On January 5, 2026, NYC Mayor Zohran Mamdani signed two executive orders (EOs) aimed at (1) hidden “junk fees” and (2) “subscription tricks and traps,” alongside New York City Department of Consumer and Worker Protection (DCWP) Commissioner Sam Levine, New York Attorney General (NY AG) Letitia James, and City Council Member Julie Menin. DCWP said it will begin outreach to businesses and “signal immediate consequences” tied to compliance with existing city law.

The City’s announcement frames this as an enforcement push against practices that can distort the “true price” or lock consumers into recurring charges they did not knowingly accept—or cannot easily exit.

What the executive orders do (and why both matter for subscriptions)

Executive Order (EO) No. 10 — Fighting “Subscription Tricks and Traps”
EO 10 directs DCWP to prioritize monitoring, investigating, and taking enforcement action against subscription practices that deceive or mislead consumers. It specifically flags conduct such as enrolling consumers into subscriptions, misrepresenting or failing to disclose pricing or renewal terms, and making cancellation difficult when those practices violate existing law. EO 10 also directs DCWP to:

• Consider “appropriate actions,” including rulemaking under its authority, to combat subscription tricks and traps;

• Make recommendations to the City Council for additional consumer protections, resources, or authority, as appropriate; and

• Coordinate, as appropriate, with the NYC Law Department and the New York Attorney General (NY AG).

In the Mayor’s Office and DCWP announcement materials, the City highlighted examples of the subscription practices it intends to target, including free trials that auto-convert with disclosures buried, fees added after payment information is collected, subscriptions disguised as one-time purchases, bundles that obscure recurring charges, and cancellation flows designed to create friction (limited hours, credential requirements, or multi-screen steps).

Executive Order (EO) No. 9 — Combating Hidden Junk Fees
EO 9 creates a Citywide Junk Fee Task Force (chaired by Deputy Mayor Julie Su and DCWP Commissioner Sam Levine) and directs DCWP to intensify its approach to fee transparency. The order directs DCWP to consider actions to crack down on deceptive or hidden fees and to monitor, investigate, and enforce violations, including through potential new rules designed to address hidden junk fees.

Important clarification:
This is not instantly a “new city subscription law”

A key point for operators: an executive order is not the same thing as a new City Council statute. These orders direct DCWP to use existing authority now and to pursue next steps through rulemaking and legislative recommendations, rather than creating an entirely new subscription code overnight.

In fact, both the Mayor and the DCWP Commissioner emphasize that much of the targeted conduct is already illegal under existing authority—and that enforcement actions can proceed now.

The legal hook NYC is leaning on

NYC already prohibits “deceptive or unconscionable trade practices” in the sale or offering of consumer goods or services.

The definitions in NYC’s Consumer Protection Law are meaningful for subscription businesses because:

• “Consumer goods/services” are those primarily for personal, household, or family purposes; and

• “Merchant” includes entities that make goods/services available directly or indirectly—language that can matter for bundles, partnerships, and distributed offers.

DCWP also maintains penalty schedules for Consumer Protection Law violations, with escalating amounts depending on the nature of the violation and enforcement posture.

INSIDER TAKE

For subscription leaders, the most practical signal here is not “NYC passed a new subscription statute today,” but rather: NYC is operationalizing subscription and fee transparency as an enforcement priority, immediately. EO 10’s explicit focus on enrollment, pricing, and disclosure of renewal terms and cancellation friction is a clear signal that subscriber-flow execution—not just policy language—is the enforcement battleground. The Mayor’s office says DCWP will begin business outreach and “signal immediate consequences,” and Commissioner Levine’s remarks reinforce the posture: businesses should not “wait for a subpoena” to correct practices the agency views as illegal traps or hidden fees.

Where teams get surprised is not usually a deliberate decision to “trick” customers—it’s experience drift: marketing pages, checkout, and cancellation flows evolve quickly, and disclosure clarity (and consumer comprehension) falls behind. NYC’s examples map directly to common subscription growth patterns: trial-to-paid conversion design, post-card-entry add-ons, bundling, and cancellation friction. That combination, defined examples plus an enforcement-forward regulator, is what raises near-term risk for any subscription business serving NYC consumers.