In July 2026, New York City’s Department of Consumer and Worker Protection (“DCWP”) finalized a new “Click-to-Cancel” rule governing automatic renewals and proposed a new junk fee rule that would require all-in pricing across a wide range of consumer transactions. Companies with subscription programs or add-on fees for products or services offered in New York City should take note.

New “Click-to-Cancel” Rule Takes Effect October 1

New York City recently adopted a first-of-its-kind municipal rule regulating subscriptions. The new rule largely mirrors many of the requirements of New York State’s existing automatic renewal law. Among other things, businesses must clearly disclose material subscription terms, obtain affirmative consent, provide required renewal notices, and offer straightforward cancellation mechanisms.  As noted by Mayor Mamdani, “In our city, we're drawing a clear line: if you can sign up with a click, you must be able to cancel with one.”  The rule, which characterizes a subscription that fails to meet these standard a “deceptive and unconscionable trade practice,” makes violators liable for restitution as well as civil penalties of $525 for a first violation up to $3500 for a third.

The most significant effect of the new rule may be enforcement. The rule gives DCWP a direct local enforcement tool, creating additional risk for marketers offering subscriptions already covered by state law. 

Proposed Junk Fee Rule Would Require All-In Pricing

New York City has also proposed a broad junk fee rule that would require companies to disclose the total price consumers must pay for products and services, including mandatory fees and charges, at least as prominently as other pricing information. Failing to do so would be a deceptive trade practice.

If adopted, the proposed “all in pricing” rule would apply across industries and generally prohibit advertising a price that does not include all unavoidable charges, with the exception of taxes, government-imposed fees, and shipping charges that are “reasonably and actually incurred to ship a physical good to the consumer.” For charges made on a periodic basis, the ad would need to prominently disclose the total price for the relevant time period and the total amount of any non-recurring charges. For any fees excluded from the advertised price, the company would need to clearly and conspicuously disclose the nature, purpose, and amount of such fees. Companies would also be required to maintain records of compliance and their failure to do so creates a presumption that a material fact alleged by DCWP – such as that an excessively high shipping fee is not based is actual shipping cost – is true. 

Takeaways

These rules are largely in line with requirements adopted at state level elsewhere, but are notable in being introduced by a major city. With subscriptions and pricing practices already subject to a patchwork of state and federal requirements, adding local compliance to the mix signals the potential for even more compliance obligations on marketers going forward.

For now, New York’s newly adopted and proposed rules provide a good reminder to review both subscription practices and pricing disclosures. In particular:

• Review automatic renewal disclosures and notices.
• Confirm that cancellation is as easy as enrollment.
• Audit add-on fees and surcharges.
• Evaluate whether advertised prices reflect the amount consumers are required to pay.