"Junk Fee" Legislative Roundup – 2025 Edition

2024 was an action-packed year for followers of federal and state laws and regulations governing the disclosure of fees, or so-called “junk fee” laws. In the waning days of the Biden administration, the FTC released a significantly narrowed version of its initial proposed rule that would apply exclusively to the sale of live-event tickets and short-term lodging, as we summarized  here.

As we wait to see whether the FTC rule will ultimately take effect, attention has shifted to state enforcement of “hidden fees” – an area that has long garnered attention of state regulators. As we  previously reported, California and Minnesota both adopted broadly applicable “hidden fee” statutes that have now gone into effect. While both laws generally require price ads to include mandatory fees and charges (excluding taxes and fees imposed by the government), there are important nuances and distinctions between the two laws, so we are monitoring closely to see how they will be