Last November, the Federal Trade Commission (FTC or Commission) published its final click-to-cancel rule (the Rule), which requires sellers to make it as easy for consumers to cancel their enrollment into a service or goods plan as it was to sign up. As we discussed previously, the Rule prohibits sellers from misrepresenting any material facts and requires them to provide clear and conspicuous disclosures of material terms before obtaining billing information and charging consumers. Sellers must also obtain informed consent to a negative option feature (i.e., consumer silence or inaction construed as continuing acceptance) prior to charging consumers. The three sitting FTC commissioners – all Republicans – have now voted to extend the compliance deadline to July 14, 2025.
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