Privacy, accessibility and AI rules

Membership cancellation rules for gyms, studios and subscriptions.

The FTC's click-to-cancel rule was struck down, but cancelling a membership is still regulated. This guide covers what happened to the rule, the federal and state laws that apply anyway, the European rules, and how to build a sign-up and cancel route that holds up.

Updated 29 October 2026, about 9 minutes to read

The short answer

The FTC's click-to-cancel rule is not in force: a federal appeals court vacated it in July 2025, and in 2026 the FTC asked for comments on a new one. Memberships sold online in the US still fall under ROSCA, which requires clear terms before billing, express consent and a simple way to stop charges, and under state laws such as California's, which requires online cancellation for online sign-ups.

The short answer

If you run a gym, a studio, a salon with memberships or any plan that bills every month, the rule people call click to cancel is not what you need to follow. The laws that already applied before it still do, and they ask for most of the same things: show the terms before you take payment details, get a clear yes to the recurring charge, and make stopping it simple.

California and some other states go further, and Europe has its own rules, including a cancellation button in Germany and new UK rules due in 2027. Build one route that meets the strictest of them, and you rarely need to think about which law applies to which member.

Fees for missed classes or appointments are a separate matter, covered in the no-show and cancellation policy guide. This guide is about ending the membership itself.

What happened to the click-to-cancel rule

The rule's short history, from the FTC's own records and the court's opinion:

  • October 2024: the FTC announced a final rule amending its Negative Option Rule, which covers offers that renew or continue unless the customer acts. Among other things, it banned misrepresentations in this kind of marketing, required sellers to give important information before taking billing details, and required simple cancellation.
  • 8 July 2025: the US Court of Appeals for the Eighth Circuit vacated the rule in Custom Communications v. FTC. It found the FTC's failure to issue a preliminary regulatory analysis procedurally insufficient.
  • 12 February 2026: the FTC restored the text of its Negative Option Rule as it stood before 2024. That older rule, first made in 1973, covers prenotification plans, the kind where a seller sends something each period unless the member declines it in time.
  • 13 March 2026: the FTC published an advance notice of proposed rulemaking, asking whether to amend the rule again to help consumers avoid recurring payments they did not intend and cancel without unwarranted obstacles. Comments closed on 13 April 2026.

When this guide was written, the FTC's page for the rule listed nothing after that notice. Check the FTC's Negative Option Rule page before you rely on any of this, because a new proposal could follow.

What still applies across the US: ROSCA

The Restore Online Shoppers' Confidence Act of 2010 covers goods and services sold on the internet through a negative option feature, which includes a monthly membership that bills until the member cancels. It makes charging such a customer unlawful unless the seller:

  • Clearly and conspicuously discloses all material terms of the transaction before obtaining billing information.
  • Obtains the customer's express informed consent before charging their card or account.
  • Provides simple mechanisms for the customer to stop recurring charges.

The FTC is using it against gyms. In August 2025 it sued the operators of LA Fitness, alleging that members could cancel only in person with one designated employee at each club, or by post, that staff were trained to reject escalated requests and deny cancellations by phone or email, and that add-ons such as towel service or childcare were billed as separate recurring programmes without telling members they could be cancelled separately and more easily. The complaint was amended in January 2026, and the FTC's case page still listed the case as pending. These are allegations, not findings.

The FTC's own advice to businesses after filing it was plain: be clear up front about what customers are committing to, including monthly fees, annual fees and add-ons, explain how to cancel, and offer a simple way to stop the charges. In its words, consumers should be able to choose which recurring charges they want to keep.

State laws: California and others

California's Automatic Renewal Law was strengthened for contracts entered into, amended or extended from 1 July 2025. The parts that matter most to a membership business:

  • A consumer who signed up online must be able to cancel online, at will, without steps that obstruct or delay it. The route is a prominently located direct link or button, which can sit in their account, or an immediately accessible termination email that the business formats and provides.
  • The business may ask a member with an account to log in first, but a member who cannot log in must still be able to cancel another way.
  • A discount or other save offer is allowed during online cancellation only if a prominently located link or button, labelled click to cancel or similar, stays on screen beside it, and the business processes the cancellation promptly when it is used.
  • The member must give express affirmative consent to the renewal terms.
  • The business must send an annual reminder naming the plan, how often and how much it charges, and how to cancel.
  • A price increase needs notice at least 7 and no more than 30 days before it takes effect.

