The FTC’s New Junk Fee Rule: What Consumer-Facing Brands Need to Know in 2025
Consumer-protection enforcement has entered a new era. The Federal Trade Commission’s latest rule on “junk fees” — hidden or misleading charges layered into the sales process — carries far-reaching implications for businesses that market, price, and sell to the public.
From hotels and ticketing platforms to e-commerce and subscription services, companies must now put transparent pricing and fair-fee disclosures at the center of their compliance strategy.
The Rule at a Glance
The FTC rule prohibits:
- Hidden or surprise fees not disclosed upfront
- Displaying a lower price before revealing mandatory charges
- Deceptive “service fees,” processing fees, or facility charges
- Fees that appear unavoidable but offer no real value
In short, if a price isn’t disclosed clearly and early — the FTC may consider it unlawful.
Industries under heightened scrutiny include:
- Hospitality and lodging
- Ticketing and live events
- Travel and transportation
- Subscription services & SaaS
- Utilities and telecom
- Gig and delivery platforms
- Marketplaces and booking sites
Key Obligations for Businesses
The rule goes beyond disclosure. Companies must:
- Provide total price upfront
The “real price” — including mandatory fees — must appear before checkout or customer commitment.
- Clearly identify optional vs. mandatory fees
Optional add-ons must be distinguishable from required charges.
- Support fees with real value
Charges must correspond to a legitimate service — not administrative padding.
- Review recurring billing practices
Opaque subscription fees are a top enforcement target.
What’s at Stake
Penalties for violations can include:
- Civil fines and enforcement actions
- Class action exposure
- State AG coordination
- Public enforcement announcements — damaging reputations overnight
In a marketplace where trust drives loyalty, pricing practices now signal integrity as much as profit.
How Businesses Can Prepare
Proactive compliance measures include:
- Conduct a pricing and fee audit across all customer touchpoints
- Update marketing, checkout flows, and disclosures
- Train teams on consumer-protection expectations
- Ensure subscription cancellation is simple and conspicuous
- Review third-party platforms and payment partners for alignment
Businesses adopting transparency now will be best positioned as regulators intensify scrutiny.
How Holon Law Partners Can Help
Holon advises consumer-facing businesses navigating the evolving compliance landscape. Our team works across regulatory, advertising, technology, and commercial disciplines to help organizations:
- Conduct compliant pricing and advertising reviews
- Structure subscription and recurring-billing programs
- Draft defensible fee and disclosure language
- Manage regulatory inquiries and enforcement response
- Build trust-centered consumer experience frameworks
In a regulatory climate increasingly defined by transparency and consumer fairness, Holon helps companies stay ahead — strategically, ethically, and competitively.
For support evaluating your pricing, disclosures, or subscription practices under the new FTC rule, contact Holon Law Partners.
