New York automatic renewal law
New York General Business Law §§ 527 and 527-a after the November 5, 2025 rewrite — the disclosure with a deadline to act, consent, price-increase consent or refund, the notices, and cancellation as easy as sign-up, with every requirement cited.
New York's automatic renewal law, General Business Law §§ 527 and 527-a, was rewritten effective November 5, 2025. It covers automatic renewal and continuous service offers to New York consumers and is enforced by the Attorney General with civil penalties.
New York Automatic Renewal Law (Prohibited Service Offer Practices) — N.Y. Gen. Bus. Law §§ 527, 527-a (Art. 29-BB). Effective 2021-02-09. Status: in force. Source: https://www.nysenate.gov/legislation/laws/GBS/527-A
Material terms disclosed before consent or billing information; affirmative consent; consent or a refund right for price increases; prompt retainable post-consent notice; cancellation as easy as sign-up, in the same medium and every consent medium; no obstruction; 15-45 day renewal notice (1-year terms renewing for 6+ months); 5 business day-30 day material-change notice; 3-21 day trial notice (trials over a month). AG enforcement; civil penalties $100-$1,000.
Scope: Consumers (personal, family or household purposes; definitions in § 527). Exempt (§ 527-a(4)): services under a municipal franchise, DFS-regulated entities, security alarm operators, banks/credit unions/financial institutions, and service contract sellers and administrators (Ins. Law § 7902). Related but not cataloged: GBL § 5-903 (renewal notice for service, maintenance or repair contracts for real or personal property).
- Amendment: L. 2023, ch. 728 (S5941-B), effective 2023-12-13: 15-45 day renewal notice for initial paid terms of one year or longer.
- Amendment: L. 2025, ch. 58, Part W (S.3008-C/A.3008-C), effective 2025-11-05: Comprehensive rewrite of § 527-a (see file header).
What changed in 2025
- The sign-up disclosure must include the deadline to act to stop further charges (by date or frequency) and the cancellation mechanisms, before consent or billing information is requested (§ 527-a(1)(a)).
- Price increases need the subscriber's affirmative consent, or a right to cancel within at least 14 days after the higher charge with a pro-rata refund (§ 527-a(1)(b-1)).
- The post-consent notice must include the terms, the charges, their frequency, the deadline to act and the cancellation mechanisms (§ 527-a(1)(c)).
- Cancellation as easy as sign-up, in the same medium and in every medium in which consent can be given; no obstruction, false information or unreasonable delay (§ 527-a(1)(d), (d-1), (e)).
- Notices of material changes, including price increases, at least 5 business days and no more than 30 days before the change (§ 527-a(1)(g)), and trial notices 3 to 21 days before the cancellation deadline for trials longer than a month (§ 527-a(1)(h)).
The 15-to-45-day renewal notice for initial paid terms of one year or longer has applied since December 13, 2023 (§ 527-a(1)(f)).
"In the manner the consumer selected"
New York's renewal, trial and change notices go out "in the manner the consumer selected" — text, email, app notification or another channel you offer. A template cannot show that, so Checkbox asks: the compliance plan includes a question for the human (attest_ny_notice_channel), and the reminder checks stay needs_review in New York until it is answered. The same applies to the price-increase consent or refund right (attest_ny_price_increase), which no notice can provide by itself.
Every New York requirement in the catalog
| Requirement | Citation | Applies when | Timing | Severity | Checkbox checks |
|---|---|---|---|---|---|
| Disclose the material terms before consent or billing information is requested, next to the consent request Present, clearly and conspicuously, the material terms of the offer — including a description of the product or service subject to renewal, the amount that will be charged, the frequency of charges, the deadline (by date or frequency) by which the consumer must act to stop further charges, and the cancellation mechanisms — before consent to the offer or billing information is requested, and in visual proximity (for voice offers, temporal proximity) to the request for consent. | N.Y. Gen. Bus. Law § 527-a(1)(a); § 527(2) | always | — | critical | signup.disclosure.autorenew_language, signup.disclosure.price, signup.disclosure.frequency, signup.disclosure.cancellation_policy, signup.disclosure.term_length, signup.disclosure.proximity, signup.disclosure.conspicuous |
| Explain how and when a trial or temporary price changes, and the later price If the offer includes a free gift or trial, or the price is temporary, clearly and conspicuously explain how and when the price will change and the price or prices that will subsequently be charged. | N.Y. Gen. Bus. Law § 527-a(1)(a) (second sentence) | free trial | — | critical | signup.disclosure.trial_terms, signup.disclosure.price |
| Obtain affirmative consent before charging for the initial term Do not charge the consumer or the consumer's account with a third party for the initial term of an automatic renewal or continuous service without first obtaining the consumer's affirmative consent to the agreement containing the renewal terms, including terms offered at a promotional or discounted price for a limited time. | N.Y. Gen. Bus. Law § 527-a(1)(b) | always | — | critical | signup.consent.affirmative, signup.consent.not_prechecked |
