On July 10, 2026, the New York City Department of Consumer and Worker Protection announced the adoption of its “Click-to-Cancel” rule requiring businesses to provide consumers with streamlined methods for canceling subscriptions. The rule, which takes effect October 1, 2026, treats noncompliant automatic-renewal and continuous-service practices as deceptive and unconscionable trade practices under the New York City Consumer Protection Law.
The rule applies broadly to subscriptions for goods or services, although it exempts banks, credit unions, certain other regulated financial institutions, New York Department of Financial Services-regulated entities, and several additional categories of businesses. Specifically, the rule requires covered businesses to:
- Clearly disclose subscription terms. Before obtaining consent or billing information, businesses must disclose material terms, including the product or service, charges, billing frequency, cancellation deadline, and available cancellation methods.
- Make cancellation as easy as enrollment. Consumers must be able to cancel at any time through a mechanism that is as easy to use, and through the same medium, as the method used to enroll.
- Avoid obstructing cancellation. Businesses may not impose unreasonable conditions, obscure cancellation instructions, misrepresent the consequences of cancellation, or unreasonably delay a cancellation request.
- Provide advance notices. The rule establishes notice requirements for certain long-term renewals, material changes and price increases, and free trials lasting more than one month.
- Provide restitution following attempted cancellation. A business found to have violated the rule may be liable for amounts charged after the consumer’s first cancellation attempt.
Putting It Into Practice: The final rule follows the Mayor’s January 2026 executive orders directing DCWP to address junk fees and subscription practices (previously discussed here). The rule signals that New York City is placing greater enforcement emphasis on subscription disclosures, renewal practices, cancellation methods, and other recurring-payment issues. Covered businesses serving New York City consumers should review enrollment interfaces, cancellation pathways, renewal notices, free-trial disclosures, and retention offers before October 1, assess whether an exemption applies, and update compliance procedures as necessary.