In October of 2024 the Federal Trade Commission announced a "Click-to-Cancel" rule. The rule mandates that canceling a subscription must be as straightforward as signing up for it.
Most provisions of this rule are set to take effect on May 14, 2025.
It's important for U.S.-based hosts to be aware of how the new rules will apply to their day to day activities, specifically around any customer retention strategies.
To help you stay within compliance, Momence has been working on changes to our platform based on the details of this announcement. However, there are certain aspects (like how you run your business in the physical world, away from the computer) that these rules can still apply to.
The list below highlights some key points made in the announcement that likely apply to your business. You can read the full announcement and breakdown of each rule here.
Here are some of the new requirements
Easy Cancellation Process
A customer's cancellation process must be as simple as the sign-up process
If a customer enrolls online, they must be able to cancel online without additional steps like calling or visiting in person.
No unnecessary barriers (e.g., requiring users to interact with customer service before canceling).
Clear Disclosures
Customers must be clearly informed about recurring payments, cancellation terms, deadlines, and costs before they're charged
This information must be easily noticeable and understandable.
Explicit Consent
Users must actively agree to recurring charges through a separate, clear action (e.g., checking a box, signing a document).
The platform must store records of consent for at least three years.
"Save" Attempts are Allowed (With Limits)
Before a cancellation is finalized, businesses can offer membership pauses, lower-tier plans, or discounts, but they cannot make it difficult to cancel.
Customers must explicitly agree to any alternative before their cancellation request is denied.
Annual Reminders are Not Required
Fitness memberships do not need to send annual reminders about auto-renewal.
Where will these changes show in Momence and is there anything I need to do?
In short, using the guidelines above, make sure each of your subscription contracts explain your cancellation policies clearly.
Check that the 'number of auto-renewals before a member can cancel' matches what's written in the contract above it.
Momence can then ensure you're in compliance everywhere else on the site by displaying the correct information to your customers in the correct places at the right times.
Here's a list of recent and past changes we've made to help you stay in compliance
Momence meets clear disclosure requirements by displaying a simplified list of what the membership entails for minimum renewals.
On mobile, there's new wording on renewal periods required by the contract, shown directly in the checkout section.
Membership Contracts must be read and signed before a purchase can be made, and contracts are displayed prominently.
After a contract is signed, it can be easily accessed from your end in a customer's profiles and by the customer, from their own account.
From all areas, PDFs can be downloaded.
If a customer attempts to cancel a subscription early (ie. in month 2 of a 3 month contract), the cancel button will be greyed out with a hint to clarify why cancellation isn't possible at this time.
On mobile, a customer attempting to cancel too early will see the same disabled button with an explanation (bottom of image).
Explicit Consent
A new checkbox will also now display on checkout pages for consent with recurring charges.
The checked status is required for all auto-renew memberships (including packs with the auto-refill feature).
In Settings > Your account - General, there is a new toggle labeled “Disable customers from being able to cancel their renewing memberships (overrides individual membership settings)”.
When this toggle is enabled, a modal appears displaying an explanation along with a link to the Click-to-Cancel policy.