New regulation mandates that cancelling a subscription must be as easy as signing up, with civil penalties for non-compliant businesses.
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The FTC's previous attempt at a national Click-to-Cancel rule was vacated by the 8th Circuit Court of Appeals in July 2025 due to procedural issues regarding economic impact analysis.
New York City's Click-to-Cancel rule is now in force. It gives the city power to penalise any business that makes cancelling a subscription harder than signing up for one. The Department of Consumer and Worker Protection (DCWP) began enforcing it on October 1. It covers auto-renewing plans of every kind, from Netflix, Amazon Prime and Disney+ to gym memberships. Companies that break it face civil penalties starting at $525 per violation and may have to refund customers. New York is the first city in the US to adopt such a rule. It comes just over a year after a near-identical federal version was struck down days before it was due to take effect. Industry groups representing Comcast, Disney and Warner Bros. Discovery had challenged that one in court. "If a company can take your money with one click, you should be able to get your money back with one click," Mayor Zohran Mamdani said. Under the rule, businesses must clearly explain subscription terms, disclose that a plan will renew automatically and tell customers when those terms change. Most importantly, cancelling has to work the same way as signing up. Someone who subscribed online cannot be pushed into calling a helpline or walking into a store to quit. Free trials that quietly turn into paid plans are also targeted, and companies can no longer ask people to pay for returning items they received for free. "No one should need 45 minutes of hold music to stop paying for something they never wanted," Mamdani said.
Alongside the rule, the city has opened a complaint portal at nyc.gov/click-to-cancel. The Office of Technology and Innovation's Public Interest Technology (PIT) Crew built it in 10 weeks, and it works in every major language spoken in the city. Complaints can also be sent by mail or fax. Each filer gets a complaint number to track progress, and in many cases a DCWP mediator will work with both the customer and the business to settle the matter. The Roosevelt Institute estimates the rule could save New Yorkers between $21.5 million and $162.5 million a year.
The Federal Trade Commission (FTC), then led by Lina Khan, finalised its national rule in October 2024. In July 2025, the 8th Circuit Court of Appeals vacated it on procedural grounds. The court ruled that the agency should have prepared a preliminary regulatory analysis for a rule with over $100 million in annual economic impact. Khan now advises Mamdani. The FTC sought public input in March on reviving parts of the rule, but there is no timeline yet. Meanwhile, complaints to the agency about hard-to-cancel plans rose to nearly 70 a day in 2024, up from 42 a day in 2021. More than half of US states already regulate auto-renewals, and New York state requires cancelling to be as easy as signing up. What changes now is that the city can enforce those protections on its own. The companies that sank the federal rule now have to answer to it in the country's largest city.
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