Warr and Asp Examine FTC's Renewed Focus on Subscription Cancellation Rules in Daily Business Review

05.11.2026

Stinson LLP Partner J. Nicci Warr and attorney Emily Asp authored an article in the Daily Business Review examining the Federal Trade Commission's (FTC) renewed efforts to regulate subscription cancellations and automatic renewals following the court's rejection of the Biden-era "click-to-cancel" rule.

In the article, Warr and Asp explain that while the original federal rule was vacated on procedural grounds, the FTC is once again pursuing rulemaking aimed at ensuring subscription cancellations are as simple as sign-ups. "The underlying idea – that subscriptions should be as easy to end as they are to begin – remains popular with consumers across the political spectrum," the authors write, noting that the issue continues to draw bipartisan attention.

The article also highlights how Florida businesses may already be subject to similar requirements under existing state law. Warr and Asp outline Florida's automatic renewal statute, which requires certain businesses to allow consumers to cancel subscriptions using the same method they used to enroll. They emphasize that businesses operating recurring billing models should proactively review their sign-up and cancellation practices to identify potential compliance gaps.

In addition, the authors discuss the FTC's current rulemaking process and the likelihood that future federal regulations will resemble the original "click-to-cancel" framework. "The companies that get ahead of this will be the ones that treat easy cancellation not as a regulatory burden, but as good business," they write.

Warr counsels clients on complex litigation involving antitrust, consumer protection and intellectual property issues, with a particular focus on emerging technologies. She draws on her experience at the intersection of intellectual property and competition law to help clients find efficient and effective solutions.

Asp works with clients on a variety of different litigated matters involving, among other things, antitrust and product liability issues. She has significant experience in all phases of litigation, including trial, discovery, and motions practice in state and federal court. She brings a collaborative and forward-thinking approach to each matter while keeping client service top of mind.

Sign in to the Daily Business Review to read more.