News & Analysis as of

Disclosure Requirements Contract Terms Subscription Services

Perkins Coie

New York and Colorado Update Auto-Renewing Subscription Requirements

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Recent enforcement actions underscore the growing risks for businesses with automatically renewing subscriptions. In June 2025, New York Attorney General Letitia James announced a $600,000 settlement with fitness company...more

BakerHostetler

Automatic Renewal Law Updates - Massachusetts, New York and Connecticut

BakerHostetler on

Companies selling subscriptions have been busy navigating compliance with the Federal Trade Commission’s Negative Option Rule, which is scheduled to go into effect July 14. But when it rains, it pours....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

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

Cozen O'Connor

NY Settles with Equinox for Allegedly Making Consumers Sweat over Negative Option Plans

Cozen O'Connor on

New York AG Letitia James entered into a settlement with Equinox Group, LLC (Equinox Group), which operates fitness services under Equinox, Equinox+, and SoulCycle, resolving allegations that its subscription and cancellation...more

Lewitt Hackman

Service Franchisors: New Rules in California for Automatic Renewals July 1st

Lewitt Hackman on

From streaming services and gym memberships to software vendor agreements and e-commerce franchises, automatic contract renewals are common occurrences. Currently, California law protects consumers regarding automatic renewal...more

Winstead PC

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

Winstead PC on

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

Womble Bond Dickinson on

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

Alston & Bird

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

Alston & Bird on

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

Venable LLP

Your 2024 Outlook: California’s Enforcement Trends and New State Laws Governing Automatic Renewal Programs

Venable LLP on

It’s that time of year again. Regardless of what you call them—subscriptions, negative option programs, automatic renewals, or continuous service offers—states are continuing to enact and enforce new laws with increasingly...more

Akerman LLP

Amendments to California’s Automatic Renewal Law Take Effect

Akerman LLP on

Amendments to California’s automatic renewal law (ARL) enacted in October 2021 go into effect today, July 1, 2022. The amendments add enhanced procedural requirements related to the cancellation of subscription-based products...more

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