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Which click-to-cancel laws apply to my subscription business?

Last updated October 18, 2026 · Last verified October 18, 2026 against the official sources linked below · General information, not legal advice

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

PlaceLawStartsCancel ruleNoticesFine or penaltyOur pages
New York City6 RCNY 5-110 to 5-110.3October 1, 2026Cancel as easily as signing upReminders 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
VirginiaVa. Code 59.1-207.45 to .49July 1, 2026Cancellation at least as easy as sign-up, through each sign-up methodAcknowledgment with cancel steps after sign-upCustomers: $500 or actual damages; state: up to $2,500 per willful violationGuide · Kit
ConnecticutC.G.S. 42-158ff (P.A. 25-44)July 1, 2026Cancel link or button, replyable email and/or phone; cancel voicemails handled within one business dayYearly renewal reminderWillful: up to $5,000 per violation (42-110o)Guide · Kit
Massachusetts940 CMR 38.00September 2, 2025Cancel as easily as enrolling; online sign-up means online cancelAdvance written renewal noticesUp to $5,000 per violation (c. 93A s. 4)Guide · Kit
CaliforniaAutomatic Renewal Law (amended by AB 2863)Amendments July 1, 2025Explicit consent; straightforward cancellationAnnual reminder; notice 7 to 30 days before a price changeNot listed here (enforced by the AG and local prosecutors)No kit
MinnesotaMinn. Stat. 325G.56 to 325G.63January 1, 2025 (Laws 2024 ch. 114)Online termination option when offers are made through a websiteFree trials over 30 days: notice 5 to 30 days before the trial endsNo civil penalties after a good-faith effort to comply (325G.63); dollar figure not listedNo kit
Federal (FTC)Negative Option Rule, 16 C.F.R. Part 4252024 amendments vacated July 8, 2025No federal click-to-cancel rule in forcePre-2024 rule for prenotification plans onlyNot listed hereSee below

This table lists the rules we have checked against official sources. Other states have automatic renewal laws too; it is not a complete list. Last verified October 18, 2026 against the official sources linked in the table.

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?

  1. Put a clearly labeled cancel link or button in the account area, reachable without calling.
  2. Ask only for the information needed to find the account.
  3. Confirm the cancellation in writing right away.
  4. Do not block cancellation with retention offers the customer must sit through.
  5. Send the required reminders (yearly in Connecticut and California; set windows in NYC).
  6. 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.

See all kits →

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.

General information, not legal advice. Laws change; check the official sources before acting.

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