In the first enforcement action by the Federal Trade Commission (FTC) since the Trump administration stopped defending an FTC rule that would have banned nearly all noncompete agreements in the employment context, the FTC recently reached an agreement containing a 10-year consent order with an employer, requiring the employer to stop enforcing noncompete agreements against nearly 1,800 employees. The action signals the FTC’s shift to case-by-case approach in limiting the use of noncompete agreements, with a focus on restricting company-wide or overly broad noncompete agreements.

• The FTC negotiated a ten-year consent order with an employer to end the employer’s enforcement of blanket noncompete agreements against nearly 1,800 employees.
• The consent order mandates that the employer notify employees and former employees that the company’s noncompete agreements are no longer effective, cease enforcement of those agreements, and provide ongoing compliance reporting to the FTC for a decade.
• The consent order comes after the Trump administration stopped defending the rule adopted by the FTC during the Biden administration in the FTC’s effort to ban nearly all noncompete agreements in employment.
• The action marks a shift by the FTC under the Trump administration toward a case-by-case approach to analyze and attack unreasonable noncompete agreements the FTC views as harming competition in the labor market.

On November 25, 2025, the FTC issued a consent order involving pet...

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