Topic
Automatic Renewal
103 published works
Taft Class Action & Consumer Insights
FTC’s Negative Option Rule Revived – Public Comment Period
The Federal Trade Commission (FTC) is once again taking aim at its Negative Option Rule, signaling a renewed effort to address deceptive subscription and automatic renewal practices. On March 11,…
Regulatory Oversight
FTC Revives Negative Option Rulemaking
By Clayton Friedman, Michael Yaghi, Zoe Schloss, Namrata Kang
On March 11, 2026, the Federal Trade Commission (FTC) issued an advance notice of proposed rulemaking (ANPRM) on negative option marketing. The ANPRM restarts the agency’s effort to regulate subscriptions…
Olshan Advertising Law Blog
Federal Regulatory Update on Automatic Renewal Requirements
By Andrew B. Lustigman, Morgan E. Spina
Compliance with complex and sometimes inconsistent federal and state legal requirements for automatic renewal/continuity programs continues to present challenges to marketers. On the federal side, the applicable legal standards continue…
Inside Consumer Protection
FTC Negative Option Rule ANPRM
By Laura Kim, Jehan Patterson, Alexandra Remick, Carter McCants
On March 11, 2026, the Federal Trade Commission (“FTC” or “the Commission”) announced an Advanced Notice of Proposed Rulemaking (“ANPRM”) regarding its Rule Concerning the Use of Prenotification Negative Option Plans, commonly known as…
Inside Consumer Protection
FTC Restarts Negative Option Rulemaking Process
By Terrell McSweeny, Laura Kim, Carter McCants
The Federal Trade Commission (FTC) is poised to re-start a rulemaking process regarding disclosures and requirements for subscription and auto-renewing products and services. On January 30, 2026, the FTC submitted…
Global Policy Watch
States Press Forward with Automatic Renewal Laws Amidst Vacating of the FTC’s Negative Option Rule
By Laura Kim, Andrew Siegel, Alexandra Remick, Munseong Park
Autorenewal regulation has been a recent focus of both federal and state regulators. The U.S. Court of Appeals for the Eighth Circuit recently vacated the FTC’s Negative Option Rule on…
Inside Consumer Protection
States Press Forward with Automatic Renewal Laws Amidst Vacating of the FTC’s Negative Option Rule
By Laura Kim, Andrew Siegel, Alexandra Remick, Munseong Park
Autorenewal regulation has been a recent focus of both federal and state regulators. The U.S. Court of Appeals for the Eighth Circuit recently vacated the FTC’s Negative Option Rule on procedural…
Inside Privacy
States Press Forward with Automatic Renewal Laws Amidst Vacating of the FTC’s Negative Option Rule
By Laura Kim, Andrew Siegel, Alexandra Remick, Munseong Park
Autorenewal regulation has been a recent focus of both federal and state regulators. The U.S. Court of Appeals for the Eighth Circuit recently vacated the FTC’s Negative Option Rule on…
Paytech & Payment Systems Insights
Eighth Circuit Vacates FTC Negative Option Rule: What’s Next for Automatic Renewal Compliance?
The Eighth Circuit’s recent decision to vacate the Federal Trade Commission’s (FTC) new Negative Option Rule (commonly referred to as the “Click-to-Cancel” Rule) has created significant uncertainty for businesses in…
Consumer Finance and Fintech Blog
California’s “Auto Renewal Law” Takes Effect on July 1
By A.J. Dhaliwal, Mehul Madia, Beineng Zhang
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…