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ARTICLE · 29 SEPTEMBER 2025

FTC Steps Up Subscription Enforcement After "Click To Cancel" Rule Struck Down

Holland & Knight
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Recent lawsuits and settlements with the Federal Trade Commission (FTC) have prompted new compliance requirements for brands that offer auto-renewing products and services.

United StatesConsumer Protection
Brian Goodrich
Brian Goodrich
Benjamin Genn
Benjamin Genn
Ceijenia J. Cornelius
Ceijenia J. Cornelius
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Highlights

  • Recent lawsuits and settlements with the Federal Trade Commission (FTC) have prompted new compliance requirements for brands that offer auto-renewing products and services.
  • Even though the FTC's "Click to Cancel" Rule was voided by the U.S. Court of Appeals for the Eighth Circuit, FTC leadership is reinforcing expectations for companies to provide clear disclosures about auto-renewal terms and offer simple cancellation mechanisms.
  • This Holland & Knight alert details how the FTC's recent enforcement actions have led to a compliance road map of the FTC's expectations for businesses offering auto-renewing products or services.

Despite the demise of the Federal Trade Commission's (FTC) "Click to Cancel" Rule in July 2025, the FTC continues to actively define new standards for lawful subscription practices. The FTC's recent lawsuits and settlements with Match.com, Chegg Inc. and Cleo AI establish new compliance requirements – and create new

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