NYC Click to Cancel Rule for Subscription Businesses
What New York City's cancellation rule means for your sign up pages, trial offers, renewal emails and save offers.
Key Takeaways
- The NYC Click to Cancel rule took effect October 1, 2026, and covers automatic renewals and memberships that continue until canceled.
- Show the price, billing frequency, cancellation deadline and how to cancel right next to the sign up button, before you ask for card details.
- Canceling must be as easy as signing up and available in every channel you use for sign ups, with an online option if people join in person.
- Renewal, free trial and price change notices each have their own timing windows, so build them into your email and text flows now.
On This Page
- Businesses the NYC Click to Cancel Rule Covers
- Sign Up Pages and Checkout
- Ads and Landing Pages With Trial Offers
- Cancellation Paths by Sign Up Channel
- Save Offers That Stay Within the Rule
- Renewal and Trial Reminders by Email and Text
- New York State Rules Also Apply
- Penalties and Refunds
- Funnel Audit Checklist
- Frequently Asked Questions
- Sources
The NYC Click to Cancel rule requires businesses that sell automatic renewals or ongoing memberships to New York City consumers to explain the terms before taking payment, let people cancel as easily as they signed up and send reminders before renewals, trial charges and price increases. It took effect on October 1, 2026 and is enforced by the Department of Consumer and Worker Protection, with penalties starting at $525 per violation plus refunds. For your marketing, the changes land on sign up pages, trial offers in ads, cancellation flows and the emails and texts you send before a charge. This article explains the rule for marketing planning and isn't legal advice, so have your attorney review your terms.
Businesses the NYC Click to Cancel Rule Covers
The rule applies to 2 kinds of offers. An automatic renewal is a paid subscription that renews at the end of a set term for another term, such as an annual membership. A continuous service keeps going until the customer cancels, such as a monthly gym membership or a software plan.
That covers most gyms and studios, medspa memberships, salons with monthly plans, meal kits and subscription boxes, software, online courses and any service sold on a recurring plan. The rule exempts a short list of businesses.
| Exempt under the rule | Example |
|---|---|
| Services under a franchise from a New York State political subdivision | Cable television |
| Entities regulated by the Department of Financial Services | Insurers |
| Licensed security alarm operators | Home alarm monitoring |
| Banks, credit unions and other licensed financial institutions | Bank account services |
| Sellers and administrators of service contracts | Extended warranties |
Sign Up Pages and Checkout
Before you ask for consent or billing information, the rule requires you to show the material terms clearly and close to the consent request. That means the product or service, the amount you'll charge, how often, the deadline to cancel and how to cancel. If the offer starts with a free trial, a gift or a temporary price, you also have to explain when the price changes and what the customer will pay afterward.
Your sign up page is where most of your marketing ends up, as our guide to your website at the center of your marketing explains, so this is the page to get right first. Put a short terms box directly above or beside the button that takes payment. Here's an example for a studio:
Your first 14 days are free. On June 15 we'll charge $129, then $129 every month until you cancel. Cancel any time before June 14 in your account under Membership, or at the front desk.
Keep the terms in plain sentences at the same size as the rest of the checkout. Terms hidden behind a link or set in small gray text are hard to defend as clear and conspicuous. The rule also expects affirmative consent, and an unticked checkbox or a button that names the recurring charge is the simplest way to show it.
Ads and Landing Pages With Trial Offers
The disclosure duty applies at the point where you ask for consent or payment, so your landing page and checkout carry most of the weight. Your ads still shape what people expect. An ad that promises a free trial should lead to a page where the trial length, the price after the trial and the cancellation deadline appear before the payment step, worded the same way as the ad.
If you run intro offers for a studio or gym, the offer types in our guide to fitness studio intro offers still work. A paid intro pack that doesn't renew sits outside this rule, while a free week that rolls into a monthly membership needs the full set of disclosures and notices.
Cancellation Paths by Sign Up Channel
Customers must be able to cancel at any time, using a method as easy as the one they used to sign up and in the same medium. You have to offer cancellation in every channel you use to sign people up.
| How the customer signed up | Cancellation you need to offer |
|---|---|
| On your website or app | Online cancellation that's as easy as sign up |
| By phone | Phone cancellation without hang-ups or unreasonable delays |
| In person at your location | In-person cancellation where practical, plus an online option such as your website or email |
| Through several channels | Cancellation in each of them |
The rule also bans tactics that make canceling harder, including hanging up on callers, hiding how to cancel, refusing to acknowledge a request and misrepresenting the cost or consequences of leaving. If you charge someone after their first cancellation attempt, you owe that money back.
