Congress locks in FTC's 'click to cancel' rule, blocking future rollback.
S. 2254 — Click to Cancel Consumer Protection Act of 2025 · Filed by Ruben Gallego (D-AZ) · 2 cosponsors · Introduced Jul 10, 2025 · Referred to committee
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What it does
This bill converts the FTC's existing negative option rule (the 'click to cancel' rule) from an administrative regulation into federal law. The rule requires companies offering subscription or auto-renewal services to make cancellation as easy as the original sign-up, and to obtain clear affirmative consent before charging customers. By codifying it, Congress locks the rule into statute, making it harder for future administrations to weaken or repeal it without new legislation.
Why we flagged it
The bill's sole function is to elevate an existing FTC consumer-protection rule from regulation to statute, preventing administrative repeal. It is a straightforward legislative lock-in of a pro-consumer rule.
What the text implies
- Codification removes the FTC's ability to modify or repeal the rule through notice-and-comment rulemaking; any future change requires new legislation, raising the political bar for deregulation.
- The rule applies to all negative-option offerings (subscriptions, auto-renewals, free trials with auto-charge) across all industries and platforms, creating uniform national standards that may preempt state laws.
- Companies currently compliant with the FTC rule face no immediate operational change, but those relying on friction or dark patterns to retain subscribers will face enforcement risk if they deviate.
Section numbers refer to the bill text the analysis read — linked under Primary records below.
Who it affects
Ordinary consumers gain statutory protection against predatory auto-renewal practices (hidden charges, difficult cancellation). Codification locks in the rule, preventing future regulatory rollback. The primary cost is to subscription businesses that rely on consumer inertia or friction to retain customers, not to citizens.
Named in the bill
Federal Trade Commission (FTC), 16 CFR Part 425, subscription services industry, e-commerce platforms, streaming services, membership-based retailers
Where it stands
2 cosponsors: 2 Democrats.
- Jul 10, 2025 — Introduced · Congress.gov: “Introduced in Senate”
- Jul 10, 2025 — Referred to Senate Committee on Commerce, Science, and Transportation · Congress.gov: “Read twice and referred to the Committee on Commerce, Science, and Transportation”
Dates and quoted wording are Congress.gov's action record; the timeline shows status changes, not every procedural step.
Money around this bill
1 lobbying clients named this bill on 2 disclosure filings across 2 quarters, Dec 2025 to Jun 2026. Those filings disclosed $2,810,000 in lobbying spend. A filing names 36 bills on average, so that figure is what each filing reported, not a share belonging to this bill.
More lobbying clients named this bill than 0% of bills with at least one filing.
Ruben Gallego, the sponsor, reported $477,461 in PAC receipts in the 2026 cycle.
- Entertainment Software Association — $2,810,000 on 2 filings
Lobbying Disclosure Act filings through Jul 20, 2026. A filing shows who paid to lobby on a bill it names, not what changed.
How this was measured
Analysis — Quorum's AI read the bill text published by Congress.gov (276 characters) on Jul 2, 2026. Section numbers in the findings refer to that text, linked below; transparency and hidden-provision scores are compared against the median of 16,222 analysed bills.
Status and sponsors — Congress.gov's bill record — actions, committee referrals and cosponsors — loaded nightly. The timeline shows status changes, not every procedural action.
Money — Senate Lobbying Disclosure Act filings whose specific-issue field names this bill for quarters ending Dec 2025 to Jun 2026. A filing's amount is reported whole beside the median number of bills a filing names; it is never divided across them. PAC receipts are FEC-reported contributions to the sponsor's candidate committee in the 2026 cycle.
As of — lobbying records through Jul 20, 2026 · page rendered 2026-10-20.
“Congress locks in FTC's 'click to cancel' rule, blocking future rollback.” QuorumCivic. https://share.quorumcivic.app/bill/119/s2254 Report an error
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