Involved Parties: Primary agency is the FTC, enforcing under Section 5 of the FTC Act, the 1973 Negative Option Rule (prenotification plans), ROSCA (internet sales), and Telemarketing Sales Rule; court is the Eighth Circuit.[1][4][12] Affected include companies with subscription/auto-renewal models (e.g., Match.com, Chegg, Cleo AI, Amazon via recent FTC enforcement); public comments due April 13, 2026.[3][4][5]
Context and Timeline: FTC's 2024 "Click to Cancel" rule sought uniform standards (clear disclosures, express consent, easy cancellation) across channels but was vacated in 2025; fragmented laws persist (e.g., 1973 Rule limited scope).[1][2][8] ANPRM seeks input on retaining/amending the rule, readopting 2024 provisions, or alternatives amid ongoing consumer complaints and FTC enforcement (e.g., lawsuits for opaque terms, hard cancellations).[3][5][6] Process began with 2019 ANPRM; current ANPRM published March 13, 2026, in Federal Register.[8][12]
Newsworthy Now: With comments closing April 13, 2026 (two days away), subscription-heavy businesses face imminent input opportunity and risks of revived civil penalties; FTC signals persistence via post-vacatur enforcements and state laws (e.g., reminders in MA/CT/NY), heightening compliance urgency in digital economy.[3][4][13]