The Attorney General adds that a business must offer a toll-free number, an email address or another easy cancellation method, and that consumers must be able to cancel the way they enrolled or the way they usually deal with the business.

Some states also have laws on health club contracts specifically. New York's, for example, lets a member cancel within three business days of receiving a copy of the contract, and later if they move more than 25 miles from a club the seller operates. Check the law of each state where you sell memberships.

The EU and the UK

The EU's Consumer Rights Directive asks for the commitment to be visible before the sign-up. The consumer must be told the total price per billing period, and the total monthly cost where the price is fixed, how long the contract lasts, how to end it and any minimum term. The price, the duration and the minimum term have to be shown again right before the order, on a button labelled "order with obligation to pay" or an equally clear phrase.

A membership bought online is usually a distance contract, so the 14-day withdrawal right is the starting point. A member who wants to start classes inside the 14 days has to ask for that expressly, and if they then withdraw, they pay for what they used. The directive's exceptions include leisure services booked for a specific date or period, so ask your adviser how your memberships are treated. From 19 June 2026, EU sites also need an online withdrawal function, described in the terms and conditions guide.

Germany goes further. A website that lets consumers sign up for an ongoing paid service must offer a cancellation button labelled "Verträge hier kündigen" or equally clear words, leading to a confirmation page with a button labelled "jetzt kündigen". If the business does not provide them, the consumer may cancel at any time without notice. German standard terms also cannot tie a consumer in for more than two years at first, and after that the contract can only roll on with no fixed end and at most one month's notice to leave.

In the UK, a new regime for subscription contracts under the Digital Markets, Competition and Consumers Act 2024 is due to start on 1 January 2027, the date in the government's draft regulations. It brings clear information before sign-up, reminders before a free trial ends or a contract of 12 months or more renews, a straightforward exit, online exit for online sign-ups, and a 14-day cooling-off period after a trial or a 12-month contract renews.

Show the terms where people join

Most cancellation disputes start at sign-up, when the member never saw the minimum term or the renewal. Put the terms in plain text next to the join button, not behind a link:

  • "Unlimited classes, billed monthly on the day you join. No minimum term. Cancel any time from your account, and your membership ends at the close of the month you have paid for."
  • "12-month membership, billed monthly. After 12 months it continues month to month until you cancel. Cancel online from your account. If you cancel in the first 12 months, the remaining months of the year are still due."

Then cover the details members ask about later: the date each payment is taken, what any add-on costs and how to cancel it on its own, whether a membership can be frozen, and what notice applies. Show prices per billing period with every mandatory fee included, as price display and fee rules explains.

Ask for the yes separately. An unticked box that reads "I agree that my membership renews every month until I cancel" records express consent in a way a buried sentence in the terms does not.

Build the cancel route before the join page

Design cancelling first and you will not have to retrofit it. A route that meets the strictest rules above:

  • A Cancel membership link in the member's account, as easy to find as the join button was.
  • One optional question about the reason. Never make an answer a condition.
  • If you show a save offer, a click to cancel button beside it on the same screen.
  • An immediate confirmation on screen and by email, with the date the membership ends and the date of the last payment.
  • Add-ons that can be cancelled on their own, the same way.
  • Cancellations accepted by phone, email and at the desk too, each logged with the date and time, so a member who asked is never charged again.

Check what your membership or booking software allows: whether members can cancel from their account, whether it sends a confirmation and whether add-ons are separate plans. Where it cannot, a cancellation form on your website that reaches the front desk and confirms to the member works, as long as someone acts on it the same day. An automation can log each request and send the confirmation where your software's API allows.

Test the route on a phone every month, logged in as a test member, from the join page to the confirmation email.

