NYC's Click-to-Cancel Rule Starts Oct. 1: What It Requires, Who's Exempt, and Where Federal Rules Stand

New York City's "click to cancel" rule for subscriptions takes effect on October 1, 2026. The Mayor's Office has billed it as the first municipal rule of its kind in the nation, and it lands while the federal version is still in limbo. Even if you don't live in New York, it's a useful, concrete look at what a well-defined subscription-cancellation standard looks like, and a checklist for judging any company's cancellation practices.

This is an explainer, not legal advice. How the rule applies to a specific business or purchase is a question for the city's Department of Consumer and Worker Protection (DCWP) or an attorney.

What the rule is

The rule is titled "Cancellation of Subscriptions" and was adopted by DCWP. DCWP proposed it on April 8, 2026 and held a public hearing on May 8, 2026, according to its Notice of Adoption. The Mayor's Office announced the final rule on July 10, 2026. It adds a new Part 8 ("Click to Cancel") to Title 6 of the Rules of the City of New York. It is a city rule enforced by DCWP; how far it reaches businesses based outside the city is not something the notice settles for us, so we don't guess.

It covers any "automatic renewal" (a paid term that renews automatically at the end of a set period) or "continuous service" (a subscription that runs until the consumer cancels), for any type of goods or services. DCWP says it received more than 100 consumer complaints about difficulty canceling subscriptions in 2025 alone.

What businesses must do

Under the adopted text, a business making an automatic-renewal or continuous-service offer must:

• Disclose the material terms up front. That means a description of the product, the amount charged, how often, the deadline to stop further charges, and how to cancel. These must appear clearly and before consent or billing information is requested. If there's a free trial or a temporary price, the offer must explain how and when the price will change.
• Let you cancel the way you signed up. Cancellation must be available "at any time" through "a simple cancellation mechanism that is as easy to use" as the one used to sign up, through the same medium. If you consented in person, the business must also offer an online cancellation option, such as a website or email.
• Not obstruct cancellation. The rule lists hanging up on people who call to cancel, giving false information about how to cancel, and misrepresenting the cost or consequences of canceling. It does allow retention offers, but not ones that impose unreasonable or unlawful conditions on canceling.
• Send reminders in certain cases. For subscriptions with an initial paid term of a year or longer that renew for six months or more, the notice must go out at least 15 and not more than 45 days before the cancellation deadline. For material changes, including price increases, notice is required at least five business days, and no more than 30 days, before the change. For free trials longer than a month, the notice comes at least three and not more than 21 days before the cancellation deadline. Notices must include instructions for canceling.
• Treat unrequested goods as a gift. If goods are shipped under a subscription without your affirmative consent, they are deemed an unconditional gift, with no obligation to pay for shipping them back.

Penalties and what you can get back

The adopted penalty chart (6 RCNY § 6-47) sets civil penalties of $525 for a first violation, $1,050 for a second, and $3,500 for a third and subsequent violation. A business found in violation is also liable for the amount it charged for the subscription after the consumer's first attempt to cancel. So the date you first tried to cancel matters: keep a record of it.

From October 1, DCWP says you can file a complaint through its online portal, 311, phone, mail, or fax, and it may assign a mediator to help resolve it.

Who is not covered

The rule lists several exemptions. As written, it does not apply to:

• services offered under a franchise issued by a political subdivision of New York State;
• entities regulated by the New York State Department of Financial Services, and their subsidiaries or affiliates;
• security-system alarm operators licensed by the state;
• banks, bank holding companies, their subsidiaries and affiliates, credit unions, and other financial institutions licensed under state or federal law; and
• sellers and administrators of service contracts as defined in New York's Insurance Law.

For a money-focused reader, the last point is the important one: recurring fees and services offered by banks, credit unions and other licensed financial institutions fall outside this particular rule. Whether a given product counts as one of these is a fact-specific question, so check with DCWP before assuming either way.

Where federal rules stand

At the federal level, the FTC finalized an amended "Negative Option Rule" in October 2024, but the U.S. Court of Appeals for the Eighth Circuit vacated it on July 8, 2025, finding the FTC had skipped a required preliminary regulatory analysis (Custom Communications, Inc. v. FTC). In March 2026 the FTC opened a new rulemaking by publishing an advance notice seeking public comment on whether and how to address negative-option practices. That is an early step, not a finished rule.

In the meantime, the FTC's own notice says its main tools are Section 5 of the FTC Act (unfair or deceptive practices) and the Restore Online Shoppers' Confidence Act (ROSCA), which it describes as the only federal law primarily designed for negative-option marketing but limited to online sales. DCWP's notice adds that several states, including California, Colorado, Illinois, Massachusetts, Minnesota and others, have their own click-to-cancel requirements, and that New York State law already requires businesses to offer a cancellation mechanism as easy as the one used to consent.

What to do with this

Whether or not you live in New York, the rule doubles as a test for any subscription:

1. Screenshot the terms before you sign up: price, frequency, and how to cancel.
2. Cancel the same way you joined, and save the confirmation. Note the date of your first attempt.
3. Watch for the reminder on annual plans and free trials. If none arrives, mention it in a complaint.
4. Complain to the right regulator if a company blocks you. In New York City that's DCWP starting October 1; elsewhere it may be your state attorney general or the FTC at ReportFraud.ftc.gov.

A company's cancellation process is one of the clearest transparency signals there is; it's the same lens we apply in how to tell if a money site is worth trusting. The same concern sits behind the FTC's Amazon Prime settlement, which followed allegations that people were enrolled without clear consent and found cancellation deliberately difficult.