NYC Click-to-Cancel Takes Effect Oct. 1
Sep 30, 2026New York City’s subscription cancellation rule becomes enforceable October 1, and consumers can begin filing complaints with the city.
New York City’s Click-to-Cancel rule takes effect Thursday, October 1. The Department of Consumer and Worker Protection adopted the rule earlier this year. Beginning October 1, businesses subject to the rule must comply, DCWP can enforce it, and consumers can begin filing complaints about subscription cancellation problems.
What takes effect October 1
The rule covers automatic-renewal and continuous-service offers to consumers. DCWP has said its authority extends to companies transacting with New York City residents, including businesses based outside the city.
Businesses must clearly disclose material subscription terms and provide a cancellation process that is as easy to use as the process used to provide consent. Cancellation also must be available through the same medium used for consent. DCWP gives a simple example: if a consumer can subscribe on a company’s website, the consumer must be able to cancel on the website.
The rule prohibits businesses from obstructing or unreasonably delaying cancellation. That includes hiding cancellation information, refusing to acknowledge a cancellation attempt or creating unreasonable barriers once a consumer tries to leave. Retention offers are still allowed, but they can’t be used to block or delay cancellation.
Beginning October 1, consumers can file complaints with DCWP online, through 311, by phone, mail or fax. The city points to problems such as consumers who signed up online but were forced to cancel another way, delayed cancellations, and missing renewal or subscription-change notices.
Enforcement begins, too
Civil penalties start at $525 for a first violation, rising to $1,050 for a second violation and $3,500 for third and subsequent violations.
If a business is found to have violated the rule, it can also be liable for charges made after the consumer’s first attempt to cancel.
DCWP has not announced a separate Click-to-Cancel grace period or said that it plans to focus first on particular industries or types of violations.
New York City adds another layer
New York City’s rule sits alongside existing New York State automatic-renewal requirements.
At the federal level, the FTC’s 2024 Click-to-Cancel rule was vacated in 2025, and no replacement nationwide rule has been finalized. Federal subscription enforcement has continued under existing laws, including the Restore Online Shoppers’ Confidence Act, or ROSCA, which the FTC has used in recent cases involving cancellation, consent and recurring charges.
INSIDER TAKE
Subscription businesses are facing closer scrutiny of how recurring offers are sold, renewed and cancelled.
The rules vary by jurisdiction, but regulators keep returning to many of the same issues: what consumers are told when they subscribe, what happens when an offer renews, and how easily they can leave.
New York City’s October 1 effective date adds another local rule to that broader pattern.
Related Member Resources
New York City’s rule takes effect within an existing state and federal framework. These briefs separate the three layers so operators can see which requirements come from the city, which apply statewide, and which federal rules remain in force.
- New York City Click-to-Cancel Brief
Updated for the October 1 effective date, this brief covers the city rule’s scope, cancellation requirements, notices, exemptions, penalties and restitution, DCWP complaints, New York State overlap and questions the city’s guidance does not yet fully answer.
- New York Automatic Renewal and Continuous Service Law Brief
New York State already regulates automatic-renewal and continuous-service offers. This brief gives operators the statewide requirements needed to understand where the New York City rule overlaps with state law and where the city adds its own requirements.
- Federal Online Subscription Enrollment, Consent, and Cancellation Brief
The FTC’s 2024 Click-to-Cancel rule was vacated, but federal subscription requirements remain. This brief explains the federal rules that continue to govern online enrollment, consent and cancellation, including the requirements operators still need to account for today.
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