"Free" offers disclose all conditions, obligations, and post-trial charges

The FTC's Free Offer guidelines and Negative Option Rule both require that conditions on 'free' offers be clearly and conspicuously disclosed at the outset — not in a linked terms document. A 'Start for free' CTA that routes to a credit card form without disclosing the post-trial charge amount and date is a textbook Negative Option Rule violation. Consumers who discover a charge they didn't understand will initiate chargebacks, dispute the charge with their bank, and leave fraud-flagged reviews — all of which carry downstream payment processor consequences beyond the FTC exposure.

Disclose the post-trial charge amount, date, and cancellation method immediately below the free trial CTA — not in a linked terms document.

function FreeTrialCTA() {
  return (
    <div>
      <button>Start your 14-day free trial</button>

      {/* Disclosure inline, not in fine print — FTC standard */}
      <p className="text-sm text-gray-600 mt-2">
        No charge for 14 days. After your trial, plans start at $29/month.
        Cancel anytime before day 14 from your account settings and
        you won't be charged. Credit card required to begin.
      </p>
    </div>
  )
}

// Free tier — disclose limits upfront on the pricing card
function FreeTierCard() {
  return (
    <div>
      <h3>Free</h3>
      <p>$0/month</p>
      <ul>
        <li>Up to 3 projects</li>
        <li>1 team member</li>
        <li>500MB storage</li>
      </ul>
      {/* Limits here, not on a page the user finds after signup */}
    </div>
  )
}

The FTC standard: 'Conditions must be clearly and conspicuously disclosed at the outset of the offer.' Adjacent means adjacent — inline text immediately below the offer.

• ID: ftc-consumer-protection.advertising-claims.free-conditions-stated

• Severity: high

• What to look for: Count all relevant instances and enumerate each. Search for the word "free" across marketing copy, pricing pages, CTAs, and onboarding flows. The FTC's "Free Offer" guidelines require that when something is advertised as free, all terms and conditions are clearly and conspicuously disclosed at the outset — not buried in fine print or linked to a separate terms page. Check: (1) does a "free trial" disclose when it ends, what happens at the end (automatic charge, downgrade, or account deletion), and how much the user will be charged? (2) Does a "free tier" clearly communicate which features are excluded or what limits apply (e.g., "free up to 3 projects")? (3) Does the free trial require a payment method upfront? If so, is the future charge amount and date disclosed clearly — not just in a linked terms document? (4) Is the cancellation method disclosed alongside the free trial offer (not just in the terms)?

• Pass criteria: Every "free" offer discloses all material conditions, limits, and future obligations immediately adjacent to the "free" claim — not only in linked terms. At least 1 implementation must be verified. Free trials that require a credit card disclose the charge amount, date, and cancellation method before the user enters payment information. Free tiers clearly communicate feature limits. A partial or placeholder implementation does not count as pass.

• Fail criteria: "Start for free" CTA leads to a credit card form without disclosing the post-trial charge amount or date. "Free plan" is prominently advertised but feature restrictions appear only after signup. Trial terms are only accessible via a small "Terms apply" link with no inline disclosure.

• Skip (N/A) when: The application has no free offers, free trials, or free tiers of any kind.

• Detail on fail: Example: "'Start Free Trial' CTA leads directly to payment form. Post-trial charge ($29/month) not disclosed until Terms of Service link at checkout — not stated in the CTA or on the free trial landing page." or "Free plan promoted on homepage but storage limit (500MB) and feature restrictions are only shown after signup completion." or "14-day free trial requires credit card; no disclosure of charge date or amount adjacent to the CTA."

• Remediation: Disclose all free offer conditions at the point of the free offer:

  // Free trial CTA with inline disclosure (FTC-compliant pattern)
  function FreeTrialCTA() {
    return (
      <div>
        <button>Start your 14-day free trial</button>
  
        {/* Disclosure immediately below the CTA — not in fine print */}
        <p className="text-sm text-gray-600">
          No charge for 14 days. After your trial, plans start at $29/month.
          Cancel anytime before day 14 and you won't be charged.
          Credit card required to begin trial.
        </p>
      </div>
    )
  }
  
  // Free tier card — disclose limits upfront
  function FreeTierCard() {
    return (
      <div>
        <h3>Free</h3>
        <p className="price">$0/month</p>
        <ul>
          <li>Up to 3 projects</li>
          <li>1 team member</li>
          <li>500MB storage</li>
          <li>Community support only</li>
          {/* List the key limits here, not on a separate page */}
        </ul>
      </div>
    )
  }
  

  The FTC standard: "Conditions must be clearly and conspicuously disclosed at the outset of the offer." Adjacent means adjacent — inline text immediately below the offer, not a footnote or a linked page. For subscription trials that require a credit card, the charge amount, date, and cancellation method must all appear before the payment form.

• Cross-reference: For related patterns and deeper analysis, see the corresponding checks in other AuditBuffet audits covering this domain.