The FTC's Click-to-Cancel Rule: What You Need to Know

Please join attorneys from Holland & Knight's Consumer Protection Defense and Compliance Team for a timely discussion on the evolving landscape of subscription and recurring payment regulation, including the latest developments impacting the Federal Trade Commission's (FTC) Click-to-Cancel Rule.

Following the U.S. Court of Appeals for the Eighth Circuit's decision on July 9, 2025, the FTC's Click-to-Cancel Rule will not be enforced at this time. However, compliance remains a critical concern for businesses offering auto-renewing subscriptions, as other state and federal laws and enforcement mechanisms still pose significant risk.

During this webinar, attorneys Brian Goodrich and Benjamin Genn will provide valuable insights into where things stand now and what businesses need to do next.

Topics will include:

• the impact of the Eighth Circuit's ruling and what it means for the future of the Click-to-Cancel Rule
• the FTC's ongoing lawsuit against Uber for alleged violations of the FTC Act through "deceptive" auto-renewal practices, as well as its implications for federal and state governmental enforcement
• a discussion regarding the current regulatory landscape, including California's updated auto-renewal law (effective July 1) that applies to consumer sales
• key requirements of other applicable laws, such as the Restore Online Shoppers' Confidence Act (ROSCA), the Telemarketing Sales Rule (TSR), and state-specific auto-renewal and unfair, deceptive or abusive acts or practices (UDAAP) laws
• how to audit and update subscription practices to mitigate risk presented by governmental enforcement, as well as class actions and private litigation
• why voluntary compliance with the Click-to-Cancel Rule may help mitigate risk or present the path of least resistance for national brands
• practical steps and best practices for navigating this shifting compliance environment

We hope you can join us for this highly informative and timely discussion.

Continuing Legal Education (CLE)

Please note: After the completion of the program, Holland & Knight will apply for CLE credit in the following jurisdictions based on attendee requests: California, Colorado, Florida, Georgia, Illinois, Iowa, Missouri, New Mexico, New York, North Carolina, Ohio, Oregon, Pennsylvania, Tennessee, Texas, Utah, Vermont, Virginia and Washington. Some programs may not be awarded CLE credits because of content or jurisdictional restrictions. Please be aware that the CLE approval process can be lengthy in some jurisdictions.

Holland & Knight is an approved CLE provider in several jurisdictions, including California, Illinois, New York, Pennsylvania and Texas. For New York attorneys, this program's format qualifies for CLE for transitional (newly admitted) and experienced attorneys. General Certificates of Attendance will be provided upon request for states where applications are not submitted.