News & Analysis as of

Cancellation Rights

Alston & Bird

FTC’s Click-to-Cancel Rule Vacated by Appeals Court

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Due to go into effect on July 14, the Negative Option Rule has been struck down by the Eighth Circuit. Our Consumer Protection/FTC Group examines the Federal Trade Commission’s options going forward....more

Nelson Mullins Riley & Scarborough LLP

Do NOT Cancel Your Click-to-Cancel Compliance Efforts!

As has been widely reported, the Eighth Circuit issued a decision this week vacating the Federal Trade Commission’s Click-to-Cancel Rule, which had been scheduled to spring into effect on July 14. In the grand scheme of...more

Fenwick & West LLP

Eighth Circuit Vacates FTC’s Click-To-Cancel Rule

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On Tuesday, July 8, the Eighth Circuit struck down the Federal Trade Commission’s new “click-to-cancel” rule just days before the FTC planned to begin enforcement on July 14, 2025. ...more

Winstead PC

8th Circuit Vacates FTC’s “Click to Cancel Rule”

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On July 8, 2025, the U.S. Court of Appeals for the Eighth Circuit vacated the Federal Trade Commission’s (“FTC”) Click to Cancel Rule (the “Rule”), which was previously scheduled to take effect on May 14, 2025, and later...more

BakerHostetler

Eighth Circuit Clicked to Cancel the FTC’s Negative Option Rule

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Yesterday, the Eighth Circuit vacated the Federal Trade Commission’s (FTC) Negative Option Rule (Click-to-Cancel Rule or Rule) that was set to go into effect on July 14....more

Womble Bond Dickinson

FTC’s Click to Cancel Rule is Vacated, But Remember It Was Not Alone

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What happened and why?  On July 8, 2025, a unanimous three-judge panel of the Eighth Circuit Court of Appeals vacated the updated version of the FTC’s Negative Option Rule (also known as the “click to cancel” rule) to have...more

Kelley Drye & Warren LLP

Eighth Circuit Vacates FTC’s Negative Option Rule

On the metaphorical eve of the July 14 effective date for the FTC’s Negative Option Rule, the Eighth Circuit released an opinion Tuesday vacating the Rule in its entirety. The economy-wide notice, consent, cancellation, and...more

Proskauer - Advertising Law

Subscription Shake-Up: Navigating the FTC’s Click-to-Cancel Rule

In October 2024, the Federal Trade Commission (“FTC”) updated its 1973 Negative Option Rule to address unfair and deceptive online subscription practices. See 16 C.F.R. § 425 (2024) (the “Negative Option Rule” or the “Rule”)....more

Kelley Drye & Warren LLP

NY Quietly Amends Automatic Renewal Law

On May 9, 2025, New York Governor Kathy Hochul signed a large budget bill with ​“major components of legislation necessary to implement the state transportation, economic development, and environmental conservation budget for...more

Hudson Cook, LLP

Consumer Financial Services Bites of the Month - May 2025 - "The CFPB in the End of May"

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In this month's article, we share some of our top "bites" covered during the May 2025 webinar....more

Sheppard Mullin Richter & Hampton LLP

California’s “Auto Renewal Law” Takes Effect on July 1

Amendments to California’s Automatic Renewal Law (ARL) will take effect on July 1, 2025. Enacted in September 2024 through Assembly Bill No. 2863, the amendments expand disclosure, consent, and cancellation obligations for...more

Arnall Golden Gregory LLP

State Wave of Click-to-Cancel Rules

The end of President Biden’s administration saw the Federal Trade Commission (“FTC”) adopt the sweeping “Click-to-Cancel” rule, which stands to impose a spate of requirements for disclosure, consent, and cancellation on any...more

Winstead PC

The Federal Trade Commission (FTC) Click-to-Cancel

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The Federal Trade Commission (“FTC”) has recently announced that the FTC’s Click to Cancel Rule (the “Rule”) has been postponed to July 14, 2025. Originally planned to become effective May 14, 2025, the Commission released...more

Womble Bond Dickinson

FTC Defers Some Click-to-Cancel Rule Enforcement to July 14, 2025

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Companies with recurring payment programs with negative option terms now have until July 14, 2025, to bring their disclosure, consent, and cancellation practices into full compliance....more

Fisher Phillips

FTC’s Click-to-Cancel Rule Delayed Amid Legal Challenges: What Businesses Need to Know

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Federal officials just postponed enforcement of the Click-to-Cancel rule, which requires businesses offering subscriptions or memberships to provide a cancellation process as straightforward as the sign-up procedure. The...more

Holland & Knight LLP

FTC Defers Negative Option Rule Compliance Deadline by 60 Days

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The Federal Trade Commission (FTC or Commission) on May 9, 2025, voted to defer the compliance deadline for the amended Negative Option Rule (Rule) by 60 days "given the complexities" of conforming to the amended Rule....more

Loeb & Loeb LLP

60 More Days for Click to Cancel

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Take a quick breath—but just a short one—because late Friday, the Federal Trade Commission (FTC) decided (3-0) to push the compliance date of its Negative Option (or "Click to Cancel") Rule, a regulation designed to make...more

Latham & Watkins LLP

FTC Delays Enforcement of Click-to-Cancel Rule Until July 14 2025

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Companies with B2C or B2B recurring payment programs that include negative option terms now have until July 14, 2025, to ensure their disclosure, consent, and cancellation practices are compliant with the Negative Option...more

Fenwick & West LLP

Two-Month Click-to-Cancel Rule Extension

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If you've been following the latest updates on the click-to-cancel rule, you might have heard about the recent extension granted by the Federal Trade Commission....more

Venable LLP

The FTC Defers Compliance Deadline for Updated Negative Option Rule to July 14 - A Fast VAST Update​​

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On Friday, ​the Federal Trade Commission voted to defer the compliance deadline for the amended Negative Option Rule by 60 days. The Commission issued a statement on the new deadline....more

Alston & Bird

FTC Delays Compliance Deadline for Click-to-Cancel Rule Until July 14, 2025

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Our Consumer Protection/FTC Team notes that the Federal Trade Commission extended the compliance deadline of the Negative Option Rule (better known as the Click-to-Cancel Rule) by 60 days....more

BakerHostetler

FTC Delays Enforcement of Negative Option Rule Until July 14

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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

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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

Perkins Coie

FTC “Click-To-Cancel” Rule Goes Into Effect May 14

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Key Takeaways - - Beginning May 14, businesses offering "negative option features" can incur significant financial penalties for each violation of the FTC’s “click-to-cancel” rule. - The rule imposes obligations related to...more

Wiley Rein LLP

Is Your Company Prepared for the FTC’s May 14 “Click-to-Cancel” Compliance Deadline?

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A May 14, 2025 deadline is rapidly approaching for companies to comply with several of the most significant changes to the Federal Trade Commission’s (FTC) amended negative option rule, often called the “click-to-cancel”...more

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