Cancellation Flows - Options and Regulatory Considerations
Recharge is committed to empowering merchants with tools that support compliance, no matter where you operate. Recharge understands regulations evolve, and has built the platform with flexibility in mind to adapt to your unique business and legal requirements.
FTC Click-to-Cancel Regulatory Update (July 2025)
On July 8, 2025, a federal appeals court struck down the FTC’s Click-to-Cancel rule, which had been scheduled to take effect on July 14, 2025. The court found that the FTC failed to complete a required economic impact analysis, and as a result, the rule is no longer enforceable at the federal level.
Although the FTC’s nationwide rule is paused, state-level requirements remain in place—notably in California, New York, and other states—with their own laws requiring clear and easy online cancellation options. The FTC may also revisit this rule or pursue similar standards through future enforcement actions.
Key takeaway
There is no federal mandate requiring a standardized online cancellation mechanism at this time. However, state-level mandates remain enforceable (e.g., California’s ARL and New York’s GBL § 527).
What the Regulatory Update means for Recharge merchants
While the federal rule is no longer moving forward for now, Recharge continues to empower merchants to comply with state laws and stay ahead of evolving obligations with flexible, scalable cancellation tooling that supports both compliance and business control:
- Customizable configuration of cancellation flows and strategies
- Optional surveys to retain customers and gather actionable insights
- Direct-to-cancel links for high-transparency navigability
While Recharge's tools are designed to support your efforts, it’s important to note that each merchant is responsible for ensuring their use of Recharge complies with applicable laws. Recharge can’t offer legal advice, but Recharge is here to help you understand what’s possible within our platform.
If you have questions about setup or configuration, reach out anytime—Recharge is here to support you.
