Compliance Solution for FTC Click-to-Cancel

In this article, we will cover:

• FTC Click-to-Cancel Overview
• Why this matters
• What's changing in Glofox
• Frequently asked questions
• Next steps and additional support

FTC Click-to-Cancel Overview

In response to new Federal Trade Commission (FTC) regulations and state-level Automatic Renewal Law (ARL) updates, Glofox is rolling out key compliance features to help your gym or studio meet legal requirements for subscription cancellation.

Deadline: The FTC rule takes effect July 14, 2025 (updated date)

Applies to: All US-based businesses offering auto-renewing memberships.

Why this matters

• Make canceling as easy as signing up
• Increase transparency in recurring billing
• Avoid unauthorized charges
• Minimize legal and financial risk for non-compliance

What's changing in Glofox?

1. Auto-Renewal Disclosures

• Displayed clearly across Member App, Web Portal, and Lead Capture Forms
• Text adjusts based on membership type (contract, open-ended, prepaid, etc.)

2. Checkout Screen Enhancements

• T&C Consent Before Payment: Members must scroll through and accept your Terms and Conditions before entering billing details.

• Separate Auto-Renewal Consent: A distinct confirmation step for recurring memberships ensures full awareness of ongoing charges.

3. E-Agreements (If Enabled)

• Members sign the T&C again post-purchase if e-agreements are active.
• Applies to memberships only, not add-ons.

4. Cancel Membership/Add-on Button

• Appears under each active or future service in the Profile section of the app and portal.
• Add-ons can only be cancelled in the app as they are not available for purchase in the web portal.

5. Cancellation Request Form

• Members select a cancellation reason from a list and submit the request directly.
• Sent to both the member and the location email on file.

6. Success & Pending Status Messaging

• A confirmation screen appears after submission.
• If not yet processed, members see a pending message instead of the cancel button.

7. Cancellation Request Email

• The cancellation email will be sent to the member's email and CC the location's dedicated email address (Settings > Studio > Email address).

 

Frequently asked questions

1. Cancellation process and requests

Is the cancellation of the membership automated?

No. Cancellation requests are not automated. Each request must be manually reviewed and processed by the location. Non-compliance by the location in processing cancellation requests may lead to financial and legal consequences.

What if a location has a cancellation notice period?

The notice period must be stated explicitly in the T&Cs. Locations must still allow online cancellation per FTC requirements but may delay the effective cancellation date to honor the notice period.

Can a location charge cancellation fees?

Yes, if clearly and conspicuously disclosed in the membership T&Cs and sign-up flow. The fee must be processed manually as a custom charge.

How much time does a location have to process the cancellation?

The location must cancel in accordance with the terms of the Membership agreement/T&Cs and applicable law (including any applicable state or local law). Certain areas may have laws that require processing a cancellation within a specific amount of time.

Are cancellation requests tracked in the dashboard?

Not currently. Locations must monitor their inbox for cancellation emails. We may consider introducing Tasks for better tracking in the future.

Does the member receive an automated email when a membership gets cancelled?

No. Locations must manually notify the member and confirm the cancellation details. This is not an FTC requirement, but providing confirmation is best practice to reduce follow-up inquiries.

What if a member sends multiple cancellation requests?

Treat duplicate requests as a single case. Confirm once and update internal records accordingly.

2. Membership types and edge cases

Do Auto-renewal regulations apply to single/prepaid memberships?

FTC laws apply only to auto-renewing (negative option) memberships. Locations may still define buyer’s remorse or refund policies for prepaid memberships in their T&Cs, so members will be allowed to request cancellation for pre-paid memberships/addons.

Can a member request to cancel a locked or paused membership?

Yes. FTC guidelines require that auto-renewal cancellation must be possible even if the membership is locked or paused. Locations can attempt to collect outstanding balances separately and notify the member about access limitations. Blocking cancellation due to unpaid balances is not allowed.

