How is the NYC click-to-cancel rule different from New York State's auto-renewal law and the FTC rule?
Quick answer
The NYC rule (6 RCNY 5-110, in force October 1, 2026) follows New York State's auto-renewal law, GBL 527-a, with three additions: in-person sign-ups must also get an online cancel option, charges after a cancel attempt must be refunded, and DCWP fines run $525 to $3,500. The FTC's 2024 click-to-cancel rule was vacated, so no federal version applies.
Short version: the answer is above. If you need to comply, the NYC click-to-cancel kit gives you the templates, checklist and official sources for this law. $49 one-time, instant download.
What does the law say? Key facts and official sources
| Item | What the law says | Source |
|---|---|---|
| NYC rule | 6 RCNY 5-110.1 to 5-110.3 and penalty schedule 6-47, enforced by DCWP; in force October 1, 2026 | Official source |
| NY State law | General Business Law 527-a: clear terms before consent, affirmative consent, acknowledgment, simple cancellation | Official source |
| In-person sign-ups | State: offer cancellation online or by phone. NYC: must offer an online mechanism such as a website or email | Official source |
| Restitution | NYC rule adds restitution for charges after the consumer first tried to cancel (5-110.2) | Official source |
| NYC fines | $525 first, $1,050 second, $3,500 third and later violations (6 RCNY 6-47) | Official source |
| Federal | FTC 2024 negative option amendments vacated by the Eighth Circuit; pre-2024 16 CFR 425 text restored February 12, 2026 | Official source |
| Last verified | October 20, 2026 | Astor Ventures |
What does the NYC rule add to New York State law?
DCWP says its rule is fully consistent with GBL 527-a except for three points: penalty amounts (6 RCNY 6-47), restitution for charges after a cancel attempt (5-110.2), and the mediums for cancellation (5-110.1(d)). Disclosure, consent and save-offer rules track the State law.
Which cancel options must a business offer?
Under GBL 527-a, cancellation must work through every medium you accept for sign-up; for in-person consent you must at least offer an online or telephone option. The NYC rule narrows that for New York City consumers: after an in-person sign-up, the extra option must be online, such as a website or email.
Does the FTC click-to-cancel rule still apply?
No. The Eighth Circuit vacated the FTC's 2024 amendments to the Negative Option Rule, and on February 12, 2026 the FTC restored the older, narrower 16 CFR Part 425 text on prenotification plans. For New York City subscriptions, the State law and the NYC rule are the ones to follow.
Want it done in an afternoon? The NYC click-to-cancel kit turns these rules into fill-in templates, a checklist and a tracker, with the official sources quoted. One-time payment, instant download.
What else do people ask?
If I comply with GBL 527-a, am I compliant in NYC?
Mostly, but check the three NYC additions: online cancel for in-person sign-ups, refunds of post-cancel-attempt charges, and the DCWP penalty schedule.
Who enforces the NYC rule?
The NYC Department of Consumer and Worker Protection (DCWP).
How much are NYC fines?
$525 for a first violation, $1,050 for a second and $3,500 for a third or later (6 RCNY 6-47).
Is this legal advice?
No. General information only.
Related guides
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