News & Analysis as of

State Attorneys General Subscription Services Automatic Renewals

Mintz

Click to Cancel: What the FTC’s Setback Means for Subscription-Based Businesses

Mintz on

I had a thought-provoking conversation this week with an in-house counsel about the now-vacated FTC “Click to Cancel” rule—a regulation that was set to take effect July 14 and could have reshaped how companies manage...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

Perkins Coie

New York and Colorado Update Auto-Renewing Subscription Requirements

Perkins Coie on

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

Venable LLP

Subscription Sellers Take Note: New Tariffs Could Hit You Hard and Require You to Notify Customers

Venable LLP on

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

Cozen O'Connor

New FTC Rule Makes Cancelling Negative Option Plans Easier

Cozen O'Connor on

The FTC has finalized a new “Click-to-Cancel” rule to protect consumers from unfair or deceptive practices when seeking to cancel their enrollment in subscription services, memberships, and other recurring-payment programs....more

Troutman Pepper Locke

Bipartisan State AGs Support FTC’s Amendments to Negative Option Rule

Troutman Pepper Locke on

The New York and Pennsylvania state attorneys general recently led a bipartisan coalition of 26 state AGs in a letter, supporting the Federal Trade Commission (FTC)’s proposed rule amending the Negative Option Rule....more

Orrick, Herrington & Sutcliffe LLP

26 state AGs support FTC’s proposal on Negative Option Rule

On June 26, a coalition of 26 state attorneys general from New York, Pennsylvania, Alabama, Arizona, California, Colorado, Connecticut, Delaware, District of Columbia, Hawaii, Illinois, Maine, Maryland, Massachusetts,...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

Kelley Drye & Warren LLP

Washington AG Signals Enforcement on Automatic Renewals

Kelley Drye & Warren LLP on

Earlier this week, we posted that a plaintiff filed a proposed class action against the NFL over its automatic renewal practices. The complaint alleges that the NFL used “dark patterns” to enroll consumers in its NFL+...more

Cozen O'Connor

The State AG Report - Volume 7, Issue 44

Cozen O'Connor on

Here are last week’s curated AG and federal regulatory news stories highlighting key areas in which state and federal regulators’ decisions are having an impact across the US: Republican Attorneys General Send Letter...more

Proskauer Rose LLP

New York’s Broad Automatic Renewal Law (and the Accompanying Compliance Issues) Coming in February 2021

Proskauer Rose LLP on

New York has enacted a new law, effective February 9, 2021, regulating automatic renewal and some “free trial” type agreements. While some organizations may have already taken steps to be in compliance with industry...more

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