FTC Extends Enforcement of “Click-to-Cancel” Rule to July 14

The Federal Trade Commission (FTC) has postponed enforcement of its updated Negative Option Rule, including the “Click-to-Cancel” requirement, to July 14, 2025. This change follows the Commission’s acknowledgment that the original May timeline underestimated the complexity of compliance for businesses.

The rule targets negative option programs, such as subscriptions that automatically renew unless the consumer cancels. Under the updated rule, businesses must:

• Clearly disclose all material terms before initiating charges,

• Obtain express, informed consent to recurring payments,

• Offer cancellation methods that are as simple as the sign-up process, especially online,

• Retain customer consent records for at least three years.

The FTC also noted it remains open to revising the rule if enforcement reveals unforeseen issues.

Law firm Mac Murray and Shuster LLP recommends that, “Companies ensure that their disclosure, consent, and cancellation mechanisms are up to par in advance of July 14. It’s also a good time to review and fine tune automatic renewal processes to comply with state automatic renewal laws.”

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