| Price increases need consent, or a post-charge cancellation right with a pro-rata refund Before charging an increased price (or a price higher than the one disclosed at sign-up), either obtain the consumer's affirmative consent to the increased price, or let the consumer cancel at any time within at least fourteen days after that charge and refund the price of the remaining term on a pro-rata basis. Consent is required only once per increase. | N.Y. Gen. Bus. Law § 527-a(1)(b-1) | always | — | high | reminder.price_change |
| Send a retainable notice promptly after consent with the terms, charges, deadline and cancellation mechanisms Promptly after the consumer consents, provide a notice the consumer can retain that includes: the terms of the agreement; the amount that will be charged; the frequency of charges; the deadline (by date or frequency) by which the consumer must act to stop further charges (for a trial, the date to cancel before the first charge); and the cancellation mechanisms. | N.Y. Gen. Bus. Law § 527-a(1)(c) | always | — | high | confirmation.email.sent, confirmation.email.terms, confirmation.email.cancellation_instructions, confirmation.email.trial_terms |
| Cancellation as easy as sign-up, in the same medium Give the consumer the option to cancel at any time using a simple cancellation mechanism that is as easy to use as the mechanism used to consent and that is available through the same medium the consumer used to consent (an online sign-up must be cancellable online). | N.Y. Gen. Bus. Law § 527-a(1)(d) | always | — | critical | cancel.online_available, cancel.mechanism_findable, cancel.flow_friction, config.portal_cancel_enabled |
| Cancellation through every medium in which consent can be given Allow cancellation at any time through all mediums by which the business allows consumers to consent to the automatic renewal, continuous service or any price increase. Where consent was obtained in person, in addition to an in-person method where practical, offer cancellation online or by telephone. | N.Y. Gen. Bus. Law § 527-a(1)(d-1) | always | — | high | cancel.online_available, cancel.mechanism_findable |
| Do not obstruct, condition, ignore or unreasonably delay cancellation Do not impose unreasonable or unlawful conditions on, refuse to acknowledge, obstruct, or unreasonably delay a cancellation request or attempt — e.g. hanging up on callers, giving false information about how to cancel, misrepresenting the consequences or costs of cancelling, or misrepresenting the reasons for processing delays. Discount/retention offers or information about the effect of cancelling are allowed only if they do not obstruct or unreasonably delay the cancellation. | N.Y. Gen. Bus. Law § 527-a(1)(e) | always | — | high | cancel.flow_friction, cancel.confirmation |
| Renewal notice for initial paid terms of one year or longer For an initial paid term of one year or longer that renews for a paid term of six months or longer, notify the consumer of the renewal charge 15 to 45 days before the cancellation deadline, in the manner the consumer selected (text, email, app notification or any other channel the business offers), with instructions on how to cancel. | N.Y. Gen. Bus. Law § 527-a(1)(f) | term ≥ 12 months | 15-45 days before the cancellation deadline | high | reminder.annual_renewal |
| Notice of material changes, including price increases, 5 business days to 30 days in advance Give consumers a clear and conspicuous notice of any material change to the terms, including any price increase, at least five business days and no more than thirty days before the change, through the consumer-selected channel used for renewal notices. | N.Y. Gen. Bus. Law § 527-a(1)(g) | always | 7-30 days before the price change | high | reminder.price_change |
| Notice before a free gift or trial of more than a month converts to paid If the offer includes a free gift or trial for more than a month followed by an automatic charge, notify the consumer 3 to 21 days before the cancellation deadline for the first chargeable period, in the manner the consumer selected (text, email, app notification or another channel offered), with instructions on how to cancel. | N.Y. Gen. Bus. Law § 527-a(1)(h) | free trial, trial ≥ 31 days | 3-21 days before the cancellation deadline | high | reminder.trial_ending, config.trial_reminder_enabled |
New York City
New York City "Click to Cancel" Rule (DCWP) — 6 RCNY § 5-110.1. Effective 2026-10-01. Status: not cataloged. Source: https://www.nyc.gov/site/dca/news/048-26/mamdani-administration-landmark-consumer-protection-rules-ban-subscription-traps-and
City-level rule mirroring GBL § 527-a with a stricter in-person rule (online cancellation option required), detailed unreasonable-barrier examples, and municipal penalties. Applies to New York City consumers only. Not evaluated: the rule text has not been verified against the City Record, and the jurisdiction model cannot scope it to NYC consumers (attaching it to every US-NY finding would cite an unconfirmed legal basis). Kept in PENDING_VERIFICATION_REQUIREMENTS.
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