News & Analysis as of

Cancellation Rights Consumer Contracts

K&L Gates LLP

Unreasonable Manipulation, Unreasonable Distortion (Dark Patterns) to be Banned – Stronger Protections Regarding Subscriptions and...

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As it had foreshadowed, the Australian Government has released an exposure draft of the Competition and Consumer Amendment (Unfair Trading Practices) Bill 2026 (Bill).  The Bill seeks to introduce a general prohibition on...more

Stikeman Elliott LLP

Québec’s Bill 10: Protecting Consumers Against Abusive Practices in Ticket Resales and Online Subscription Renewals

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In keeping with its recent renewed interest in establishing robust protections for consumers within the province, the government of Québec tabled a new bill on December 2, 2025 amending the Québec Consumer Protection Act...more

Hudson Cook, LLP

California Enacts the Combating Auto Retail Scams (CARS) Act

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On October 6, California Governor Gavin Newsom signed Senate Bill 766—the California Combating Auto Retail Scams (CARS) Act—which purports to help make the car-buying process more transparent and strengthen consumer...more

Kelley Drye & Warren LLP

34 State AGs Settle UDAP Autorenewal Allegations Against ​“JustFab” Subscriptions

Last month, a group of 34 state attorneys general—led by D.C, Maryland, Pennsylvania, and Texas—settled with TFG Holdings, a company known for brands such as JustFab and Shoedazzle, concerning its subscription practices. The...more

Holland & Knight LLP

Podcast - The Digital Marketplace: The FTC's Focus on Fair Online Transactions

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In this episode of "Clearly Conspicuous," consumer protection attorney Anthony DiResta provides an update on Federal Trade Commission (FTC) actions in the digital commerce space. Mr. DiResta discusses the FTC's core concerns...more

Hudson Cook, LLP

Keeping Your Eye on the Ball: Federal Cancellation Policy Settlements and New York Updates to Auto Renewal Law

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While much focus has recently been paid to the Massachusetts Attorney General's "junk fee" regulation, which includes newly effective negative option requirements, focus on automatic renewal cancellation policies remains a...more

Wiley Rein LLP

FTC Consumer Protection and Privacy Enforcement Series: Subscription Cancellation Policies Remain a Top FTC Priority

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When the FTC’s “Click to Cancel” Rule (otherwise known as the revised Negative Option Rule), was in litigation in July 2025, we predicted the FTC was likely to instead focus on enforcing the Restore Online Shoppers Confidence...more

Cozen O'Connor

FTC Sues LA Fitness to Cancel Unfair Membership Cancellation Practices

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The FTC has sued Fitness International, LLC and Fitness & Sports Clubs, LLC—the operators of “LA Fitness”—alleging that the gyms have made it extremely difficult for consumers to cancel memberships and recurring charges in...more

Pillsbury - Internet & Social Media Law Blog

New EU Rule Requires Easy “Cancel Contract” Button for Online Sales

A recent update to EU consumer law will require many businesses selling online to offer a simpler, more accessible way for customers to cancel contracts within the standard 14-day cooling-off period....more

Mintz

Click to Cancel: What the FTC’s Setback Means for Subscription-Based Businesses

Mintz on

I had a thought-provoking conversation this week with an in-house counsel about the now-vacated FTC “Click to Cancel” rule—a regulation that was set to take effect July 14 and could have reshaped how companies manage...more

Kohrman Jackson & Krantz LLP

Avoiding Legal Pitfalls: Understanding Ohio’s Home Solicitation Sales Act

Are you a contractor who sells services directly to customers at their homes or outside your ordinary place of business? If so, do you know about Ohio’s Home Solicitation Sales Act? Understanding this law is crucial, and if...more

Venable LLP

Subscription Sellers Take Note: New Tariffs Could Hit You Hard and Require You to Notify Customers

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Every company will be impacted by the new import tariffs, as they increase manufacturing costs. However, companies selling on an autorenewal basis could disproportionately feel the impact and should proceed with caution...more

K&L Gates LLP

Key Changes to Consumer Protection Laws and Subscription Contracts in the United Kingdom That You Need to Know

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The landscape of subscription contracts is changing around the world, with a heavy focus on consumer protection. In the United States, the recently released "Rule Concerning Recurring Subscriptions and Other Negative Option...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

Cooley LLP

Government Reveals New Proposals for Incoming Subscription Contracts Regime Under DMCC Act

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In our last update on the Digital Markets Competition and Consumer Act (DMCC Act), we outlined some of the key consumer protection enhancements set to come into force in the UK. In particular, the DMCC Act sets out new rules...more

Ballard Spahr LLP

Consumer Finance Monitor Podcast Episode: A Look at the FTC’s Click-to-Cancel Rule, with James Kohm, Associate Director of...

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Today’s podcast features James Kohm, the Associate Director for the Enforcement Division of the Federal Trade Commission’s Bureau of Consumer Protection. We discuss the FTC’s “Click-to-Cancel” Rule (consisting of significant...more

Sheppard

Renewal Revolution: Compliance With FTC’s “Click to Cancel” Rule

Sheppard on

On October 16, 2024, the Federal Trade Commission (FTC) issued a new rule, referred to as the “Click to Cancel” rule, which is intended to make it easier for consumers to cancel recurring subscriptions and memberships....more

Kelley Drye & Warren LLP

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

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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

BCLP

Are You Preparing to Comply with the FTC “Click-to-Cancel” Rule?

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The Federal Trade Commission (FTC) published its final “Click-to-Cancel” Rule in the Federal Register on November 15, 2024, meaning that companies should ensure that they comply with the rule’s requirements within the next...more

Womble Bond Dickinson

New Click-to-Cancel Requirements… Welcome/Not Welcome?

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The Federal Trade Commission (FTC) announced its long-awaited final Negative Option Rule (the “Rule”) on October 16, 2024. “Negative Options” according to the FTC are arrangements “under which the consumer’s silence or...more

DLA Piper

Preparing for (More) Updates to California’s Automatic Renewal Law

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California has passed additional amendments to its Automatic Renewal Law (ARL), which will further strengthen that law’s already stringent requirements and likely present increased class action risk....more

Bass, Berry & Sims PLC

FTC Releases “Click to Cancel” Rule

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On October 16, the Federal Trade Commission (FTC) released the final version of its Rule Concerning Recurring Subscriptions and Other Negative Option Programs (Rule), which requires sellers of products and services to receive...more

Perkins Coie

FTC Finalizes “Click To Cancel” Rule With Substantial Requirements for Recurring Subscription Programs

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The Federal Trade Commission (FTC) announced its final Negative Option Rule (the Rule)—which the FTC often refers to as the “Click to Cancel” rule—for automatically renewing subscriptions, free trials that convert to paid...more

Lathrop GPM

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

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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

Holland & Knight LLP

The New Cancel Culture: The FTC's "Click to Cancel" Rule

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The Federal Trade Commission (FTC) has made several amendments to the prior Negative Option Rule (Rule) that alter how subscription- and membership-based businesses will need to operate. This Holland & Knight alert summarizes...more

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