As previously reported, the Federal Trade Commission's (FTC) Rule on Unfair or Deceptive Fees—commonly referred to as the "Junk Fees Rule"—officially took effect on May 12. Just days later, the agency publicly warned ticket reseller StubHub that it must comply with the new rule or face civil penalties of up to $53,088 per violation.
This nearly immediate warning confirms what was apparent months ago: despite broader political uncertainty and anticipated regulatory headwinds, junk fees remain a top enforcement priority for the FTC.
The rule requires that businesses disclose the total price of a good or service up front, inclusive of all mandatory fees. Only government-imposed taxes, shipping, and truly optional add-ons may be excluded from the advertised price. The goal is to eliminate bait-and-switch pricing tactics that obscure the true cost of a transaction and undermine consumer trust.
The Commission's warning to StubHub was timed to coincide with the release of the NFL's 2025 season schedule—a peak moment for online ticket traffic. It wasn't subtle. It was a signal to the entire ticketing industry, and to other sectors that rely on complex or layered pricing models, that the FTC intends to enforce this rule aggressively.
There was never much doubt about where this was headed. Even as questions circulated about the viability of recent FTC rules under a potential regulatory freeze, it was clear that junk fees were too politically salient—and too consumer-facing—to be shelved quietly.
Commissioner Melissa Holyoak, who joined the Commission shortly before the rule went into effect, supported it on the basis that it enhances transparency while preserving pricing flexibility for businesses. Commissioner Andrew Ferguson dissented—not on substance, but on timing—expressing concern about finalizing the rule during a leadership transition. That procedural objection never appeared likely to chill enforcement, and now we have confirmation that it won't.
For legal counsel advising clients in ticketing, hospitality, travel, or any consumer-facing sector: the compliance window has closed. The FTC isn't just finalizing policy—it's enforcing it. Companies should review their pricing disclosures and checkout flows immediately to ensure they align with the new total-price requirements.
The era of hidden fees is over. And the FTC isn't waiting around to prove it.
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