The Federal Trade Commission is making clear that retail-facing enforcement is a central priority for 2026, with a string of actions spanning pricing transparency, fake reviews, deceptive subscriptions, and franchise practices. On March 5, FTC Bureau of Consumer Protection Director Christopher Mufarrige outlined the agency's enforcement agenda, citing efforts targeting the BOTS Act, fraud in the U.S. payment system, and deceptive subscription practices under the Restore Online Shopper's Confidence Act, as the Retail & Consumer Products Law Observer reported.
One of the most significant recent actions involved Xponential Fitness, where the FTC secured a settlement for Franchise Rule violations and deceptive practices that will return $17 million to franchisees — the largest consumer redress amount in a franchise case in FTC history. The agency also announced the distribution of more than $47.2 million in checks to consumers deceived by undisclosed fees charged by Invitation Homes, underscoring the FTC's focus on hidden charges and junk fees across consumer-facing industries.
The fake reviews crackdown is another front where the FTC is escalating from education to enforcement. In late December 2025, the agency sent warning letters to 10 companies about potential violations of its updated Consumer Reviews Rule. As Arnold & Porter analyzed, the prohibited practices include creating or purchasing fake reviews, incentivizing reviews based on sentiment, employees posting reviews without disclosure, and using gatekeeping tactics to suppress negative feedback. Violations could carry civil penalties of up to $53,088 per occurrence — a figure that could add up quickly for retailers with large product catalogs.
Pricing transparency is also firmly in the enforcement crosshairs. The FTC sent warning letters to 97 auto dealership groups across the country, putting them on notice that advertised prices must reflect the total cost consumers will actually pay, including all mandatory fees. While the auto sector was the immediate target, the underlying principle — that sticker prices must not obscure the true cost — has clear implications for retailers using promotional pricing, strike-through discounts, and limited-time offers that may not withstand scrutiny.
As Crowell & Moring's analysis characterized the environment, 2026 represents a "legal minefield" for retail, with the FTC, state attorneys general, district attorneys, and private plaintiffs all actively pursuing cases. The agency has also signaled a focus on payment processors and intermediaries who enable consumer fraud, having secured settlements against companies like Paddle and Cliq that returned millions to affected customers. For retailers, the message is increasingly unambiguous: compliance programs that may have been adequate in prior years need to be reassessed against an enforcement posture that has shifted from guidance to action.