Businesses facing an unresolved question about a Federal Trade Commission rule now have a dedicated way to bring it to the agency’s Bureau of Consumer Protection. On Sept. 10, 2026, the Bureau announced its Rule Guidance Program, which invites stakeholders to “identify genuine ambiguities in the Commission’s rules, substantive conflicts between a rule and an existing statute or other rule, and other significant issues that may exist within Commission rules.”
If the Bureau decides an issue warrants a response, it may publish guidance so others have an opportunity to benefit from the answer.
How to Raise an Issue
The Bureau’s program page links stakeholders to an online submission form. The form directs submitters to identify the specific rule and provisions at issue, explain the potential problem, and describe the context in which it arises. Staff will review submissions, and the Bureau retains discretion to decide whether and when to address them. The Bureau will publish any guidance it issues through the program.
What the Program Is Designed to Answer
The FTC has stated that the Rule Guidance Program provides a channel for identifying substantive issues with rules — not for asking routine compliance questions. According to the agency, Bureau staff will not restate a rule or answer a question already addressed by a rule’s text, existing business guidance, or a formal advisory opinion. Further, Bureau staff will not assume a business’s responsibility for applying legal standards to its own practices.
For example, the FTC notes that staff will not use the program to decide whether a business’s disclosure is “clear and conspicuous.” A submission identifying specific provisions that appear to conflict would more closely fit the Bureau’s stated criteria than a request to approve a particular disclosure.
Practical Takeaways
Businesses considering a submission should first review the relevant rule text and existing FTC guidance. If the issue remains unresolved, a useful submission will explain the competing interpretations or conflict and the reason the answer matters in practice. Trade associations may also find the program useful for questions that affect multiple members.
The program does not guarantee an answer, nor does it change a business’s compliance obligations while a question is pending. The Bureau also states that staff guidance is not binding on the Commission or the public. Businesses should therefore consider treating the program as an opportunity to seek broader clarity on a rule, while continuing to make and document their own compliance judgments.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
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