Which click-to-cancel laws apply to my subscription business?
Quick answer
Do customers sign up for plans that renew automatically? New York City (since October 1, 2026), Virginia and Connecticut (July 1, 2026), Massachusetts (September 2, 2025), California and Minnesota require easy cancellation, often online. The federal FTC click-to-cancel rule was struck down in July 2025 and has not been replaced, so state and city rules apply.
Facts table: laws, dates, fines and official sources
| Place | Law | Starts | Cancel rule | Notices | Fine or penalty | Our pages |
|---|---|---|---|---|---|---|
| New York City | 6 RCNY 5-110 to 5-110.3 | October 1, 2026 | Cancel as easily as signing up | Reminders on set windows before renewal, price changes and trial ends | $525 first, $1,050 second, $3,500 third and later (6 RCNY 6-47) | Guide · Kit |
| Virginia | Va. Code 59.1-207.45 to .49 | July 1, 2026 | Cancellation at least as easy as sign-up, through each sign-up method | Acknowledgment with cancel steps after sign-up | Customers: $500 or actual damages; state: up to $2,500 per willful violation | Guide · Kit |
| Connecticut | C.G.S. 42-158ff (P.A. 25-44) | July 1, 2026 | Cancel link or button, replyable email and/or phone; cancel voicemails handled within one business day | Yearly renewal reminder | Willful: up to $5,000 per violation (42-110o) | Guide · Kit |
| Massachusetts | 940 CMR 38.00 | September 2, 2025 | Cancel as easily as enrolling; online sign-up means online cancel | Advance written renewal notices | Up to $5,000 per violation (c. 93A s. 4) | Guide · Kit |
| California | Automatic Renewal Law (amended by AB 2863) | Amendments July 1, 2025 | Explicit consent; straightforward cancellation | Annual reminder; notice 7 to 30 days before a price change | Not listed here (enforced by the AG and local prosecutors) | No kit |
| Minnesota | Minn. Stat. 325G.56 to 325G.63 | January 1, 2025 (Laws 2024 ch. 114) | Online termination option when offers are made through a website | Free trials over 30 days: notice 5 to 30 days before the trial ends | No civil penalties after a good-faith effort to comply (325G.63); dollar figure not listed | No kit |
| Federal (FTC) | Negative Option Rule, 16 C.F.R. Part 425 | 2024 amendments vacated July 8, 2025 | No federal click-to-cancel rule in force | Pre-2024 rule for prenotification plans only | Not listed here | See below |
What is a click-to-cancel law?
A click-to-cancel law covers plans that renew or keep billing until the customer stops them. It usually requires clear terms before sign-up, the customer's clear yes, a confirmation they can keep, and a way to cancel that is as easy as signing up. If someone joined online, they must be able to cancel online.
Is there still a federal click-to-cancel rule?
No, not as of October 18, 2026. The FTC's 2024 “click-to-cancel” amendments to the Negative Option Rule were vacated by the U.S. Court of Appeals for the Eighth Circuit on July 8, 2025. On February 12, 2026 the FTC restored the rule's pre-2024 text, which covers only prenotification plans such as book-of-the-month clubs (91 FR 6507). On March 13, 2026 it asked for public comment on whether to write a new rule (advance notice, 91 FR 12318); comments closed April 13, 2026. The federal regulatory agenda lists staff review of comments for July 2026 and no proposed rule date (reginfo.gov). The FTC can still bring cases against deceptive subscription practices, but today the detailed cancel rules come from states and New York City.
How is NYC's rule different from the state laws?
New York City's rule is a city agency rule with fixed reminder windows and a fixed fine schedule ($525, $1,050, $3,500), and it makes businesses liable for charges after a customer's first attempt to cancel. The state laws (Virginia, Connecticut, Massachusetts) run through each state's consumer protection act, with damages and civil penalties set by a court. New York State has its own automatic renewal law, which our NYC kit does not cover. See NYC fines.
How do I set up online cancellation?
- Put a clearly labeled cancel link or button in the account area, reachable without calling.
- Ask only for the information needed to find the account.
- Confirm the cancellation in writing right away.
- Do not block cancellation with retention offers the customer must sit through.
- Send the required reminders (yearly in Connecticut and California; set windows in NYC).
- Keep a log of sign-up consent, reminders and cancel requests.
What if the customer signed up in person or by phone?
Virginia requires a cancel option for each way people can sign up, and for in-person sign-ups an online or phone option (Va. Code 59.1-207.46(B)). Connecticut requires a cancel link or button, a replyable email and/or a phone number. Check the rule for each place where your customers live.
Which kit fits me?
Pick the place where your customers are: NYC click-to-cancel kit ($49), Virginia click-to-cancel kit ($29), Connecticut click-to-cancel kit ($29) or the Massachusetts junk fee and auto-renewal kit ($49). Each includes sign-up wording, customer notices and a cancel-request log. We do not sell a California or Minnesota kit.
Need it done fast? Our one-law compliance kits give you a checklist, fill-in templates and a tracker with the official sources quoted. One-time payment, instant download.
FAQ
Is there still a federal click-to-cancel rule?
No. The Eighth Circuit vacated the FTC's 2024 click-to-cancel rule on July 8, 2025. The FTC restored the older, narrower rule in February 2026 and asked for comments on a possible new rule in March 2026; no new rule had been proposed as of October 18, 2026.
What if customers signed up in person?
Virginia requires an online or phone cancel option for in-person sign-ups. Other places require a cancel method at least as easy as sign-up. Check each law.
What notices must I send before renewal?
It depends on the place: a yearly reminder in Connecticut and California, set reminder windows in New York City, advance written renewal notices in Massachusetts, and an acknowledgment with cancel steps in Virginia.
Do I have to keep records?
Not every law sets a record period, but a dated log of consent, reminders and cancel requests is the easiest way to show you complied. Our NYC, Virginia and Connecticut kits include one.
Which kit fits me?
Choose by where your customers are: NYC ($49), Virginia ($29), Connecticut ($29) or Massachusetts ($49).
Is this legal advice?
No. This is general information, not legal advice.