News & Analysis as of

Cancellation Rights

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

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

Holland & Knight LLP

FTC Signals Enforcement on Auto-Renewing Subscriptions and Sales

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In January 2025, prior to President Donald Trump's inauguration, the Federal Trade Commission (FTC) finalized its Click to Cancel Rule (Rule). This regulation requires additional disclosures, consents and simple cancellation...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

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

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

Negative Option and Continuity Marketing

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The Federal Trade Commission, state attorneys general, and class action plaintiffs continue to scrutinize negative option and continuity offers, including automatic renewals, free-to-pay conversions, and continuity programs....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

DLA Piper

German Higher Courts Clarify Strict Requirements for Online Contract Cancellations

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In two recent decisions, the German Higher Regional Courts (Oberlandesgerichte – OLG) of Cologne and Munich have clarified the – strict – German requirements for cancellation buttons on websites of tech companies providing...more

Lowenstein Sandler LLP

FTC "Click-To-Cancel" Rule Coming Soon

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The Federal Trade Commission’s final “click-to-cancel” rule, which goes into effect on May 14, 2025, attempts to address the difficulties consumers may face when trying to cancel an automatically renewing subscription. The...more

Venable LLP

FTC's "Click-to-Cancel" Rule Challenged by Industry in the Eighth Circuit

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Last week, a security services company and several trade groups filed their merits brief in the U.S. Court of Appeals for the Eighth Circuit challenging the Federal Trade Commission’s (FTC) newly adopted Negative Option Rule,...more

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