News & Analysis as of

Federal Trade Commission (FTC) Negative Option Rule Subscription Services

Wiley Rein LLP

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

Wiley Rein LLP on

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

Bass, Berry & Sims PLC

Eighth Circuit Vacates FTC’s Click-to-Cancel Rule

Bass, Berry & Sims PLC on

On July 8, the U.S. Court of Appeals for the Eighth Circuit issued a unanimous opinion in Custom Communications Inc. v. Federal Trade Commission that vacates the Federal Trade Commission’s (FTC) Rule Concerning Recurring...more

Troutman Pepper Locke

Eighth Circuit Vacates FTC’s Negative Option Rule for Procedural Violations

Troutman Pepper Locke on

On July 8, a panel for the U.S. Court of Appeals for the Eighth Circuit issued a significant decision in the case of Custom Communications, Inc. v. Federal Trade Commission (FTC). The panel vacated the FTC’s amended Negative...more

BakerHostetler

Eighth Circuit Clicked to Cancel the FTC’s Negative Option Rule

BakerHostetler on

Yesterday, the Eighth Circuit vacated the Federal Trade Commission’s (FTC) Negative Option Rule (Click-to-Cancel Rule or Rule) that was set to go into effect on July 14....more

Hudson Cook, LLP

Eighth Circuit Vacates FTC's Negative Option Rule

Hudson Cook, LLP on

On July 8, 2025, the Eighth Circuit issued an opinion that vacated the FTC's Negative Option Rule in its entirety. The FTC's compliance deadline for the Rule, which had been extended once, was set to go into effect on July...more

Womble Bond Dickinson

FTC’s Click to Cancel Rule is Vacated, But Remember It Was Not Alone

Womble Bond Dickinson on

What happened and why?  On July 8, 2025, a unanimous three-judge panel of the Eighth Circuit Court of Appeals vacated the updated version of the FTC’s Negative Option Rule (also known as the “click to cancel” rule) to have...more

Venable LLP

Eighth Circuit Cancels FTC Negative Option Rule: What Does It Mean?

Venable LLP on

The U.S. Court of Appeals for the Eighth Circuit vacated the Federal Trade Commission’s Rule Concerning Subscriptions and Other Negative Option Plans (often referred to as the “Click-to-Cancel” rule) on July 8, just days...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

Miller Canfield

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

Miller Canfield on

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

Lewitt Hackman

Service Franchisors: New Rules in California for Automatic Renewals July 1st

Lewitt Hackman on

From streaming services and gym memberships to software vendor agreements and e-commerce franchises, automatic contract renewals are common occurrences. Currently, California law protects consumers regarding automatic renewal...more

Winstead PC

The Federal Trade Commission (FTC) Click-to-Cancel

Winstead PC on

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

Womble Bond Dickinson on

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

Holland & Knight LLP

FTC Defers Negative Option Rule Compliance Deadline by 60 Days

Holland & Knight LLP on

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

Loeb & Loeb LLP on

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

Cooley LLP

FTC Delays Enforcement of Amended Negative Option Rule

Cooley LLP on

On May 9, the Federal Trade Commission (FTC) voted unanimously to delay enforcement of most portions of its amended Negative Option Rule (rule) by 60 days, shifting the compliance deadline for these portions from May 14 to...more

Latham & Watkins LLP

FTC Delays Enforcement of Click-to-Cancel Rule Until July 14 2025

Latham & Watkins LLP on

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

Venable LLP

The FTC Defers Compliance Deadline for Updated Negative Option Rule to July 14 - A Fast VAST Update​​

Venable LLP on

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

Alston & Bird on

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

BakerHostetler on

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

DLA Piper on

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

DLA Piper

FTC “Click-to-Cancel” Rule to Take Effect May 14

DLA Piper on

In October 2024, the Federal Trade Commission (FTC) finalized significant updates to the Negative Option Rule, which are slated to take effect on May 14, 2025. A negative option is a contract term under which a buyer agrees...more

Latham & Watkins LLP

FTC’s Click-to-Cancel Rule to Take Effect on May 14, 2025, Despite Litigation

Latham & Watkins LLP on

Companies with B2C or B2B recurring payment programs that include negative option terms should review their disclosure, consent, and cancellation practices to ensure compliance with the rule....more

Perkins Coie

FTC “Click-To-Cancel” Rule Goes Into Effect May 14

Perkins Coie on

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?

Wiley Rein LLP on

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

46 Results
 / 
View per page
Page: of 2

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
- hide
- hide