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FTC Seeks Public Comment on Advance Notice of Proposed Rulemaking for Negative Option Marketing Practices

NoneMarch 11, 2026Federal Trade Commission

Summary

The FTC is seeking public comment on an Advance Notice of Proposed Rulemaking (ANPRM) to amend the Negative Option Rule, which governs prenotification negative option marketing plans. The rulemaking aims to address deceptive or unfair practices including misleading disclosures, unauthorized billing, and difficult cancellation processes, following over 100,000 consumer complaints about negative option practices in the past five years. Comments will be accepted for 30 days after the ANPRM is published in the Federal Register.

Contract Impact

This press release does not announce an enforcement action, but rather an FTC proposal to amend the Negative Option Rule governing prenotification negative option marketing. In-house teams should review customer subscription, automatic renewal, and negative option clauses in consumer-facing agreements to ensure clear and conspicuous disclosures of material terms, obtain express informed consent for enrollment, and provide simple, easy-to-use cancellation mechanisms. Vendor agreements involving marketing services should also be reviewed for compliance with negative option marketing requirements.

Contract Search Terms

negative option marketingautomatic renewal clausecancellation processexpress informed consentprenotification negative optionsubscription enrollment termsdeceptive marketing disclosuresnegative option plan

Laws Cited

Rule Concerning the Use of Prenotification Negative Option Plans (Negative Option Rule)

Violation Types

Entity Details

Entity

None

Industry

Other

Official Sources

Source Evidence

Title
"FTC Seeks Public Comment in Response to Advance Notice of Proposed Rulemaking Regarding Negative Option Marketing Practices"
Event Date
"March 11, 2026"
Jurisdiction
"Federal Trade Commission"
Event Type
"seeking public comment on an Advance Notice of Proposed Rulemaking (ANPRM)"
Laws Cited
"Rule Concerning the Use of Prenotification Negative Option Plans, commonly known as the Negative Option Rule"
Document Urls
"https://www.federalregister.gov/documents/2026/03/13/2026-04952/rule-concerning-the-use-of-prenotification-negative-option-plans"

Related Enforcement Actions

VA

None

The press release is a weekly roundup of Virginia Attorney General Jay Jones' activities, including updates on vape legislation, joining a 22-state coalition opposing a USPS firearm mailing proposal, filing emergency appeals to the U.S. Supreme Court regarding redistricting, commencement speeches, and Law Day events. No privacy-related enforcement actions are documented.

CT

None

Connecticut Attorney General William Tong praised final passage of House Bill 5312, which creates new civil enforcement mechanisms for deepfake digital sexual assault. The legislation allows the AG to pursue civil injunctions and penalties against platforms that disseminate illegal synthetic intimate images, including AI-generated child pornography, and establishes a private right of action for victims. The bill builds on prior Connecticut laws criminalizing unauthorized dissemination of intimate images.

NJ

None

New Jersey Attorney General Matthew Platkin and the Division on Civil Rights (DCR) announced the adoption of comprehensive new rules codifying the prohibition against disparate impact discrimination under the New Jersey Law Against Discrimination (LAD). The rules, published in the New Jersey Register on December 15, 2025, clarify legal standards for disparate impact liability in employment, housing, public accommodations, financial lending, and contracting, including the use of artificial intelligence in employment contexts. The rules do not create new liability but provide clarity on existing LAD protections amid federal rollbacks of disparate impact standards.

FTC

12 Unnamed Nudify Tool Providers

The FTC sent warning letters to 12 companies offering 'nudify' tools that generate nonconsensual intimate images, for failing to comply with the TAKE IT DOWN Act (TIDA) by not providing a mechanism for victims to request removal of such content. The letters urge immediate compliance with TIDA, which requires platforms to remove nonconsensual intimate images within 48 hours of a valid request. Noncompliant companies may face future legal action and civil penalties of up to $53,088 per violation.

FTC

Covered Platforms

The FTC began enforcing the TAKE IT DOWN Act on May 19, 2026, a law requiring covered platforms to establish a process for victims to request removal of nonconsensual intimate images and delete such content within 48 hours of a valid request. The agency launched a consumer complaint portal, issued compliance guidance for businesses and consumers, and sent reminder letters to major platforms including Meta, TikTok, and X about their obligations under the law. No specific penalties or enforcement actions against individual companies were announced in this release.

FTC

Cliq Inc.

$6.5M

A federal court held Cliq Inc. and its executives Andrew Phillips and John Blaugrund in civil contempt for multiple violations of a 2015 FTC order requiring the payment processor to prevent enabling consumer fraud. The court found the defendants facilitated fraud by processing transactions for high-risk merchants, avoiding fraud monitoring, failing to conduct required underwriting, and ignoring chargeback thresholds. The court imposed $6.5 million in civil contempt sanctions against the defendants.