News & Analysis as of

Disclosure Requirements Subscription Services

Partridge Snow & Hahn LLP

New Massachusetts Fee Disclosure Rules Impose Substantial Penalties for Non-Compliance

Effective September 2, 2025, Massachusetts will begin enforcing 940 CMR 38.00, a new regulation aimed at promoting price transparency for consumers. These comprehensive rules apply to the sale or lease of goods and services...more

Kelley Drye & Warren LLP

HelloFresh to Pay $7.5 Million to Settle Automatic Renewal Suit

Last month, HelloFresh agreed to settle an investigation by the California Automatic Renewal Task Force (“CART”) made up of several California counties and cities. CART’s lawsuit, filed contemporaneously with its agreed...more

Miller Canfield

Michigan Reintroduces Automatic Renewal Law

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Michigan may be joining a growing number of states in tightening regulations around automatic renewal provisions in consumer contracts. On August 27, 2025, the Michigan House introduced HB 4826, a bill aimed at strengthening...more

Troutman Pepper Locke

Massachusetts AG Campbell Releases Business Guidance on “Junk Fee” and Auto-Renewal Regulations

Troutman Pepper Locke on

Massachusetts Attorney General (AG) Andrea Joy Campbell has issued guidelines to help businesses comply with the recently enacted consumer protection regulations, prohibiting “junk fees” and providing consumers with greater...more

Loeb & Loeb LLP

Match Group’s $14 Million Lesson: Even Without “Click-to-Cancel,” Subscription Companies Can’t Play Hard to Get

Loeb & Loeb LLP on

Last week, Match Group Inc., the powerhouse behind Match.com, OkCupid, Plenty of Fish and The League, agreed to shell out $14 million and revamp its cancellation policies, ending a nearly six-year showdown with the Federal...more

Cozen O'Connor

FTC and Match Strike $14M Deal over Alleged Deceptive Practices

Cozen O'Connor on

The FTC has reached a settlement with Match Group, Inc. and Match Group, LLC (collectively, “Match”)—the owners and operators of online dating services Match.com, OkCupid, PlentyofFish, The League, and other dating sites—to...more

Kelley Drye & Warren LLP

Massachusetts Provides Clarifications on Upcoming ​“Junk Fee” and Negative Option Regulations

Last week, the Massachusetts Attorney General’s office released a webinar and business guidance to help companies comply with upcoming regulations on junk fees and negative option contracts. The webinar and guidance cover a...more

Hinch Newman LLP

Massachusetts Releases Junk Fee Business Compliance Guidance

Hinch Newman LLP on

On July 29, 2025 the Massachusetts Attorney General released updated business guidance on the new "junk fee" rules. Business must comply by September 2, 2025. The updated guidance and webinar is designed to help businesses...more

Lowenstein Sandler LLP

FTC Click-to-Cancel Rule on Hold, but California’s Automatic Renewal Law Remains Intact: What Companies Need To Know

Lowenstein Sandler LLP on

On July 8, the Eighth U.S. Circuit Court of Appeals vacated the Federal Trade Commission’s (FTC) "click-to-cancel" rule (FTC Rule), which would have required companies to provide customers with an easy, one-click method to...more

Wiley Rein LLP

With “Click-to-Cancel” Rule Now Vacated by 8th Circuit, What’s Next for FTC?

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The U.S. Court of Appeals for the Eighth Circuit on July 2 issued a decision vacating the Federal Trade Commission’s (FTC) revised Negative Option Rule, which the previous Administration called the “Click to Cancel” Rule....more

Proskauer - Advertising Law

Canceled Before It Clicked: Eighth Circuit Strikes Down FTC’s Click-to-Cancel Rule

Just days before it was set to take effect, the U.S. Court of Appeals for the Eighth Circuit struck down the Federal Trade Commission’s (FTC) much anticipated “Click-to-Cancel Rule” (the “Rule”), delivering regulatory...more

Fisher Phillips

Court Strikes Down FTC’s Click-to-Cancel Rule – But Businesses Still Face Major Risk from State Auto-Renewal Laws

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A federal appeals court just vacated the FTC’s controversial Click-to-Cancel rule on procedural grounds – but businesses shouldn’t drop their guard just yet. Many states already have their own automatic renewal laws on the...more

Benesch

Eighth Circuit Cancels FTC’s “Click-to-Cancel” Rule

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On July 8, the United States Court of Appeals for the Eighth Circuit vacated the Federal Trade Commission’s Negative Option Rule, also referred to as the “Click-to-Cancel” rule (the “Rule”), determining that the FTC...more

Kelley Drye & Warren LLP

Ad Law News and Views - June 2025

In our most recent ​“Junk Fee” Legislative Roundup, we noted that the Connecticut legislature had introduced a bill that could require companies to include mandatory fees in their prices. On June 10, 2025, Connecticut’s...more

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

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

Miller Canfield

FTC's 'Click-to-Cancel' Rule Battles Through Political Shifts and Legal Challenges

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The Federal Trade Commission’s (“FTC”) Negative Option Rule, dubbed the “Click-to-Cancel” Rule (the “Rule”), stands to substantially change the way online businesses must interact with customers. Its fate is now in the hands...more

Proskauer - Advertising Law

Subscription Shake-Up: Navigating the FTC’s Click-to-Cancel Rule

In October 2024, the Federal Trade Commission (“FTC”) updated its 1973 Negative Option Rule to address unfair and deceptive online subscription practices. See 16 C.F.R. § 425 (2024) (the “Negative Option Rule” or the “Rule”)....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

Robinson Bradshaw

Cancel Culture, FTC Style: What Subscription-Based Businesses Need to Know about the FTC’s New “Click-to-Cancel” Rule

Robinson Bradshaw on

Last fall, the FTC published the Rule Concerning Recurring Subscriptions and Other Negative Option Programs, or the “Click-to-Cancel Rule.” The Rule targets practices where cancellation is intentionally more difficult than...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

Connecticut Enacts New Law Strengthening Consumer Protections

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The Connecticut legislature has passed a sweeping new consumer protection law addressing hidden fees, subscription practices, electronic privacy, price gouging, and right-to-repair requirements, among other things....more

Cozen O'Connor

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

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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

Mintz - Privacy & Cybersecurity Viewpoints

New York is Protecting its Consumers, One Budget at a Time

New York Governor Kathy Hochul has spoken: New York consumers need more information, more protections, and more money in their pockets. As part of the Transportation, Economic Development and Environmental conservation...more

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