and what they saw?
- Is the renewal consent separate from the general terms of service, and does your intake form capture it at the right step?
3. Cancellation
- Is cancelling about as easy as signing up was, without a phone call during business hours as the only option?
- Does cancellation immediately stop future charges?
- Is the path to cancel visible in the account, not hidden behind a support ticket?
- Do you tell the patient what cancellation means for their care, in a neutral, factual way?
4. State overlay
California's AB 2863, signed September 24, 2024, takes effect July 1, 2025. Among other things it requires express affirmative consent to automatic renewal terms, effectively separate from consent to the service terms, and says consumers must be able to cancel as easily as they signed up.4 Other states have automatic renewal laws as well. Ask your attorney which states you serve and which rules apply to each.
What evidence should you keep?
If a patient or a regulator ever asks what happened, your records are your defense. Keep:
- Screenshots of every step of the enrollment flow, dated, saved when the flow changes.
- A log of consent: timestamp, plan, price and the exact consent text shown.
- The cancellation path and every cancellation request, with the time it was received and the time charges stopped.
- Copies of ads and landing pages for each version you have run.
Ads belong in the checklist
Ads are where promises start. If an ad says "cancel anytime" and the flow says "call us," you have created the mismatch yourself. Review your creative against your billing terms the same day you review your checkout.
If it is easy to enter and hard to leave, the problem is not retention. It is the funnel.
What should you do this week?
Walk your own flow as a patient. Write down every gap. Hand the list to your attorney. Fix the cancel path first, because that is where most of the risk sits. Then update the evidence file. For the retention side of the same problem, read GLP-1 Patient Retention.
If you would like help auditing the ad-to-checkout path for your telehealth brand, that is part of my work, which you can read about on my telehealth page.
Educational content about business operations, not legal advice. Consult a qualified attorney about your specific program.
Keep building.Ekai
Questions people ask
What is the FTC click-to-cancel rule?
It is the FTC's amended Negative Option Rule, announced October 16, 2024. It prohibits misrepresentations, requires clear disclosure of material terms before billing information is taken, requires express informed consent and requires a simple way to cancel that immediately halts charges.
When do the click-to-cancel requirements apply?
The rule was effective January 14, 2025. The FTC voted on May 9, 2025 to extend the compliance deadline by 60 days, to July 14, 2025. Confirm the current status with your attorney before relying on any date.
Does the rule apply to telehealth memberships?
The FTC says the rule applies to almost all negative option programs in any media. A recurring telehealth membership that renews automatically fits that description, but a qualified attorney should confirm how it applies to your specific program.
What state laws also matter?
California's AB 2863 amended its automatic renewal law with requirements including express affirmative consent and an easy cancellation process, effective July 1, 2025. Other states have their own rules.
Sources
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