FTC's 'Click-to-Cancel' Rule Vacated by Federal Court

What Happened

Today, the US Court of Appeals for the Eighth Circuit struck down the FTC's  “Click-to-Cancel” Rule—a major victory for the fitness industry and a direct result of HFA’s sustained advocacy.

HFA has been deeply involved in this issue for more than two years, starting with formal comments on the original proposal and continuing through every phase of the process. We filed an amicus brief in the case to highlight the rule’s burdens on health and fitness facility operations, while also leading a Capitol Hill strategy to prepare a Congressional Review Act resolution in partnership with the US Chamber and industry allies.

The rule, finalized in October 2024, would have required cancellation processes to match sign-up methods, disrupting billing systems, trial offers, and contract structures across the fitness industry.

Industry Impact

As a result of the ruling:

• The FTC rule is fully vacated and will not take effect on the July 14 compliance date
• Fitness operators are no longer subject to rigid, unclear cancellation mandates, avoiding costly system overhauls, contract restructuring, and potential legal exposure
• HFA’s efforts prevented unnecessary cancellations and refund disputes that could have arisen from the rule’s vague requirements

The court affirmed what HFA and its partners warned all along: the FTC’s process was flawed, its cost estimates off base, and it imposed a blanket standard with no regard for how fitness businesses operate.

This is a landmark advocacy win—and a powerful example of what HFA can accomplish through early engagement, legal leadership, and coordinated advocacy.

What's Next

HFA supports fair, transparent cancellation policies, but we oppose unworkable, one-size-fits-all mandates that ignore the realities of fitness business operations.

We will continue to advocate for consumer-friendly policies at the state level that strike the right balance between member rights and operational feasibility for clubs and studios.

If the FTC revisits this issue, HFA will once again lead the charge—at the agency, in Congress, and in the courts—to ensure any future rule is practical, proportionate, and industry-informed.

We’ll keep you updated and continue working to protect your business and strengthen the member experience.