Is It Hard to Cancel a Pet Tech Subscription?
Quick answer: The federal FTC 'Click-to-Cancel' rule — which would have required cancellation to be at least as easy as signing up — was vacated by a federal court of appeals in 2025 over a rulemaking procedure violation, and it is not currently federal law. The FTC relaunched a rulemaking process (an Advance Notice of Proposed Rulemaking) in March 2026 to try to revive it, but that's still in progress, not finalized. In the meantime, the FTC can still act against clearly deceptive or unfair cancellation practices under its general Section 5 authority, and roughly 30 US states have their own automatic-renewal laws, some stricter than the vacated federal rule — so real protection currently depends more on your specific state than on a single national standard.
Subscription cancellation friction is a real, actively regulated area — but the specific federal rule that would have made this simple isn’t currently in effect, and it’s worth knowing exactly where things actually stand.
The federal rule was vacated, not just delayed
The FTC finalized its “Click-to-Cancel” rule in 2024, which would have required that canceling a subscription be at least as easy as signing up for one — if you could sign up online in two clicks, the rule required cancellation to take a comparable number of steps, closing off the common pattern of an easy online sign-up paired with a cancellation process that requires a phone call, a retention pitch, or a mail-in form. In 2025, a federal court of appeals vacated the rule entirely, finding the FTC had violated required rulemaking procedure under the Administrative Procedure Act during the process that produced it. This means the rule is not currently binding federal law — a meaningfully different situation from “delayed” or “under review,” since it has to be effectively rebuilt from a procedural standpoint, not just reinstated.
The FTC is trying again, but it’s not finished
In March 2026, the FTC launched a new rulemaking process — an Advance Notice of Proposed Rulemaking — specifically aimed at reviving some version of the click-to-cancel protections. This is a real, active effort, not an abandoned idea, but it’s an early-stage regulatory process that takes time to produce an actual final rule, and there’s no guarantee the eventual result matches the vacated 2024 version exactly. As of now, this hasn’t produced anything binding yet.
What’s actually protecting you in the meantime
The FTC hasn’t lost all authority here — it retains general power under Section 5 of the FTC Act to act against “unfair or deceptive acts or practices,” a broader, more case-by-case standard than the vacated rule’s specific, clear requirement. This has continued to support enforcement action against clearly bad-faith cancellation practices, just without the bright-line “as easy to cancel as to sign up” test the vacated rule would have provided. Separately, and often more directly relevant: roughly 30 US states have their own automatic-renewal laws, and some are stricter than the vacated federal rule would have been. Practically, this means the real, enforceable protection against a hard-to-cancel pet tech subscription currently depends more on which state you’re in than on a single uniform national standard.
What to actually do if a subscription is hard to cancel
Document the friction as it happens — screenshots of a buried or broken cancellation flow, timestamps if you’re stuck on hold or unanswered by chat or email. Check your specific state’s automatic-renewal law for what it actually requires of subscription businesses, since this varies and some states offer real, specific protections beyond the general federal standard. If a company still won’t cooperate, a chargeback through your card issuer or a complaint to your state attorney general’s consumer protection office are real, available paths — not something to treat as an unavoidable cost of having subscribed in the first place.
How this connects to the rest of this site’s subscription coverage
This is about cancellation difficulty specifically — a different question from our subscription overlap guide (paying for the same feature twice across devices) or our trial periods guide (a manufacturer’s own return window before you’ve committed at all). If you’re choosing between subscription-gated pet tech options, it’s reasonable to weigh a company’s actual cancellation process — check it before subscribing, not after — alongside price and features, especially while federal protection on this specific issue is in an unsettled, in-progress state.
Bottom line
There’s currently no binding federal rule guaranteeing an easy pet tech subscription cancellation — the one that would have done that was vacated in 2025 and is being rebuilt, not currently active. Real protection right now comes from general FTC deceptive-practices authority and, more concretely, your specific state’s automatic-renewal law. If a subscription is genuinely hard to cancel, document it and use the real enforcement paths available (chargeback, state attorney general complaint) rather than assuming there’s no recourse.
Frequently asked questions
Is the FTC's click-to-cancel rule currently in effect?
No — a federal court of appeals vacated the rule in 2025, finding the FTC violated required rulemaking procedure (the Administrative Procedure Act) when it finalized the rule. It is not currently binding federal law. The FTC responded by launching a new rulemaking process (an Advance Notice of Proposed Rulemaking) in March 2026 to try to revive some version of it, but that process takes time and hasn't produced a new final rule yet.
Does that mean companies can legally make cancellation as hard as they want right now?
Not entirely — the FTC retains general authority under Section 5 of the FTC Act to act against "unfair or deceptive acts or practices," which has continued to apply to clearly bad-faith cancellation practices even without the specific vacated rule in place. It's a less precise, case-by-case standard than the vacated rule's clear requirement (cancellation must be as easy as sign-up), but it isn't a total absence of federal oversight either.
Are there other protections if the federal rule isn't in effect?
Yes — roughly 30 US states have enacted their own automatic-renewal laws, and some of these are stricter than the vacated federal rule would have been. Real protection against a hard-to-cancel subscription currently depends more on which state you're in than on a single uniform national standard, which is worth knowing if a specific pet tech subscription is proving difficult to cancel.
What should I actually do if a pet tech subscription is hard to cancel?
Document the difficulty (screenshots of a hidden or broken cancellation flow, timestamps of phone hold times or unanswered requests), check your specific state's automatic-renewal law for what it actually requires, and if the company won't cooperate, a chargeback through your card issuer or a complaint to your state attorney general's consumer protection office are real, available options — not just tolerating it as unavoidable.