On July 10, 2026, New York City Mayor Zohran Mamdani and Department of Consumer and Worker Protection (“DCWP”) Commissioner Samuel Levine announced the adoption of a new “Click to Cancel” rule governing how businesses disclose, bill, and cancel subscriptions. The rule takes effect October 1, 2026.
For companies already tracking the requirements of New York State’s autorenewal statute, GBL § 527-a, the new City rule will feel familiar. The DCWP explained that the rule is designed to be “consistent with the approach codified in New York State law” and its substantive provisions largely mirror state law. But it is not a carbon copy: it narrows cancellation options for certain businesses, increases potential civil penalties, and defines the measure of restitution. Businesses that focus solely on state law compliance may be caught off guard by the new City rule.
Cancellation Options
Where a consumer signs up in person, GBL § 527-a requires the business to offer cancellation through an online mechanism or a telephone number. The City rule tightens this requirement: it mandates an online mechanism, “such as a website or email,” and drops the telephone option altogether. Businesses that rely on phone-based cancellation for in-person enrollments will therefore need to add an online cancellation channel to comply with the City rule.
Civil Penalties
Under GBL § 527-a, maximum civil penalties are $100 for a single violation and $500 for multiple violations arising from a single act or incident, rising to $500 and $1,000, respectively, for knowing violations. The statute also provides a bona fide error defense for unintentional violations resulting from a genuine mistake despite reasonable procedures.
The City rule increases potential civil penalties. Enforced as a deceptive and unconscionable trade practice under the Consumer Protection Law, a violation is subject to the penalty schedule in § 6-47 of the Rules of the City of New York. Unlike the state statute, which sets a ceiling on multiple violations arising from a single act, the City imposes a fixed amount per violation, as defined in § 20-703: $525 for a first violation, $1,050 for a second, and $3,500 for a third or subsequent violation. The City rule also lacks an express bona fide error defense.
Restitution
GBL § 527-a leaves restitution to the court’s discretion in an Attorney General enforcement action. The City rule, by contrast, provides a defined restitution measure: a business that violates the rule is liable for the amount charged to the consumer after the consumer’s first attempt to cancel. Check back here for more updates on autorenewal law developments. If you have any questions about click-to-cancel compliance, please contact members of our Advertising and Consumer Protection Investigations practice.