New York City's new Click-to-Cancel rule took effect on 1 October 2026, requiring covered businesses to make cancelling qualifying subscriptions as easy as signing up.
The city also launched a complaint portal that Department of Consumer and Worker Protection Commissioner Samuel A.A. Levine told The Verge would connect complainants with actual people rather than divert them into a 'chatbot doom loop'.
The rule applies to automatic-renewal and continuous-service subscriptions. It requires clear disclosures and straightforward cancellation methods while giving the Department of Consumer and Worker Protection (DCWP) citywide authority to enforce the requirements.
Cancelling Should Be as Easy as Signing Up
Businesses must clearly disclose material subscription terms before obtaining consent. These include the product or service, the amount and frequency of charges, the deadline for stopping future charges and the available cancellation methods.
Consumers must be able to cancel at any time through a simple mechanism that is as easy to use as the one used to provide consent and through the same medium. Businesses must also offer cancellation through every medium they allow consumers to use when giving affirmative consent.
That means a company that allows customers to subscribe online cannot require them to telephone or visit a physical location simply to cancel. If consent was obtained in person, the business must also offer an online cancellation mechanism, such as a website or email. A similar in-person cancellation method must also be offered where practical.
The rule prohibits businesses from obstructing or unreasonably delaying cancellation. Examples include hanging up on consumers, providing false information about how to cancel and misrepresenting the consequences or costs of cancellation.
Longer-term subscriptions can also trigger renewal notices.
An initial paid term of at least one year that renews for at least six months requires notice 15 to 45 days before the cancellation deadline. Free gifts or trials lasting more than a month can trigger a separate notice three to 21 days before the deadline for the first chargeable period.
A business found to have violated the rule can be liable for the amount charged after a consumer's first attempt to cancel. Civil penalties are $525 for a first violation, $1,050 for a second and $3,500 for a third or subsequent violation.
Exemptions include certain services provided by businesses or affiliates operating under a franchise issued by a political subdivision of New York State, entities regulated by the New York State Department of Financial Services, licensed security-system alarm operators, banks and other specified financial institutions, and sellers or administrators of certain service contracts.
New York City says it is the first US municipality to implement a Click-to-Cancel rule.
The Roosevelt Institute estimated that the measure could deliver between $21.5 million and $162.5 million in annual economic benefits to adult New Yorkers through time saved and, in some cases, subscription fees avoided.
Those figures are projections, not recorded savings.
No More 'Chatbot Doom Loops'
The rule took effect alongside a new complaint portal built in 10 weeks by the Office of Technology and Innovation's Public Interest Technology Crew in partnership with DCWP.
Consumers can report unclear subscription terms, delayed cancellations, undisclosed automatic renewals or unnecessarily difficult cancellation processes. After a complaint is filed, DCWP may seek more information. In many cases, a mediator will work with the consumer and business to try to resolve the dispute.
The Verge reported that DCWP may also try to help consumers cancel subscriptions or recover money. A pattern of noncompliance at a business could lead to further investigation or legal action.
Levine told The Verge that when people submit complaints, 'they're not going to be diverted into a chatbot doom loop. We're going to have actual people whose full-time job is to help them.'
The distinction is important.
The rule does not ban businesses from using chatbots. Levine's 'doom loop' comment describes how the city says complaints submitted through its own portal will be handled.
NYC Rule Follows Vacated Federal Effort
New York City's action comes after a similar federal effort was vacated.
The Federal Trade Commission finalised amendments to its Negative Option Rule in 2024, including a nationwide requirement for a simple cancellation mechanism.
On 8 July 2025, the US Court of Appeals for the Eighth Circuit vacated the amended rule after finding that the FTC failed to issue a required preliminary regulatory analysis once the rule's estimated annual economic impact was found to exceed the statutory $100 million threshold.
The court vacated the federal rule on procedural grounds and did not reach the petitioners' remaining substantive challenges.
In March 2026, the FTC issued an Advance Notice of Proposed Rulemaking seeking public comment on whether and how the existing Negative Option Rule should be amended. One option was adopting provisions from the vacated 2024 rule.
New York State already requires a simple cancellation mechanism that is as easy to use as the method used to provide consent and operates through the same medium. State law also prohibits businesses from obstructing or unreasonably delaying cancellation.
The city's rule substantially overlaps with those state protections but gives DCWP its own municipal enforcement framework, including restitution provisions, civil penalties and a city complaint portal.
For consumers, the practical standard is straightforward: if a covered business lets you sign up online, it should not force you to make a phone call or visit in person just to cancel.
