Background: the federal click-to-cancel rule is vacated, and the FTC started over in March 2026

Background. This event was more than 90 days old when we wrote this post. Prices, plan names or rules may have changed since; newer posts on the news page say so where we know.

Timeline: 2024 FTC finalizes the click-to-cancel rule, 2025 the Eighth Circuit vacates it, March 2026 the FTC asks for comment on a new rule, no new rule in force today.

What changed?: The FTC's 2024 Click-to-Cancel Rule was vacated by the Eighth Circuit in Custom Communications, Inc. v. FTC (2025). In March 2026 the FTC issued an Advance Notice of Proposed Rulemaking asking for comment on revising its Negative Option Rule, including whether to bring back parts of the vacated rule, according to a 2026-03-23 analysis by the law firm BCLP.
When?: Court decision: 2025. FTC advance notice: March 2026. No new rule is in effect. Background: more than 90 days old.
Who is affected?: Every US consumer with a subscription, Starlink customers included. Nothing in Starlink's own terms changed because of this, as of our 2026-10-05 reading.
What should you do now?: Rely on Starlink's own terms for cancelling and returns, not on the vacated federal rule. Note your Payment Due Date and the date your next invoice will be generated.
What stays the same?: Starlink's Referral Program Terms, as we read them on 2026-10-05, still give a new customer one free month on the eligible plan they pick, credited to the second monthly bill. You still pay month one, still need to order the kit and plan on starlink.com through a current customer's link, and still need two full billing cycles on a high-speed plan (Standby doesn't count). Starlink's Terms of Service still say you must cancel before the next invoice is generated to avoid that month's charge.

Source

"I'm Not Dead Yet": Is the Demise of the FTC's Click-to-Cancel Exaggerated? Legal analysisBryan Cave Leighton Paisner (BCLP) · published 2026-03-23 · retrieved 2026-10-06

What the rule would have done

The 2024 rule required sellers to disclose material terms clearly, get express informed consent before charging, and offer a way to cancel that is at least as simple as signing up. BCLP's analysis says the Eighth Circuit vacated it because the FTC did not follow required procedural steps and went beyond its authority.

BCLP also notes that the Restore Online Shoppers' Confidence Act (ROSCA) is still in force, and the FTC still brings cases under it.

What happened in 2026

In March 2026 the FTC issued an Advance Notice of Proposed Rulemaking on the Negative Option Rule. That is an early step: it asks questions, it does not set rules. BCLP says the FTC has not confirmed it will restore the 2024 rule.

How this touches the free month

The free month only works if you stay subscribed long enough. Starlink credits it to your second bill, and the referral only matures after two full billing cycles on a high-speed plan. If you cancel early, you lose it (see Paused, cancelled or switched to Standby early).

The 30-day return window is a separate thing, and it comes from Starlink's Terms of Service, not federal law. Our free trial page explains it, and the glossary defines Payment Due Date and billing cycle.

What we don’t know yet

Whether the FTC will propose a new cancellation rule, and when. The March 2026 notice is a request for comment.
The exact day of the Eighth Circuit decision is not given in the analysis we cite; we give the year only.

Corrections

No corrections to this post. If something here is wrong, tell us and we’ll fix it in the open, with a dated note.

Where to next

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The short answer