Last week, Match Group Inc., the powerhouse behind Match.com, OkCupid, Plenty of Fish and The League, agreed to shell out $14 million and revamp its cancellation policies, ending a nearly six-year showdown with the Federal Trade Commission. The message to subscription-based businesses? Even after the Eighth Circuit overturned the FTC's "click-to-cancel" rule in July 2025, companies may still face scrutiny for making it hard for customers to say goodbye.
Match's "Guarantee" Comes With Strings Attached
The FTC sued Match in 2019, alleging that the company deceived users with its widely advertised "six-month guarantee," which promised a free six-month renewal if someone hadn't "met someone special" within their initial six months. In practice, eligible users hit a wall of hidden conditions and "onerous" requirements that weren't clearly disclosed.
The agency also took aim at Match's billing practices, claiming the company locked out users who lost billing disputes, even after collecting payment and without providing the purchased services. The settlement now requires Match to:
- Clearly and conspicuously disclose all terms of its six-month guarantee
- Make account cancellation straightforward and accessible
- Stop retaliating against users for disputing charges
Match does not admit or deny any wrongdoing as part of the settlement.
Click-to-Cancel Is Dead—But the Fight Isn't Over
Just days before the FTC's new "click-to-cancel" rule was set to take effect in July 2025, the Eighth Circuit vacated the rule – meaning, for now, companies aren't federally required to make cancellation as easy as sign-up with a single click. But while the rule itself may be dead, companies should not treat the decision as a green light for confusing or convoluted cancellation pathways.
The FTC and state regulators continue to scrutinize so-called "dark patterns" and difficult cancellation processes under existing consumer protection laws, many of which remain in force nationwide. States like California, for example, mandate accessible cancellation for automatic subscription renewals.
Key Takeaways for Subscription Services
- Easy-out is still best practice: Whether or not "click-to-cancel" is the law of the land, making cancellation simple helps avoid both legal headaches and reputational blowback.
- Honest, upfront terms: Any "guarantee" – especially those that entice users to subscribe – must be clearly explained up front, not buried in small print.
- No more paywalls after payment: Denying paid-for service or retaliating against users who dispute charges is likely to draw regulator (and customer) ire.
- Watch the regulatory horizon: Legal rules around automatic renewals and recurring charges remain in flux. Monitoring both federal and state law is crucial for compliance.
Match Group's $14 million lesson is loud and clear: consumer protection isn't going anywhere. In a world of recurring charges and auto-renewals, businesses should treat transparency and easy exits not as legal obligations, but as brand essentials.
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