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Subscription Services Automatic Renewals Cancellation Rights

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

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

Alston & Bird

Cancellation Practices Back in the Spotlight as Click-to-Cancel Rule Looms

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Our Consumer Protection/FTC Group investigates the implications of a Federal Trade Commission complaint against Uber alleging deceptive billing and cancellation practices under the Restore Online Shoppers’ Confidence Act...more

Wilson Sonsini Goodrich & Rosati

FTC Files Consumer Protection Complaint Against Uber for Deceptive Billing and Cancellation Practices

On April 21, 2025, the Federal Trade Commission (FTC) announced that it had filed a complaint against Uber Technologies, Inc. and Uber USA LLC (collectively, Uber), a rideshare and delivery company. Among other things, the...more

Venable LLP

FTC Makes Clear It Will Continue Regulating Subscription Services and Signals Enforcement Priority for Negative Option Rule in...

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This week, the Federal Trade Commission (FTC) filed a lawsuit in federal court against rideshare and delivery company Uber for allegedly deceptive subscription practices, including making it unreasonably difficult to cancel....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

Venable LLP

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

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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 Mullin Richter & Hampton LLP

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

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

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

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

ArentFox Schiff

Click to Cancel – FTC Amends Negative Option Rule

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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

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

Katten Muchin Rosenman LLP

Cancel Culture - Kattison Avenue | Issue 13

The FTC's new rule makes it easier for consumers to cancel subscriptions and memberships they no longer want. The Federal Trade Commission (FTC) introduced a "click-to-cancel" rule on October 16, amending the 1973...more

Venable LLP

The Massive Change in FTC's "Click to Cancel" Rule and California's Updated Law That Nobody Is Discussing: A Fast VAST Update

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Many alerts and articles discussing the Federal Trade Commission's (FTC) updated Negative Option Rule and the Amendments to California's Automatic Renewal law have focused on the stricter consent and cancellation...more

Kilpatrick

The FTC takes a new swipe at autorenewal programs

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Use of California’s Auto Renewal Law as a predicate for UCL, FAL or CLRA claims has been a hotbed of consumer class action litigation. Now, the FTC has added a federal arrow to the consumer protection quiver by expanding its...more

Lerman Senter PLLC

What the FTC's Click to Cancel Rule Means for Subscription Services

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Subscription-based services are a lynchpin of the services industry and the current focus of the Federal Trade Commission’s (FTC) new “click to cancel” rule. Responding to customer complaints focusing on the difficulty of...more

Hinch Newman LLP

California Expands “Dark Pattern” Automatic Renewal Legislation

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On October 16, 2024, the Federal Trade Commission announced the final FTC “Click-to-Cancel” Rule pertaining to recurring subscriptions and memberships. The Federal Trade Commission is not the only regulatory agency that...more

Brownstein Hyatt Farber Schreck

FTC Finalizes “Click-to-Cancel” Rule Making It Easier for Consumers to Cancel Subscriptions

On Oct. 16, the Federal Trade Commission (FTC) voted 3-2 to finalize its “click-to-cancel” rule that will introduce new requirements to simplify the cancellation process for consumers wishing to terminate their subscriptions...more

Troutman Pepper Locke

FTC Adopts “Click-to-Cancel” Amendments to Its Negative Option Rule

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On October 16, the Federal Trade Commission announced final “click-to-cancel” amendments to its Negative Option Rule. Under the FTC’s amended Negative Option Rule...more

Morgan Lewis

FTC ‘Click-to-Cancel’ Rule Requires Canceling Recurring Charges to Be as Easy as Signing Up

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The Federal Trade Commission (FTC) recently issued its Final Rule requiring businesses subject to its authority to establish equivalency between the ease of signing up and canceling subscriptions, memberships, and other...more

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