Navigating the Enforcement and Regulatory Landscape of Recurring Subscription Practices

The Federal Trade Commission’s (FTC) amended Negative Option Rule, also known as the “Click to Cancel” Rule, is scheduled to take full effect on July 14, 2025. The rule introduces new compliance obligations for businesses selling goods or services with a negative option feature, including auto-renewals and continuity plans. The rule is part of the FTC’s broader effort to address alleged deceptive and unfair practices in the subscription space. This is also an area where a number of states have been active, including through the recent enactment of new or amended auto-renewal laws.

As enforcers continue to scrutinize subscription practices, join our upcoming webinar, where we will:

• Examine the key provisions of the FTC’s "Click to Cancel" Rule
• Highlight recent developments with auto-renewal laws at the state level
• Review recent FTC enforcement activity