- videocam Live Webinar with Live Q&A
- calendar_month April 23, 2026 @ 1:00 p.m. ET/10:00 a.m. PT
- signal_cellular_alt Intermediate
- card_travel Class Action and Other Litigation
- schedule 90 minutes
Automatic Renewal and Subscription Laws Update: Lessons for 2026 From the Most Important Developments In 2025
Welcome! Use code NEWYEAR26 to unlock 25% off all expert-led CLE, CPE, and Professional Skills webinars, and 10% off annual passes.
About the Course
Introduction
This CLE webinar will review the most important developments in 2025 concerning subscription and automatic renewal laws (ARLs) and what businesses and counsel can expect in 2026 and beyond. The speakers will discuss what these laws require, how they differ from jurisdiction to jurisdiction, and enforcement trends by the FTC, state attorneys general, the class action plaintiffs bar, and others. They will also highlight key decisions, case filing trends, and settlements, and discuss practical options for in-house and defense counsel.
Description
The FTC's Rule Concerning Subscriptions and Other Negative Option Plans—a/k/a Click-to-Cancel—was vacated by the Eighth Circuit in 2025 due to procedural defects, but the FTC has continued to enforce existing regulations and has indicated further rulemaking may be in the offing. In addition, numerous states (including Arkansas, California, Colorado, Connecticut, Maryland, Massachusetts, Minnesota, New York, Utah, and others) have been amending, and in some instances enacting for the first time, state-level ARLs that regulate subscriptions and similar automatically renewing contracts for goods or services. These laws can require upfront disclosures, affirmative consent, reminders, and an easy cancellation process. They may also govern "free trials." Enforcement is regularly occurring at both the federal and state level and via regulatory enforcement as well as civil lawsuits (typically class actions).
Counsel should understand what claims are typically asserted in these actions and whether they have evolved, what implications new and amended state and federal laws may have, and how these cases are being resolved in order to prepare for 2026 and beyond.
Listen as our expert panel delves into the current status and key issues in ARL disputes and offers insights into what to expect in 2026.
Presented By
Mr. Jaeger represents clients in class actions and complex litigation in state and federal courts across the country with a particular focus on privacy and consumer protection defense. Clients turn to Mr. Jaeger for advice on claims brought under the California Consumer Privacy Act, the California Invasion of Privacy Act, Illinois’ Biometric Information Privacy Act, Florida’s Security of Communications Act, the Telephone Consumer Protection Act, California’s Unfair Competition Law, California’s Consumers Legal Remedies Act, the Americans with Disabilities Act, and California’s Unruh Civil Rights Act, among others. Companies leverage his significant experience with business disputes and related litigation, including in the areas of COVID-19 liability, sports and entertainment, false advertising, product liability, labor and employment, RICO, construction defect, ERISA, and franchising. Clients also seek Mr. Jaeger's counsel on compliance and litigation avoidance in the areas of privacy and data protection, online terms and conditions, arbitration provisions, class action waivers, and automatic renewal/continuing subscription programs. He is the author of Practical Law’s guidance on state automatic renewal laws and is a part of the Uniform Law Commission’s Recurring Service Charges Drafting Committee.
Mr. Singer spent over two decades in the Texas Attorney General’s office, spearheading its consumer protection, advertising and marketing, public health, and data protection efforts. He leverages the insights he gained, relationships he developed, and trust he earned in that role to help companies in various industries protect their legal, business, and reputational interests when they find themselves under government scrutiny. Mr. Singer defending clients in state-level investigations and enforcement actions, providing comprehensive compliance counsel, and advancing their interests through persuasive policy advocacy on consumer protection matters. His extensive knowledge and experience have made him a requested and frequent speaker at national seminars and trainings on a variety of technology, privacy, and general consumer protection topics.
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This 90-minute webinar is eligible in most states for 1.5 CLE credits.
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Live Online
On Demand
Date + Time
- event
Thursday, April 23, 2026
- schedule
1:00 p.m. ET/10:00 a.m. PT
I. Overview of ARL statutes and rules
A. Federal regulation
B. State regulation
C. Consumer contracts
D. Business-to-business contracts
II. Typical provisions
A. Clear and conspicuous material disclosures
B. Affirmative consent
C. Confirmation/acknowledgement
D. Renewal reminders
E. Notices of material/fee changes
F. Simplified cancellation process and "saves"
G. Other notable elements
III. Notable 2025/early 2026 developments
A. FTC Rule
B. States: key amendments and new laws
IV. Court actions
A. Filing trends: state and federal
B. Notable settlements
C. Decisions
V. Expectations for 2026 and beyond
The panel will review these and other important issues:
- What are the trends in ARL provisions based on 2025 developments?
- Which states' laws seem to have the most impact on the federal regulatory scheme?
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Unlimited access to premium CLE, CPE, Professional Skills and Practice-Ready courses.:
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