News & Analysis as of

Disclosure Requirements Automatic Renewals Consent

Miller Canfield

Eighth Circuit Slams the Brakes on FTC’s Click-to-Cancel Rule

Miller Canfield on

In a dramatic turn of events, the United States Court of Appeals for the Eighth Circuit has vacated the Federal Trade Commission’s (FTC) Click-to-Cancel Rule, which was set to take effect on July 14, 2025. ...more

Orrick, Herrington & Sutcliffe LLP

Navigating Federal and California Negative Option Rules: Key Insights for Businesses

As regulatory scrutiny around automatic renewals intensifies, understanding the Federal Trade Commission’s new “Click-to-Cancel” rule and California’s recently amended Automatic Renewal Law, is essential for companies looking...more

Nelson Mullins Riley & Scarborough LLP

Autorenewal Requirements Are Finally Coming Into Focus – What You Need to Know

As July prepares to descend upon us, the swirl regarding the impending legal requirements for properly offering and administering autorenewing subscriptions has become downright maddening – which rules will apply? How can I...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

Paul Hastings LLP

Updated California and FTC Auto-Renewal Regulations Take Effect

Paul Hastings LLP on

In the fall of 2024, California and the Federal Trade Commission (FTC) amended their respective auto-renewal regulations. The amendments detail new and largely parallel disclosure, consent, and cancellation requirements for...more

Morgan Lewis

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

Morgan Lewis on

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

Hinch Newman LLP

FTC Announces Final “Click-to-Cancel” Recurring Subscriptions and Memberships Rule

Hinch Newman LLP on

On October 16, 2024, the Federal Trade Commission announced a final “click-to-cancel” rule that will require sellers to make it as easy for consumers to cancel their enrollment as it was to sign-up. Most of the final rule’s...more

Foley & Lardner LLP

FTC Finalizes “Click-to-Cancel” Rule 18 October 2024

Foley & Lardner LLP on

The Federal Trade Commission (FTC) has finalized amendments to the Negative Option Rule, now retitled the “Rule Concerning Recurring Subscriptions and Other Negative Option Programs“ (“Rule”), which represents a significant...more

Venable LLP

Fast VAST Update: California Proposes Sweeping Changes to Autorenewal Law

Venable LLP on

Last week, California's legislature proposed amendments to its Automatic Renewal Law (ARL) to tighten the already-strict requirements for autorenewal, negative option, and continuous service offers. The law would impose new...more

Venable LLP

Ninth Circuit Upholds Dismissal of Autorenewal Lawsuit, Finds Disclosure, Consent, and Acknowledgment Sufficient

Venable LLP on

In January, the Ninth Circuit agreed with a California district court's finding that a software company's autorenewal practices did not violate California's autorenewal law. The decision reflects a win for companies offering...more

Venable LLP

Is Your New Year’s Resolution to Comply with Automatic Renewal Laws? If So, Look No Further

Venable LLP on

The law surrounding negative option and continuity programs continues to evolve rapidly. Feeling a bit overwhelmed with the latest developments? Below is what you need to know in light of new laws, new enforcement actions,...more

Venable LLP

Lawsuit Targets Technical Requirements in California's Autorenewal Law

Venable LLP on

​​​​​​​Autorenewal programs remain in the crosshairs for private class action plaintiffs, as evidenced by another lawsuit filed in California targeting numerous technical requirements in the state's automatic renewal law. ...more

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