Connecticut’s Click-to-Cancel Law Is Now in Force, and the FTC Is Rewriting Its Own: What Martial Arts Schools With Auto-Renewing Memberships Need to Do
The federal click-to-cancel rule was struck down in 2025, and many school owners took that as the end of the matter. It was not. Connecticut’s tougher automatic-renewal rules have been in force since 1 July, the state attorney general has said he will enforce them, and the Federal Trade Commission has restarted its own rulemaking. If your memberships renew automatically, the direction of travel is clear.
The facts in brief
- Connecticut: amendments to the state’s automatic-renewal law, passed as Senate Bill 3 of the 2025 session (“An Act Concerning Consumer Protection and Safety”), took effect 1 July 2026.
- The core duties: an annual renewal reminder; cancellation that does not require a visit or a letter; an online, email or phone route to cancel; and action on a voicemail cancellation within one business day.
- Enforcement: Attorney General William Tong said on 16 July that non-compliance may be an unfair trade practice and that his office “will not hesitate to enforce the law.”
- Federal: after the Eighth Circuit vacated the FTC’s 2024 click-to-cancel rule in July 2025, the FTC opened a new rulemaking in March 2026. Comments closed on 13 April 2026. No proposed rule has been published.
What Connecticut now requires
The rules apply to businesses that sell consumers goods or services under contracts that renew automatically unless the consumer cancels. The exemptions listed by the attorney general — utilities, banks and credit unions, certain regulated entities and some national content providers — do not include fitness businesses or schools. A Connecticut martial arts school with auto-renewing memberships should assume it is covered.
| Requirement | What it means in practice |
|---|---|
| Annual reminder | Once a year, tell each member what renews, how often, how much it costs and how to cancel |
| No in-person or mail-only cancellation | “Come in and see us” or “send a certified letter” can no longer be the only way out |
| A real cancellation route | If you have an online platform, a clear online cancellation option or a dedicated cancellation email; if you do not, a phone number |
| Prompt processing | Cancellations must be handled without obstruction or delay |
| Voicemail | If a member leaves a voicemail asking to cancel with enough information to act on, the renewal must be cancelled within one business day |
According to an analysis by the compliance firm CompliancePoint, the same bill also struck the sentence in the statute that said it created no private right of action, opening the door to consumer lawsuits. Treat that as a reason for care rather than a settled reading; take Connecticut legal advice on your exposure.
Two laws, not one. Connecticut’s Health Club Act, which governs registration, contract terms, bonding and three-day cancellation for health clubs, still applies separately where a school falls within it. Our Connecticut reference entry covers both.
Where the federal rule stands
The FTC’s 2024 “click-to-cancel” amendments to its Negative Option Rule would have required simple cancellation nationwide. The Eighth Circuit vacated them in July 2025, finding that the agency had skipped a required preliminary regulatory analysis. In March 2026 the FTC issued an advance notice of proposed rulemaking asking whether to revive the vacated provisions, adopt a different approach or treat some industries differently. About 100 comments were filed by the 13 April deadline, according to the law firm Jones Day. The next step would be a proposed rule; none has appeared.
In the meantime the FTC continues to bring cases under the Restore Online Shoppers’ Confidence Act and Section 5 of the FTC Act, alleging the same three failures the vacated rule targeted: unclear terms, charging without consent and obstructing cancellation. About 30 states have their own automatic-renewal laws.
What school owners should do now, in any state
- Audit how a member cancels. Count the steps. If cancelling is harder than signing up, fix it before a regulator or a plaintiff counts them for you.
- Add an annual reminder. Even where it is not yet required, a yearly statement of what renews, when and for how much prevents disputes and chargebacks.
- Check your voicemail and inbox daily. In Connecticut a voicemail can start a one-business-day clock.
- Separate retention from obstruction. You can still offer a member a conversation, a freeze or a different programme. You cannot make that conversation the price of leaving.
- Look up your own state. Our membership contract law by jurisdiction covers all 50 states and DC, Canada, the UK, Australia and New Zealand.
Frequently asked questions
Does Connecticut’s law apply to martial arts schools?
It applies to businesses with consumer contracts that renew automatically. The listed exemptions do not include fitness businesses or schools, so a Connecticut school with auto-renewing memberships should assume it is covered and confirm with a Connecticut lawyer.
When did it take effect?
1 July 2026.
Is the FTC click-to-cancel rule in effect?
No. The 2024 rule was vacated by the Eighth Circuit in July 2025. The FTC began a new rulemaking in March 2026; no proposed rule has been published. The FTC still enforces existing law against deceptive subscriptions.
Can a school still try to keep a member who wants to cancel?
Yes, but in Connecticut cancellation must be prompt and unobstructed. An offer to pause or switch programmes is fine; requiring a meeting before cancelling is not.
Sources
- Connecticut Office of the Attorney General, “Attorney General Tong Highlights New Click-to-Cancel Consumer Protections,” 16 July 2026.
- CompliancePoint, “Connecticut Creates a Private Right of Action for Automatic Renewals.”
- Health & Fitness Association, “Connecticut’s Updated Automatic Renewal Law Adds New Requirements for Fitness Operators,” September 2026.
- Jones Day, “FTC Revives Click-to-Cancel Rule: New Risks for Subscription Businesses,” May 2026.
- Cooley, “FTC Issues New Advance Notice of Proposed Rulemaking on Negative Option Marketing,” 19 March 2026.
This article provides general information and is not legal advice.