Save Offers That Stay Within the Rule
You can still present a discount, a pause option or information about what the customer loses after they ask to cancel. The rule allows that as long as the offer doesn't add unreasonable conditions, obstruct the cancellation or unreasonably delay it.
A workable design is one screen after the cancel button with a single retention offer and a clearly visible button to finish canceling. A phone script can include one offer, and the cancellation goes through if the customer says no. Multiple screens of offers, a required call to a retention team or a survey the customer must complete before canceling are the patterns that put you at risk.
Renewal and Trial Reminders by Email and Text
There are 3 kinds of notices with fixed timing windows. Each one goes through the channel the customer chose, such as email, text or an app notification. Every notice must include cancellation instructions.
| Notice | When it applies | When to send it |
|---|---|---|
| Renewal reminder | First paid term of 1 year or longer that renews for 6 months or longer | 15 to 45 days before the cancellation deadline |
| Free trial reminder | Free gift or trial longer than 1 month, followed by a charge | 3 to 21 days before the cancellation deadline for the first charge |
| Price or terms change | Any material change, including a price increase | 5 business days to 30 days before the change |
Set these up as automated flows in your email or text platform, triggered by each customer's renewal or trial date, and keep a log of what was sent. A monthly membership that just keeps renewing doesn't get the renewal reminder, but it does need the price change notice before any increase. If you want help building the flows, our email and SMS marketing team sets these up, and as a digital marketing agency in New York City we work under the same city rules.
New York State Rules Also Apply
New York State's automatic renewal law, General Business Law section 527-a, sets similar requirements for businesses selling to New York consumers, including clear terms before consent, a simple cancellation method and the same reminder windows. A few state rules go further than the city rule.
| Requirement | NYC rule | New York State law |
|---|---|---|
| Confirmation after sign up | Not specified | A notice the customer can keep, with terms and how to cancel |
| Customers who signed up in person | In person where practical, plus online | An online option or a phone number, where practical |
| Price increases | Notice 5 business days to 30 days ahead | New consent, or a chance to cancel within 14 days of the charge with a prorated refund |
| Enforced by | NYC Department of Consumer and Worker Protection | New York Attorney General |
If you sell to customers in the city, design your sign up and cancellation flow to meet both.
Penalties and Refunds
| Violation | NYC civil penalty |
|---|---|
| First | $525 |
| Second | $1,050 |
| Third and later | $3,500 |
On top of penalties, you owe customers whatever you charged them after their first attempt to cancel. Goods you send without the customer's affirmative consent count as an unconditional gift, and the city's guidance says you can't charge customers to ship back items they received for free.
Funnel Audit Checklist
- Every sign up page shows price, billing frequency, cancellation deadline and how to cancel before payment details
- Trial and intro price offers say when the price changes and what it changes to
- Consent is an unticked checkbox or a clearly labeled button
- Ads with trial offers match the terms on the landing page
- Customers who signed up online can cancel online, and customers who signed up in person can cancel in person where practical plus online or by email
- The cancellation flow has a visible way to finish canceling, with one save offer at most (our recommendation)
- Renewal, trial and price change reminders are automated with the right timing
- Each reminder includes cancellation instructions
- Billing stops on the date of the first cancellation request
Frequently Asked Questions
When did the NYC Click to Cancel rule take effect?
October 1, 2026. The Department of Consumer and Worker Protection enforces it.
Can I still offer a discount when someone tries to cancel?
Yes. You can show a discount, a pause or information about the effect of canceling after the customer asks to cancel, as long as it doesn't obstruct or delay the cancellation.
Do monthly memberships need renewal reminders?
The 15 to 45 day renewal reminder applies to first terms of 1 year or longer that renew for 6 months or longer. Monthly memberships still need notice before a price increase, and free trials longer than 1 month need a reminder before the first charge.
What's the penalty for breaking the NYC Click to Cancel rule?
Civil penalties are $525 for a first violation, $1,050 for a second and $3,500 for each one after that, plus refunds of anything charged after the customer's first cancellation attempt.
Does the rule apply if my business is outside New York City?
The rule is a New York City rule. If you sell subscriptions to consumers in the city, ask your attorney whether it applies to you, and remember that New York State's automatic renewal law covers sales to New York consumers statewide.
Sources
- Click to Cancel, NYC Department of Consumer and Worker Protection nyc.gov
- Notice of Adoption of Final Rule, Click to Cancel, 6 RCNY sections 5-110 to 5-110.3 nyc.gov
- New York General Business Law section 527-a, New York State Senate nysenate.gov
Keep Subscribers Without Making Them Fight to Leave
Request a free proposal and we'll review your sign up and retention flows with you.