New York City's Click-to-Cancel Law Takes Effect October 1
A federal court killed the FTC's "click-to-cancel" rule six days before it would have applied nationwide. Fourteen months later, New York City is enforcing a version of it anyway — just for one city, starting in a little over two weeks.
On July 8, 2025, a federal appeals court vacated the FTC's click-to-cancel rule — the regulation that would have required any company letting you subscribe online to also let you cancel online, with no forced phone call or retention pitch in between. The rule was scheduled to start applying to businesses on July 14, 2025. The court's decision landed six days earlier. On October 1, 2026, a version of that same idea takes effect anyway. It just covers one city instead of the whole country, and the city got there first.
The rule that died six days early
The Eighth Circuit didn't strike down the FTC's 2024 Negative Option Rule because the agency lacked the authority to write it, or because reviewers disagreed with the substance. It vacated the entire rule on a procedural ground: the FTC had skipped a preliminary cost-benefit analysis that Section 22 of the FTC Act requires before this kind of rule can take effect. The rule itself wasn't found unreasonable — the process behind it was found incomplete, days before it would have started applying to every subscription business in the country.
The FTC has been trying to rebuild it since. It submitted a new draft Advance Notice of Proposed Rulemaking in early 2026 and formally opened it for public comment that March. An ANPRM is an early, exploratory step — the agency asking what a future rule should look like — not a finished regulation with an effective date. As of this writing, there is no federal click-to-cancel rule back in force, and no announced timeline for one.
New York City didn't wait
Mayor Zohran Mamdani and Department of Consumer and Worker Protection Commissioner Samuel A.A. Levine proposed the city's own Click to Cancel rule on April 8, 2026, ran a public comment period, and adopted the final version on July 10, 2026 — becoming, per the city's own announcement, the first municipality in the country to write this kind of rule into local law. "The Mamdani Administration is shutting the door on the era of fleecing New Yorkers with junk fees and subscription traps," Levine said at the announcement. The rule takes effect October 1, 2026.
| Date | What happened |
|---|---|
| Jul 8, 2025 | Eighth Circuit vacates the FTC's click-to-cancel rule, 6 days before its effective date |
| Early 2026 | FTC submits a draft ANPRM to begin rebuilding a federal rule |
| Apr 8, 2026 | NYC proposes its own Click to Cancel rule |
| Jul 10, 2026 | NYC adopts the final rule |
| Oct 1, 2026 | NYC's rule takes effect |
Source: Latham & Watkins, Kirkland & Ellis, NYC Mayor's Office, Jul 2025–Jul 2026.
What actually changes on October 1
Under the rule as published by DCWP, any business that lets a New York City consumer sign up for a subscription — streaming, software, a gym, a meal kit, anything billed on autopilot — has to disclose the price, the billing frequency, the cancellation deadline, and how to cancel, before it takes their payment details or their consent. And it has to let them cancel the same way they signed up: subscribe online, and the company can't require a phone call, a mailed letter, or a conversation with a retention agent to get out.
DCWP enforces it, and the penalties aren't token amounts. Under the adopted rule text, civil penalties are tiered — $525 for a first violation, $1,050 for a second, and $3,500 for a third or later one — and a business that keeps charging someone after their first cancellation attempt owes that money back on top of the fine. Each deceptive statement or omission can count as its own violation, which is how a single bad cancellation flow can rack up more than one penalty at a time.
Not every subscription, and not only New York
Some categories are carved out: banks, credit unions, and other businesses already overseen by the New York Department of Financial Services fall outside this particular rule, since they answer to their own regulator instead.
But the rule applies based on where the customer is, not where the company is headquartered — a subscription business based in California, Texas, or anywhere else has to comply the moment it has a New York City subscriber. Building a cancellation flow that only shows up for New York City IP addresses is possible, but it's rarely worth the engineering effort next to just building one compliant flow and using it everywhere. That's the quiet mechanism by which a rule this specific can end up changing a cancel button used well outside city limits.
What to actually do about it
If you're a New York City resident, you'll be able to file a complaint with DCWP starting October 1 if a company doesn't comply — worth knowing the next time a subscription makes leaving harder than joining was. If you're not, there's nothing to act on directly here; this is regulation working on companies, not a deadline attached to your own accounts.
It's still a reasonable prompt to look at whatever you've been avoiding cancelling because the process is annoying enough to keep putting off — the exact behavior this rule and its federal predecessor were both written to stop being profitable. A rule that fixes the mechanism for future signups doesn't retroactively fix the one you're already stuck in.
Skip waiting on a compliant cancel button
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