FTC "Click-To-Cancel" Rule Goes Into Effect May 14

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 disclosure, informed consent, simple cancellation, and more.
• The rule joins a number of state laws targeted at deceptive and unfair subscription practices.

On May 14, 2025, the bulk of the requirements of the Federal Trade Commission's (FTC) Negative Option Rule, also known as the "click-to-cancel" rule, goes into effect. (The rule's prohibition on material misrepresentations went into force earlier in the year, on January 14.) The rule affects businesses offering "negative option features"—including free-to-pay trials and recurring subscriptions—and can trigger civil penalties of up to $53,088 per violation. Unlike many state laws on automatically renewing subscriptions, the rule applies to both business-to-consumer and