Which businesses are exempt from NYC's click-to-cancel rule?
Quick answer
Five groups are exempt under 6 RCNY 5-110.3: businesses (or affiliates) operating under a franchise issued by a New York political subdivision, entities regulated by the state Department of Financial Services, alarm operators licensed by the Department of State, banks, credit unions and other licensed financial institutions, and sellers and administrators of service contracts. Everyone else selling auto-renewals in NYC must comply since October 1, 2026.
What does the law say? Key facts and official sources
| Item | What the law says | Source |
|---|---|---|
| In force | October 1, 2026 (rule Section 3) | DCWP Click-to-Cancel Rule (6 RCNY 5-110 to 5-110.3) |
| Franchise holders | Any service provided by a business or affiliate doing business under a franchise issued by a political subdivision of New York State (5-110.3(a)) | DCWP Click-to-Cancel Rule (6 RCNY 5-110 to 5-110.3) |
| DFS-regulated | Any entity, or subsidiary or affiliate, regulated by the Department of Financial Services (5-110.3(b)) | DCWP Click-to-Cancel Rule (6 RCNY 5-110 to 5-110.3) |
| Alarm operators | Security system alarm operators licensed by the New York State Department of State (5-110.3(c)) | DCWP Click-to-Cancel Rule (6 RCNY 5-110 to 5-110.3) |
| Financial institutions | Banks, bank holding companies and their subsidiaries and affiliates; credit unions; other financial institutions licensed under state or federal law (5-110.3(d)) | DCWP Click-to-Cancel Rule (6 RCNY 5-110 to 5-110.3) |
| Service contracts | Sellers and administrators of a service contract as defined in Insurance Law section 7902 (5-110.3(e)) | DCWP Click-to-Cancel Rule (6 RCNY 5-110 to 5-110.3) |
| Fines | $525 first, $1,050 second, $3,500 third and later violations (6 RCNY 6-47 chart, added by the rule); plus restitution of charges after the first cancel attempt (5-110.2) | DCWP Click-to-Cancel Rule (6 RCNY 5-110 to 5-110.3) |
| Last verified | October 31, 2026 | Astor Ventures |
Are gyms, streaming apps or meal kits exempt?
No. None of them is on the 5-110.3 list unless the business itself falls into one of the five groups, for example by being regulated by the Department of Financial Services.
Does an exemption for my bank cover my own subscription business?
Only if your business is the bank, its subsidiary or affiliate, or another listed institution. Using a bank to process payments does not make a merchant exempt.
Do other laws still apply to exempt businesses?
The exemption is from this part of the NYC rules only. New York State's automatic renewal law and other consumer laws are separate and may still apply.
Want it done in an afternoon? The NYC click-to-cancel kit gives you sign-up terms and how-to-cancel wording, renewal, price-change and free-trial notices, a staff checklist and a cancel and reminder log, with the official text quoted. One-time payment of $49, instant download.
What else do people ask?
When did the rule start?
October 1, 2026 (rule Section 3).
What are the fines?
$525, $1,050 and $3,500 for first, second and third or later violations (6 RCNY 6-47).
Where is the official text?
DCWP published the rule as a PDF on nyc.gov (linked above).
Is this legal advice?
No. General information only.