FTC: FleetCor (Corpay) and CEO to Pay $100 Million Over Hidden Fuel-Card Fees

The Federal Trade Commission announced on September 17, 2026 that FleetCor Technologies, Inc. (now Corpay, Inc.) and CEO Ronald Clarke agreed to pay $100 million to resolve an FTC administrative action over hidden fuel-card fees, following a federal appeals court ruling that the company violated the FTC Act.

Information last verified on September 20, 2026.

Status: Settlement announced September 17, 2026. It is not yet final. The FTC placed the Agreement Containing Consent Order on the public record for 30 days of public comment following publication in the Federal Register, after which the Commission will decide whether to make the proposed consent order final.

Jurisdiction scope: This is a federal enforcement matter under Section 5 of the FTC Act, brought by the Federal Trade Commission against a payments company and its CEO over how it billed its own business customers. It is not a consumer class action, does not involve a rulemaking, and (as of this writing) has no public claims-filing process for individual consumers.

What Happened

FleetCor Technologies, a fuel-card company that has since renamed itself Corpay, markets and sells cards that businesses use to pay for fuel and related purchases at gas stations. The FTC's complaint centered on two kinds of alleged misconduct: unauthorized fees and misleading marketing.

On the fee side, the FTC alleged FleetCor charged late fees to customers who had actually paid on time, along with other fees the company did not adequately disclose. On the marketing side, the FTC alleged FleetCor's advertising misrepresented how much money its cards would save businesses on fuel, overstated the fraud-control features that would protect customers from unauthorized charges, and misrepresented the fees customers would actually pay.

The agency sued FleetCor and CEO Ronald Clarke in the U.S. District Court for the Northern District of Georgia on December 20, 2019, alleging five counts of FTC Act violations. The district court granted summary judgment for the FTC against both defendants on August 9, 2022, and entered a permanent injunction on June 8, 2023, requiring customer consent before charging fees, barring further misrepresentations, and prohibiting other unlawful conduct.

FleetCor and Clarke appealed to the Eleventh Circuit. On January 6, 2026, the appeals court affirmed Corpay's liability on all five counts and upheld the injunction against the company. As to Clarke individually, the court affirmed his liability on four of the five counts but found the FTC had not shown enough on the count involving fraud-control-feature misrepresentations, vacating the injunction against him and remanding that count to the district court.

Separately, in August 2021, the FTC's Bureau of Consumer Protection had filed an administrative complaint against the same two respondents over the same conduct, opening a second, parallel case before the Commission itself (Docket No. D-9403). That is the case the $100 million settlement resolves. FleetCor and Clarke signed an Agreement Containing Consent Order; the FTC withdrew the matter from adjudication to consider it, and on September 17, 2026 placed the proposed order on the public record for comment.

What the Law Actually Says

Section 5 of the FTC Act (15 U.S.C. § 45) prohibits "unfair or deceptive acts or practices in or affecting commerce." The FTC's complaint invoked both prongs: the fee counts as unfair practices, and the marketing counts as deceptive practices. A practice is generally "deceptive" when it involves a material representation likely to mislead a customer acting reasonably, and "unfair" when it causes substantial injury that the customer could not reasonably avoid and that is not outweighed by any countervailing benefit.

The remedy mechanism here is worth being precise about, because it is easy to get wrong. In 2021, the Supreme Court held in AMG Capital Management, LLC v. FTC, 593 U.S. 67 (2021), that the FTC cannot obtain equitable monetary relief, such as restitution or disgorgement, through the provision of the FTC Act it had long used to sue directly in federal court. The FTC's own Decision and Order in this matter says explicitly that it filed the parallel administrative complaint against FleetCor in August 2021 "following" AMG, challenging "the same acts and practices" already being litigated in the federal lawsuit.

What the FTC's Decision and Order and its Analysis of Proposed Consent Order do not say is that the $100 million flows from Section 19 of the FTC Act (15 U.S.C. § 57b), the post-AMG redress statute that lets the FTC seek consumer refunds in federal court after a final Commission cease-and-desist order in a case involving dishonest or fraudulent conduct. That is a real, separate pathway, but it is not the one documented here. Instead, the $100 million is a negotiated term of the consent order itself, in the administrative case: FleetCor and Clarke agreed to pay it to settle the Part 3 administrative complaint, rather than litigate that case to a contested Commission order. The order directs that the money be paid to the Commission, which may deposit it into a fund used for consumer redress and related administrative expenses, with any leftover funds going to other relief or the U.S. Treasury. If a claims and payment process for individual customers has not yet been described in the record reviewed for this article, that is because the order has not been finalized.

Analysis: Why This Matters

The following is analysis from the Recording Law Editorial Team.

This case is a clean illustration of how the FTC has adapted its playbook since AMG closed off the fast route to money damages in federal court. Rather than relying solely on the district court injunction, which can stop future conduct but, after AMG, generally cannot hand back money already taken, the agency ran a second track: an administrative complaint before the Commission itself. When a company and an executive are willing to settle that administrative case by consent, the FTC can secure a monetary payment as a negotiated term of that settlement, without needing to prove the specific elements Section 19 would otherwise require.

The split outcome for Clarke is also instructive. Executives at companies the FTC pursues for fee or marketing practices should not assume personal liability rises or falls in lockstep with the company's. The Eleventh Circuit affirmed Clarke's personal liability on four of five counts but drew a line on the one where the agency's evidence of his personal knowledge was, in the court's view, thinner. That kind of count-by-count scrutiny of an individual defendant's knowledge and control is a recurring theme in FTC Act unfairness and deception cases against corporate officers.

This case also sits alongside a broader run of federal fee-transparency enforcement. See our coverage of a dealer add-on fee settlement and a travel-booking junk fees settlement for other recent examples of the FTC targeting undisclosed charges, and our summary of the FTC's auto dealer price transparency rule for the regulatory backdrop.

How This Affects You

This is a business-to-business enforcement matter, not a consumer class action, and nothing here is legal advice for your specific situation. If your business used FleetCor or Corpay fuel cards, here is what is actually known as of September 20, 2026: the settlement is not final, the FTC has not announced a claims process, and the agency's order says it may use customer information FleetCor/Corpay is required to provide in order to administer redress directly, rather than through a public claims form. Watch the FTC's own case page for updates before assuming a specific dollar figure or timeline applies to your account.

Because major FTC settlements attract scammers, be skeptical of any unsolicited call, text, or email claiming to process a "FleetCor refund" or "Corpay settlement payment" for you, especially one that asks for banking information or an upfront fee. The FTC does not charge customers to receive money it orders returned to them. For a sense of how FTC-ordered redress has played out in other cases, our tracker on the Amazon Prime FTC settlement and our coverage of expanded automatic-payment redress in that case show how the agency has handled distribution once an order becomes final.

Disclaimer: This article is for general informational purposes only and is not legal advice. It does not create an attorney-client relationship. If you have questions about your specific business's dealings with FleetCor or Corpay, consult a licensed attorney.

Last updated: 2026-09-20. This is a developing story; details verified as of 2026-09-20.