In 2025, the FTC devoted significant resources to consumer protection. Both its public statements and enforcement activity made the agency’s priorities unmistakably clear. Across speeches, policy statements, consent orders and complaints, the Commission emphasized protecting vulnerable consumers, safeguarding children’s privacy and safety, addressing widespread problems with subscription and billing practices, and ensuring that emerging technologies are marketed truthfully. While not every priority resulted in headline-grabbing settlements, the enforcement docket shed light on the agency’s 2025 priorities, and offered clues regarding what we can expect in 2026.  

Fraud: Protecting Vulnerable Communities

In 2025, the FTC consistently framed fraud enforcement as a response to real-world harm suffered by vulnerable populations. Public statements repeatedly referenced families struggling to put food on the table, seniors and veterans living on fixed incomes and consumers drowning in debt. The agency’s enforcement actions closely tracked that messaging. Some examples include:

• Click Profit. The marketer of a “passive income” opportunity promised consumers substantial earnings through online storefronts. Consumers paid tens of thousands of dollars for services that rarely produced meaningful income. Click Profit paid more than $20 million to settle, reinforcing the FTC’s long-standing hostility toward deceptive earnings claims and business opportunity scams.
• Citizens Disability. Citizens Disability offered prizes, coupons, and other incentives to obtain consumer contact information. It then placed outbound telemarketing calls, including to veterans and disabled consumers, falsely claiming the caller was responding to the consumer’s inquiry about disability benefits. The company agreed to pay $2 million in monetary relief.
• Superior Servicing. The company sent direct mail to student loan borrowers falsely claiming affiliation with the U.S. Department of Education and offering loan consolidation. Borrowers were required to pay substantial upfront fees that they believed would be applied toward their student loan balances. Those payments were pocketed by the scammers. The FTC obtained a $45.9 million judgment, a permanent ban on providing debt relief and loan servicing, and a telemarketing ban against one company officer.

Children’s Privacy and Safety

Protecting children’s privacy and safety was a recurring theme in FTC public statements throughout 2025. The Commission repeatedly emphasized that platforms and services attracting young users must take affirmative steps to comply with the Children’s Online Privacy Protection Act (COPPA) and implement safeguards to mitigate risks. Enforcement reflected concerns not only about data collection, but also safety issues tied to digital engagement. Examples include:

• Disney. The FTC alleged that Disney violated COPPA by collecting personal information from children without parental consent. This issue arose because videos that were inaccurately designated as “not made for children” were published on YouTube channels marketed to children. Disney paid a $10 million civil penalty, reinforcing the FTC’s message that even sophisticated companies remain accountable for children’s data practices.
• Sendit (Complaint). The FTC’s complaint against Sendit alleges the social media platform knowingly collected personal information from users under 13 without parental consent. The agency also alleges that Sendit sent anonymous fake and provocative messages, and falsely stated that the recipient could learn the sender’s identity if they enrolled in a premium subscription. The matter is pending.
• 6(b) Orders Regarding Companion Chatbots. Beyond enforcement, the FTC issued orders using its 6(b) authority to companies developing companion chatbots that may be marketed to or used by children. These orders sought information about data practices, training methods, and safeguards, signaling concern about how AI-driven conversational tools interact with minors. 

Subscriptions, ROSCA, and Billing Practices

Subscription practices remained one of the FTC’s most active enforcement areas in 2025. Public statements consistently criticized confusing enrollment processes, unexpected recurring charges, and burdensome cancellation mechanisms. The Commission emphasized that ROSCA applies broadly, regardless of industry or business model. Enforcement activity included:

• Amazon. The FTC alleged that Amazon’s Prime enrollment and cancellation flows were designed to steer consumers into recurring subscriptions, and that Amazon purposefully made cancellation difficult. According to the complaint, consumers were funneled through multiple screens and prompts that obscured cancellation options. Amazon agreed to a historic $2.5 billion settlement, making this the largest ROSCA-related resolution to date.
• Match. The FTC argued that Match deceptively induced consumers to enroll by promising a free six-month subscription if consumers didn’t meet someone special, but failed to disclose onerous conditions. Match was also accused of suspending users' accounts after they filed billing disputes, and made cancellation difficult. Match paid $14 million to settle the FTC’s charges.
• Cerebral. An online mental health provider claimed that consumers could cancel anytime, but failed to disclose the complicated, multi-step procedure that often took several days to complete. The company also promised “safe, secure and discrete” services, even though it shared consumers’ sensitive data with third parties for advertising purposes. The proposed order requires Cerebral to pay almost $5.1 million in partial refunds, and a $10 million penalty to be suspended after a $2 million payment because of inability to pay. 

AI: Enforcement Without Stifling Innovation

In 2025, the FTC publicly aligned itself with the White House position that the United States should lead in artificial intelligence innovation and that enforcement should not suppress legitimate technological development. At the same time, the Commission emphasized that claims about AI capabilities must be truthful and substantiated.

• Workado. Workado broadly marketed a tool that could purportedly identify writings that had been created using AI. Because the AI tool had been trained using only educational materials, it often produced incorrect results for non-educational writings. The FTC enjoined Workado from  making from future unsubstantiated claims.
• DoNotPay. DoNotPay marketed its services as providing AI-powered assistance that could replace traditional legal services. The FTC alleged that these claims were false. DoNotPay agreed to pay $193,000 and to refrain from making unsupported claims about its AI tools.
• Air AI (Complaint). The FTC’s complaint alleges that Air AI marketed business coaching materials, including “conversational AI” that could replace human customer service and, combined with other features, could deliver significant profits. Small businesses often did not earn promised profits, or even recoup the money they paid to Air AI. The litigation is pending.

Made in USA: Public Statements and Warning Letters

Although 2025 did not feature any Made in USA complaints or settlements, the FTC used public statements and warning letters to reinforce its expectations. Chair Ferguson declared July “Made in USA Month” and emphasized that unqualified Made in USA claims require that products be “all or virtually all” made in the United States, including component parts.

The FTC also issued warning letters to manufacturers and retailers reminding them of the persuasiveness of U.S. origin claims, and the stringent requirements imposed by Section 5 and the Made in USA Labeling Rule. These actions signal continued scrutiny, even if they didn’t produce settlements or complaints in 2025.

Looking Ahead to 2026

Based on the FTC’s activity in 2025, several themes are likely to carry forward. Fraud targeting vulnerable populations, children’s privacy and safety, and subscription and billing practices will likely remain enforcement priorities. The recent settlement regarding pricing practices with Greystar, the largest rental housing provider, signals that pricing practices and junk fees will be a focus, even outside of ticketing and short-term rentals, and in industries not previously scrutinized. The FTC also signaled that consumer reviews are on its radar when, in late December, it sent warning letters to 10 companies regarding potential violations of the Consumer Reviews and Testimonials Rule. Further, the recently announced Workshop on Consumer Injuries and Benefits in the Data-Driven Economy suggests that data privacy and security will be an area of focus. We will continue to monitor what's happening at the FTC and will report on any significant developments.