Click-to-cancel in October 2026: what's law, what isn't, and Amazon's Prime refunds
The FTC's 2024 click-to-cancel rule is gone and its replacement is only at the question stage. But federal law, state rules and the Amazon Prime settlement still help. Here's where things stand.
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What's happened
Amazon has been sending a new round of automatic refunds since October 1, 2026, under its September 2025 settlement with the FTC over Prime sign-ups and cancellations. A revised court order, announced by the FTC on September 17, 2026, raised the maximum payment per person from $51 to $200 and added millions of customers.
The settlement totaled $2.5 billion: a $1 billion civil penalty and up to $1.5 billion in refunds. Amazon had paid more than $845 million by September 2026.
Meanwhile, the FTC's 2024 "click-to-cancel" rule, which would have required cancellation to be as easy as sign-up across most subscriptions, isn't law. A federal appeals court, the Eighth Circuit, threw it out in July 2025 on procedural grounds, and the FTC formally revised its rule in February 2026 to match. On March 11, 2026, the FTC asked for public comment on whether to write a new rule, with comments closing on April 13. When we checked on October 26, the FTC hadn't proposed new rule text.
Who's affected
Anyone paying for streaming, apps, software, gyms, meal kits or memberships that renew automatically. You still have real protections.
- Federal law (ROSCA). The Restore Online Shoppers' Confidence Act of 2010 says online sellers using automatic renewals must clearly disclose all material terms before taking your billing details, get your express informed consent before charging, and provide simple ways to stop recurring charges. It's what the FTC used against Amazon.
- California. Since July 1, 2025, businesses must get express consent, let you cancel online if you signed up online, and not obstruct or delay cancellation. They must send an annual reminder and give 7 to 30 days' notice of a price increase.
- New York. Cancellation must be as easy as sign-up and in the same medium. Before charging a higher price, a business needs your consent or must let you cancel within at least 14 days with a pro rata refund.
- Massachusetts. Since September 2, 2025, a subscription started on a website must be cancelable on that site, and charges must stop immediately.
Many other states have their own automatic renewal laws.
Amazon Prime refunds: a worked example
This is an illustration of how the settlement works, not a real case.
You may qualify if you're a US Prime customer who signed up through one of the challenged sign-up flows, or tried and failed to cancel online, between June 23, 2019 and June 23, 2025, and used no more than 20 Prime benefits in any 12-month period.
Say Lee got $51 earlier this year. If total accepted payments don't reach the required level by February 2027, Lee gets another $149, for $200 in all, in a final round starting by April 2027. A customer who used 15 benefits wasn't eligible before, but now gets an automatic payment. Payments come by PayPal, Venmo or check, and expire 60 days after they're issued.
What to do now
- Watch for your Amazon payment and accept it within 60 days. No claim form is needed.
- List your subscriptions from your card and bank statements, and cancel what you don't use.
- Cancel the way you signed up. If a site makes it hard, keep screenshots and note the time.
- Dispute charges after you've canceled. On a credit card, a charge for a service you canceled may count as a billing error. Your written notice must reach the issuer within 60 days of the statement.
- Complain to the FTC at ReportFraud.ftc.gov and your state attorney general if you can't cancel.
FAQs
Can a company make me listen to a retention offer?
California and New York allow save offers as long as they don't obstruct your cancellation. You can say no and cancel.
Will the click-to-cancel rule come back?
Possibly, but not soon. The FTC is at the earliest stage of rulemaking. It would need to propose a rule and take comments before anything final.
Where can I check my Amazon refund?
The settlement administrator is at SubscriptionMembershipSettlement.com or 1-888-999-8094.
Ways to save
Signing up for a VPN for holiday travel? Check the renewal price and date before you pay, and see current codes for Surfshark and FastestVPN.
Sources: FTC: additional payments from the Amazon Prime settlement, FTC: Amazon refunds, FTC: Negative Option Rule, FTC: advance notice of proposed rulemaking, March 2026, Federal Register: negative option ANPRM, 15 U.S.C. 8403 (ROSCA), California Attorney General: automatic renewal law alert, New York General Business Law section 527-a, Massachusetts: 940 CMR 38.00
More on your rights when you shop
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- Gift cards: the 5-year expiry rule, fee limits, and how to dodge draining scams
- Holiday buy gone wrong? How a credit card dispute can get your money back
- Holiday order late? The FTC rule that says when stores must ship or refund you
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