Guide · facts checked 5 Nov 2026
Can your cancel flow show an offer? What the click-to-cancel rules say
Under California's automatic renewal law, yes: it lets a business show a discount, a retention benefit or information about what cancelling means to someone who asks to cancel online, as long as a prominent 'click to cancel' link or button is displayed with it and works promptly. The FTC's federal click-to-cancel rule was vacated by a federal appeals court in July 2025 and the FTC restarted rulemaking in March 2026, so California's statute is the written text to design against while the federal rule is rebuilt.
What California's statute says about retention offers
The rule sits in California Business and Professions Code section 17602, as amended by AB 2863. Three parts matter for a cancel flow.
- Cancel online if you sign up online. A business that lets a consumer accept an automatic renewal or continuous service offer online must let them end it “exclusively online, at will, and without engaging any further steps that obstruct or delay” the cancellation. The online method is a prominently located direct link or button (in the account, profile or settings), or an immediately accessible termination email the customer can send without adding information.
- An offer is allowed. Subdivision (e) says a discount offer, another benefit, or information on the effect of cancelling “shall not be considered an obstruction or delay”, provided the consumer remains able to cancel.
- The condition for an online flow. If a consumer asks to cancel through an online system, the business may display a discounted offer, retention benefit or information about the effects of cancelling, “provided that the business simultaneously displays a prominently located and continuously and proximately displayed direct link or button entitled ‘click to cancel,’ or words to that effect, with the presentation” of the offer. If the consumer uses that link or button, the business must promptly process the cancellation and not obstruct or delay it.
Account login is allowed: a business may require a customer who has an account to authenticate before cancelling online. A customer who cannot or will not authenticate online must still be able to cancel by another method.
When it applies
| Point | What the statute text says |
|---|---|
| Who it covers | Businesses that make an automatic renewal or continuous service offer to a consumer in California. |
| Which contracts | Contracts entered into, amended or extended on or after 1 July 2025 (subdivision (j)). |
| Where to cancel | In the same medium used to sign up, or the one the consumer is used to dealing with you in (subdivision (f)). A phone sign-up needs a retainable phone number. |
| Other duties in the same section | Clear renewal terms before purchase, express consent, a retainable acknowledgment with how to cancel, an annual reminder for annual plans (subdivision (h)) and notice of fee changes (subdivision (g)). |
The section talks about consumers. Whether your customers count as consumers, and which other states’ laws reach you, depends on who you sell to and where they live; ask a lawyer which of those apply to you.
What happened to the federal rule
The FTC adopted a click-to-cancel amendment to its Negative Option Rule in October 2024. In July 2025 the Eighth Circuit vacated it. According to a law-firm summary of the decision, the court acted on one argument only: that the FTC did not prepare a required preliminary regulatory analysis before finalising the rule. The court did not rule on the others.
The FTC then started over. On 11 March 2026 it announced an advance notice of proposed rulemaking asking for public comment on whether to amend or replace the Negative Option Rule, including whether to revive some portions of the vacated amendments. A request for comment is not a rule: as of 5 Nov 2026 the law-firm coverage checked reports no proposed or final rule in force. Federal enforcement continues under the existing law, including the Restore Online Shoppers’ Confidence Act (ROSCA), which requires a simple mechanism to stop recurring charges, so a cancel flow that is hard to use is still a federal risk.
A cancel-flow design checklist
These are design practices that follow from the statute’s wording. They are not legal advice.
- Show the cancel option on the same screen as the offer, labelled “Cancel”, “Cancel anyway” or similar, not hidden in small print or behind a scroll.
- One click from the offer to the cancel. No second survey, no “are you really sure” loop after they click it. Ask for a reason before the offer, and make the reason optional if you can.
- Cancel end-to-end online. If sign-up is online, do not send people to a phone number or a support email to cancel.
- Keep the offer to information and value. A discount, a pause or a lower plan. Not a delay: no timers that keep the button disabled, no waiting for an email.
- Process the cancel at once. In Stripe terms, set
cancel_at_period_endas soon as they click, as in building a cancel flow with Stripe, and confirm the end date on the page. - Re-check the text. The section was amended in 2024 and has a long list of duties beyond cancelling; read it before you launch, and again when you change the flow.
See an offer next to a one-click cancel
Run a sample cancel session: play a subscriber, give a reason, and see the offer the AI picks.
90 seconds, no sign-up. You play the subscriber; the AI answers, and “Cancel anyway” is always one click away.