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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

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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

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FTC

Credit Glory LLC

The FTC filed a complaint against Credit Glory LLC and related entities for deceptive credit repair practices, including false promises, impersonating debt collectors, charging illegal upfront fees, and using negative option billing without consent. A federal court temporarily halted the operation.

FTC

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Hims & Hers

The FTC, along with Utah and California, filed a complaint against Hims & Hers alleging the telehealth provider shared consumers' sensitive health information with third-party advertising platforms without consent, and deceived consumers about billing and cancellation practices. The complaint alleges violations of the FTC Act and the Restore Online Shoppers' Confidence Act.