Service Focus Area

Subscriptions & Negative Option Compliance

The FTC's updated rules for subscriptions, auto-renewals, and cancellation processes set a higher bar for compliance. We help you meet it.

Why this matters for your business

If you bill customers on a recurring basis — whether through memberships, subscriptions, auto-renewals, or free-trial-to-paid conversions — the FTC's negative option rules apply to you. The FTC has made subscription compliance a major enforcement priority, and the rules require clear disclosures, informed consent, and simple cancellation.

Businesses that don't comply face significant enforcement risk, including civil penalties, refund orders, and injunctions that disrupt the way they operate.

What the FTC requires

Clear and conspicuous disclosure of all material terms before billing
Affirmative, informed consent before charging — not pre-checked boxes
A cancellation mechanism that is at least as easy as the sign-up process
No unnecessary retention steps or dark patterns in cancellation flows
Pre-renewal reminders for certain types of offers
Accurate representations about trial terms and pricing

Common issues we find

Trial-to-paid transitions without adequate disclosure of recurring charges
Cancellation processes that are harder than sign-up
Material terms buried in fine print or separate pages
Retention flows that create unnecessary barriers
Missing or unclear renewal reminders
Consent mechanisms that don't meet the informed consent standard

How we help

We review your entire subscription lifecycle — from how you present offers and capture consent to how you handle renewals and cancellations. Our recommendations cover the specific changes needed to align with the FTC's current requirements.

For businesses with complex billing models (tiered plans, annual vs. monthly, bundled offers), we address each billing pathway individually.

Running subscriptions, memberships, or auto-renewals?

The FTC's requirements are specific. Let's make sure you're meeting them.