FTC Final Click-to-Cancel Rule: Implications for Subscription Contracts, Autorenewals, and Other Negative Option Offers

Partner Paul Singer will present FTC Final Click-to-Cancel Rule: Implications for Subscription Contracts, Autorenewals, and Other Negative Option Offers in a recorded webinar for Strafford.

On Oct. 16, 2024, the FTC finalized its Click-to-Cancel rule, which imposes a variety of requirements on sellers of goods or services with a so-called ​“negative option” feature under which the seller interprets a customer’s silence or failure to affirmatively take action to cancel as acceptance of the offer. If upheld, the rule will significantly impact the sign-up and cancellation procedures for subscription services.

The new rule requires businesses to offer a cancellation mechanism that is as easy to use as the method the consumer used to subscribe. Businesses must also provide clear and conspicuous disclosures about the terms of the subscription, including how to find the cancellation mechanism, and obtain express informed consent from consumers before charging them.

Violations of the Click-to-Cancel rule can have significant consequences, including consumer redress and civil monetary penalties of more than $50,000 per violation. Companies that offer subscription-based services and contracts should review their current practices and procedures for compliance.

An expert panel will delve into the details of the FTC’s final Click-to-Cancel rule, its implications for businesses, and practical steps for compliance.

Register here.