The front desk is not the gatekeeper

The quickest way to turn a cancellation into a complaint is a member who hears "you'll have to come in" or "I can't do that, only the manager can". Give staff one script and let anyone on shift use it:

  • "Of course. I'll cancel that now. Your last payment was on the 3rd, so you can keep coming until the end of the month. I'll email you the confirmation."

One save offer is fine if the member hears it once and the answer no ends the conversation. Log every request, including the ones made in passing at the desk, because a member who asked and was charged again is the case regulators and banks hear about.

A customer service chatbot can answer "how do I cancel" at any hour with the link to the account page, and pass anything unusual, such as a billing dispute, to a person.

How our own plans are written

Our monthly plans are a small example of terms shown beside the price. The prices page says they run from launch, month to month, that clients can change plan any month or stop with 30 days' notice, and that the domain, site and accounts stay theirs.

The one longer commitment sits in the same place: a website built with no setup fee in exchange for at least 12 months on the Growth or Full plan, then month to month. It is an option the client picks knowing the term. That is the habit this guide recommends for any membership: every commitment visible before anyone agrees to it.

Three memberships, checked

  • A climbing gym in Sacramento sells memberships online. It adds a cancel link to each member's account, shows its one save offer beside a click to cancel button, sends the annual reminder and gives notice of price rises 7 to 30 days ahead. A fitness studio anywhere can copy the same setup.
  • A salon in Denver sells a monthly blow-dry membership through its booking tool. ROSCA covers the online sign-ups, so the terms sit beside the join button, consent is a separate box, and members can cancel online or at the desk with an emailed confirmation.
  • A Pilates studio in Berlin puts a cancellation button on its website, explains the 14-day withdrawal right to members who join online, sets an initial term of no more than two years and then runs month to month with one month's notice.

Mistakes to avoid

  • Joining online, cancelling only in person or by letter.
  • A cancel link three screens deep in the account settings.
  • A save offer with no way past it.
  • Charging after a cancellation request because the paperwork was not finished.
  • Add-ons that cannot be cancelled on their own.
  • A minimum term mentioned in the terms but not beside the price.
  • Free trials that turn into paid plans without a reminder.
  • Assuming the click-to-cancel rule's defeat means no rules apply.

Questions people ask

Is the FTC click to cancel rule in effect?

No. The Eighth Circuit vacated it on 8 July 2025, and in February 2026 the FTC restored its older Negative Option Rule. In March 2026 the FTC asked for comments on whether to write a new rule, and comments closed on 13 April 2026. Online subscriptions are still covered by ROSCA and by state laws.

Do gyms have to let members cancel online?

In California, yes, if the member could join online, under the state's Automatic Renewal Law as amended from 1 July 2025. Federal law, through ROSCA, requires a simple way to stop recurring charges for memberships sold online. Other states have their own rules, and in Germany sites that sell ongoing contracts online need a cancellation button.

Can a gym make members cancel in person?

Not when a Californian joined online, because they must be able to cancel online. The FTC's case against LA Fitness, still pending in 2026, alleges that limiting cancellation to in-person visits or letters broke federal law. In-person cancellation can be one option, but it should never be the only one.

What is ROSCA?

The Restore Online Shoppers' Confidence Act, a 2010 federal law. For goods or services sold online with a negative option feature, such as automatic renewal, it requires a clear disclosure of all material terms before billing details are taken, the customer's express informed consent before charging, and a simple way to stop recurring charges.

Can I offer a discount when a member tries to cancel?

Yes, if it does not block the exit. California allows a save offer during online cancellation only if a prominently placed click to cancel link or button stays visible beside it, and the cancellation is processed promptly when it is used. Show the offer once, and never make the member call to finish.

Do I have to send membership renewal reminders?

In California, yes: an annual reminder of the plan, with its charges and how to cancel, and notice of a price increase 7 to 30 days before it starts. The UK's new rules, due from 1 January 2027 under draft regulations, add reminders before free trials end and before contracts of 12 months or more renew.