"Free" offers disclose all conditions, obligations, and post-trial charges
Why it matters
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.
Severity rationale
High because undisclosed post-trial charges directly violate the FTC's Negative Option Rule, and the deceptive omission occurs at the highest-trust moment in the funnel — the moment a consumer decides to try the product for free.
Remediation
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.
DetectionPro
The detection method for this pattern is part of AuditBuffet Pro.
The full method (what to look for, pass and fail conditions, and how results get reported) ships inside the FTC Consumer Protection Audit. The pattern definition, severity rationale, and remediation remain openly licensed under CC-BY-4.0.
External references
- external · ftc-free-offer-guidelines — FTC Guide Concerning Use of the Word 'Free' (16 CFR Part 251)
- external · ftc-negative-option-rule — FTC Negative Option Rule (16 CFR Part 425, updated 2024)
Taxons
History
- 2026-04-18·v1.0.0·Initial import from ftc-consumer-protection·automated