News & Analysis as of

Automatic Renewals Negative Option Rule Final Rules

Cooley LLP

FTC Delays Enforcement of Amended Negative Option Rule

Cooley LLP on

On May 9, the Federal Trade Commission (FTC) voted unanimously to delay enforcement of most portions of its amended Negative Option Rule (rule) by 60 days, shifting the compliance deadline for these portions from May 14 to...more

BakerHostetler

FTC Delays Enforcement of Negative Option Rule Until July 14

BakerHostetler on

The Federal Trade Commission (FTC) released a statement on May 9 deferring by 60 days its enforcement of certain provisions of the Negative Option Rule (the Rule). The bulk of the Rule’s requirements are now scheduled to go...more

DLA Piper

FTC Pauses “Click-to-Cancel” Rule Until July 14

DLA Piper on

The Federal Trade Commission (FTC) announced on May 9, 2025 that it will delay full implementation of the amended Negative Option Rule and begin enforcing it on July 14, 2025....more

Kelley Drye & Warren LLP

FTC Extends Compliance Deadline for Negative Option or ​“Click to Cancel” Rule, but Indicates Intent to Enforce as Written in July

Late Friday, the FTC announced that the Commission had voted 3-0 to extend the compliance deadline for the to-be-effective provisions of the Negative Option Rule, formerly known as the ​“Click to Cancel Rule.” While the...more

Latham & Watkins LLP

FTC’s Click-to-Cancel Rule to Take Effect on May 14, 2025, Despite Litigation

Latham & Watkins LLP on

Companies with B2C or B2B recurring payment programs that include negative option terms should review their disclosure, consent, and cancellation practices to ensure compliance with the rule....more

Venable LLP

Are Hyperlinked Disclosures "Clear and Conspicuous"? Yes, in some cases, according to the FTC's Final Negative Option Rule - A...

Venable LLP on

The Federal Trade Commission's Final Negative Option Rule ("Click to Cancel Rule") contains stringent new requirements for negative option programs, making it even more difficult to run compliant negative option offers....more

Kelley Drye & Warren LLP

With Uncertainty Surrounding the FTC’s Negative Option Rule, New California Requirements Wait in the Wings

Kelley Drye & Warren LLP on

Last Friday, the FTC’s final Negative Option Rule was published in the Federal Register, starting the clock on the effective dates for the agency’s expansive overhaul of requirements related to goods or services sold through...more

Lathrop GPM

New Click-To-Cancel FTC Rule Carries New Rules, Hefty Penalties for Violations

Lathrop GPM on

Attention, any companies that sell direct to consumers: the FTC has announced a new final rule requiring businesses to make it easier for consumers to opt-out and cancel subscriptions. Businesses will have 180 days to comply...more

ArentFox Schiff

Click to Cancel – FTC Amends Negative Option Rule

ArentFox Schiff on

In an October 16, 2024, press release, the Federal Trade Commission (FTC) announced its final Negative Option Rule, requiring businesses to make it as easy for consumers to cancel their enrollment in recurring subscriptions...more

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