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New York City Click to Cancel rule

New York City's DCWP "Click to Cancel" rule (6 RCNY §§ 5-110 to 5-110.3, effective October 1, 2026) for subscription businesses: 8 cited requirements, notice windows, refunds and penalties. Generated from Checkbox's legal catalog; pending attorney review.

At a glance

Applies toConsumers in New York City (in addition to New York State law)
LawsNew York City "Click to Cancel" Rule (DCWP)
Effective2026-10-01
StatusIn force
Requirements in the catalog8 (3 with a notice window)
Private right of actionpublic enforcement only
Last reviewed2026-10-31

New York State law applies too: see New York. Federal law applies everywhere: see federal subscription law.

The law

New York City "Click to Cancel" Rule (DCWP)

  • Citation: 6 RCNY §§ 5-110 to 5-110.3
  • Effective: 2026-10-01
  • Status: In force
  • Verified: 2026-10-31, official text read in full (confidence: medium)

City rule mirroring GBL § 527-a: material terms (including the deadline to act) before consent or billing information; cancellation as easy as consent, in the same medium and every consent medium, with an online option (website or email) for in-person sign-ups; no obstruction or unreasonable save offers; 15-45 day renewal notice (initial term of one year or more renewing for six months or more) and 3-21 day trial notice (trials over a month) in the consumer-selected channel; 5 business day-30 day material-change notice. Violators refund every amount charged after the first cancellation attempt (§ 5-110.2); DCWP penalties $525 / $1,050 / $3,500. Evaluated under US-NY (the jurisdiction model has no city level).

Scope: New York City consumers. Exempt (§ 5-110.3): municipal franchise holders (e.g. cable), DFS-regulated entities, licensed alarm operators, banks and licensed financial institutions, and service-contract sellers. Territorial reach and interaction with state AG enforcement are open question 9 (hence medium confidence).

AmendmentEffectiveChange
DCWP Notice of Adoption (proposed Apr. 8, 2026; hearing May 8, 2026; adopted July 10, 2026)2026-10-01Adds 6 RCNY Part 8 "Click to Cancel" (§§ 5-110 to 5-110.3).

Requirements

Each row is one obligation in the catalog, in plain English, with the provision it comes from. "Applies when" lists the conditions under which it applies (otherwise it always applies to covered offers). The ids are stable and match the dataset and Checkbox API results.

At sign-up

RequirementApplies whenEffectiveCitation
NYC: disclose the material terms before consent or billing information, next to the consent request Before requesting consent or billing information, clearly and conspicuously disclose the material terms — the product, the amount and frequency of charges, the deadline (by date or frequency) by which the consumer must act to stop further charges, how to cancel, and any trial or temporary-price terms — in visual proximity to the request for consent.
US-NY.NYC.6RCNY5-110.1.b
always2026-10-016 RCNY § 5-110.1(b)

Before charges (notices and reminders)

RequirementApplies whenEffectiveCitation
NYC: renewal notice 15-45 days before the cancellation deadline for one-year-plus terms Where the initial paid term is one year or longer and the plan renews for a paid term of six months or longer, notify the consumer 15 to 45 days before the cancellation deadline, in the manner the consumer selected (text, email, app notification or another channel offered), with instructions on how to cancel.
US-NY.NYC.6RCNY5-110.1.g
term ≥ 12 months2026-10-016 RCNY § 5-110.1(g)
NYC: notice of material changes, including price increases, 5 business days to 30 days in advance Give the consumer a clear and conspicuous notice of any material change to the terms, including a price increase, at least five business days and no more than thirty days before the change, in the manner the consumer selected.
US-NY.NYC.6RCNY5-110.1.h
always2026-10-016 RCNY § 5-110.1(h)
NYC: notice 3-21 days before a free trial of more than a month converts to paid If a free gift or trial lasts more than a month and is 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, with instructions on how to cancel.
US-NY.NYC.6RCNY5-110.1.i
free trial, trial ≥ 31 days2026-10-016 RCNY § 5-110.1(i)

Cancelling

RequirementApplies whenEffectiveCitation
NYC: cancellation as easy to use as the consent mechanism, in the same medium Provide a cancellation mechanism that is as easy to use as the mechanism the consumer used to consent and that is available through the same medium (an online sign-up must be cancellable online).
US-NY.NYC.6RCNY5-110.1.c
always2026-10-016 RCNY § 5-110.1(c)
NYC: offer online cancellation (website or email) for in-person sign-ups Allow cancellation through every medium in which consent can be given. Where consent was obtained in person, also offer an online cancellation mechanism (website or email) — a telephone line alone is not enough (state law allows online or phone).
US-NY.NYC.6RCNY5-110.1.d
always2026-10-016 RCNY § 5-110.1(d)
NYC: do not obstruct, ignore or unreasonably delay cancellation (save offers included) Do not obscure cancellation instructions, hang up on consumers, refuse to acknowledge a cancellation request or unreasonably delay processing it; save (retention) offers are allowed only if they do not impose unreasonable conditions on, or unreasonably delay, the cancellation (§ 5-110.1(e)(2)).
US-NY.NYC.6RCNY5-110.1.e
always2026-10-016 RCNY § 5-110.1(e)
NYC: refund everything charged after the consumer's first attempt to cancel A business that violates the rule must refund every amount charged after the consumer's first attempt at cancellation. Honour the first cancellation attempt (confirm it and stop charging) so no charge follows it.
US-NY.NYC.6RCNY5-110.2
always2026-10-016 RCNY § 5-110.2

Notice windows

When each notice must be sent. A notice outside its window does not count, so schedule sends against the exact dates.

NoticeWhenApplies whenCitation
NYC: renewal notice 15-45 days before the cancellation deadline for one-year-plus terms15-45 days before the cancellation deadlineterm ≥ 12 months6 RCNY § 5-110.1(g)
NYC: notice of material changes, including price increases, 5 business days to 30 days in advance7-30 days before the price changealways6 RCNY § 5-110.1(h)
NYC: notice 3-21 days before a free trial of more than a month converts to paid3-21 days before the cancellation deadlinefree trial, trial ≥ 31 days6 RCNY § 5-110.1(i)

Several states use overlapping windows; one email can often satisfy all of them. See free-trial notices and price increases.

Who can sue, and remedies

Private right of action: No private right of action: enforced by public officials only.

NYC Department of Consumer and Worker Protection: penalties of $525 (first), $1,050 (second) and $3,500 (third and later) per violation, and restitution of every amount charged after the consumer's first attempt to cancel (6 RCNY § 5-110.2).

Recorded in the catalog: refunds or restitution.

Remedy figures come from the cited statutes and from public enforcement records summarized in Checkbox's litigation research; figures from secondary sources are marked "unverified" where they appear.

Check your subscription flow

Checkbox evaluates these requirements automatically: the sign-up page, the emails and the cancellation flow are checked against New York City's rules (and every other jurisdiction's) on every check. 17 machine checks cover this page.

Data and citation

This page is generated from the open subscription law dataset (catalog 2026.11.01.1, CC BY 4.0), available as JSON and CSV. Cite it as: Checkbox, "New York City Click to Cancel rule", checkbox.site/laws/new-york-city, catalog 2026.11.01.1 (last reviewed 2026-10-31). Report an error: support@checkbox.site.

Checkbox is compliance software, not a law firm; nothing in these docs is legal advice (details). You remain solely responsible for your subscription program, and Checkbox takes on no legal liability for it (Terms). Checkbox is a System1 company; Trust center · Status. For AI agents: every page is available as Markdown at the same URL plus .md; the index is /llms.txt.