In April 2026, the Federal Trade Commission ordered Rollins, Inc., one of the largest pest-control companies in the United States, to stop enforcing noncompete agreements against…


In April 2026, the Federal Trade Commission ordered Rollins, Inc., one of the largest pest-control companies in the United States, to stop enforcing noncompete agreements against more than 18,000 employees nationwide. The action stands as one of the agency's most significant post-Ryan LLC enforcement efforts and underscores that the FTC's interest in restrictive employment covenants is far from dormant. Employers who assumed the regulatory landscape had stabilized after the withdrawal of the categorical national noncompete ban should take careful note of the scale and posture of this action.

Alongside the Rollins order, the FTC sent warning letters to 13 other companies in the pest-control industry, urging them to review their employment agreements. Read together, these moves signal a sector-wide review and a clear message to similarly situated employers: the agency is prepared to scrutinize noncompete practices on an industry-by-industry basis and to pursue relief that can sweep across tens of thousands of workers at a single company. For companies in the pest-control sector, the warning letters function as both notice and invitation to conduct an internal audit before the agency arrives at the door.

The broader takeaway is strategic. Having withdrawn its categorical rule, the FTC has pivoted to case-by-case Section 5 enforcement, treating overbroad or unnecessary noncompetes as potential unfair methods of competition. This means that the question is no longer whether a single national rule applies, but whether the scope, necessity, and worker classifications covered by a given employer's agreements can withstand individualized review. Employers across industries—not only pest control—should reassess which roles are subject to noncompetes, whether narrower tools such as nondisclosure or nonsolicitation provisions would suffice, and whether existing agreements reach categories of workers whose inclusion is difficult to justify.

Proactive review now is meaningfully cheaper than responding to an investigation later. Companies should consider documenting the business rationale supporting any restrictions they intend to retain and revising agreements where the justification is thin or the coverage is excessive.

This article is provided for general informational purposes only and does not constitute legal advice. Clients should seek tailored counsel regarding their specific circumstances and agreements.

Authors