Click to Cancel is also requiring "sellers" to provide information to customers including when they are being switched from a free trial to a paid subscription, and requiring consent from customers before doing so. It also will "prohibit sellers from misrepresenting any material facts while using negative option marketing."

The Commission voted 3-2 to approve publication of the final rule in the Federal Register, with Commissioners Melissa Holyoak and Andrew Ferguson voting no. Not surprisingly, industry leaders complained that it forces an undue burden on businesses, even though websites and apps can be updated with unsubscribe buttons fairly easily.