Can a non-primary group member cancel a membership?

No. Non-primary members cannot request to cancel. They will see a message to contact the location directly to be removed from the group.

Can a family member cancel a membership?

Family members can request cancellation via the app or web portal. The request will be sent to their own email and to the location for processing.

Can a member cancel a membership from a non-home location if they have a roaming membership?

No. If a member is logged in in a non-home location, they cannot request to cancel. They will see a message to switch to their Home club.

If a member has both an active and a future membership, can they cancel both at once?

No. They’d need to cancel the future membership first. If the active membership is cancelled first, the future one will activate automatically.

Does cancelling a membership also cancel associated add-ons?

Yes. Add-ons tied to the membership are automatically cancelled. Members may also request to cancel an add-on independently. Please note that add-ons cannot be scheduled for cancellation in the dashboard, so locations should cancel them manually the day before the next billing date.

Does a cancellation cancel future bookings?

• Recurring bookings: will be removed when the membership becomes inactive.
• Single bookings: remain intact.

3. Cancellations for contract memberships

How should locations handle cancellations of contracts mid-term?

Locations must follow their membership terms and conditions. If mid-term cancellation is allowed, locations may apply early termination fees or offer pro-rated refunds, based on what is outlined in the agreement. If mid-term cancellation is not allowed, locations may require the member to complete the current term. These rules must be clearly disclosed in the membership terms and conditions. Glofox does not enforce these terms. Locations are responsible for compliance. Members must still be allowed to terminate the auto-renewal of their membership at any time. Immediate cancellation of the current term is only required if permitted by the membership agreement.

Can a member cancel the auto-renewal of an end-date contract membership?

Yes. Members must be able to cancel the auto-renewal of their agreement at any time. After cancelling, the membership stays active until the end of the current term. Members are not required to cancel immediately mid-term. Currently, the cancellation of auto-renewal for contracts with an end date may require manual action by the location. Locations should ensure the cancellation request is processed before the next renewal.

4. Membership terms & conditions and consents

What needs to be included in the membership T&Cs to be compliant?

T&Cs must:

• Clearly and conspicuously disclose all material terms.
• Clearly explain how to cancel (e.g., app, web.
• State the processing time (must comply with FTC/state timelines).
• Disclose any cancellation fees, notice periods, and auto-renewal conditions.
• Mention annual fees or maintenance charges—these must be disclosed up front.

Only one agreement template is supported in Glofox, so T&Cs should account for all membership types. These can be updated in Settings > Forms > Membership Terms and Conditions.

Are member auto-renwal consents and T&C acceptance stored for legal disputes?

Yes, both consents are tracked within the membership purchase. Auto-renewal consent tracking is being finalized. Staff don’t need full visibility, but the system must be able to confirm acceptance occurred.

Why do members need to scroll and sign if e-agreements are turned on?

The legal requirements mandate that all material terms must be clearly and conspicuously disclosed, and unavoidable. Documents are generated post-checkout. Scrolling and acceptance of T&Cs must happen before billing info is collected to meet FTC requirements. This is unavoidable due to technical and legal constraints.

Can merge tags be used in Membership T&C to dynamically populate information?

If you're using e-agreements, you can use merge tags in Forms to add placeholders into the document to dynamically populate in the preview. If you are not using e-agreements, you can still use the tags, but will need to add the placeholders/ manually into the document text.

Below is the list of values that you can include as static text:

[branch_name]

[branch_address]

[membership_name]

[plan_name]

[billing_frequency]

[upfront_fee]

[price]

[first_name]

[last_name]

[email]

[dependant_first_name]

[dependant_last_name]

5. API & Custom integrations

How do integrators ensure compliance if the location uses a custom app or flow?

Integrators are responsible for implementing FTC-compliant purchasing and cancellation workflows. For documentation reach out to your Customer Success Manager.

Next steps and additional support

If you have any questions, reach out to us at support@glofox.com or contact your Customer Success Manager.