The FTC announced its Final Rule for subscriptions (negative options), dubbed the “click to cancel” rule because of the focus on cancellation methods. But the FTC’s new rule covers more than just requirements for easy cancellation.

Below are a few of the rule’s requirements:

• No misrepresentations – the new rule prohibits sellers from misrepresenting any material fact while marketing a negative option plan.
   
• Provide important information before collecting billing information – the new rule requires sellers to provide important information prior to obtaining the consumer's billing information and to charging them (or using any saved account information to charge the consumer).
   
• Obtain consent – under the new rule, sellers must obtain the consumer's unambiguously affirmative consent to the negative option plan before charging them.
   
• Simple cancellation – sellers must provide consumers with simple cancellation methods that will immediately stop all recurring charges.

The new requirements around misrepresentations and disclosures will become effective 60 days after the rule is published in the Federal Register, and the requirements around consent and simple cancellation will become effective 180 days after the rule is published in the Federal Register.