Businesses that sell subscriptions to New Yorkers have been operating under a new set of cancellation rules since October 1, 2026, when the city’s Department of Consumer and Worker Protection began enforcing its final rule on subscriptions. The rule covers New York City only, but it is written in the vocabulary of the national click-to-cancel fight: disclose the terms up front, and make leaving as easy as joining. Penalties start at $525 for a violation.
A final rule with an October 1 start, not a proposal
The Department of Consumer and Worker Protection, known as DCWP, announced the rule on July 10, 2026, in a release from the Mamdani administration. The text is plain about its status: “This final rule goes into effect on October 1, 2026 and gives DCWP citywide enforcement authority to ensure New Yorkers can easily cancel subscriptions and end memberships.”
That sentence settles the question that usually follows a rule announcement. The rule was adopted in July, and October 1 was its effective date, so as of October 3 it is in force. The release calls it the “Click-to-Cancel” rule and describes it as one of two rules announced together. The second, on so-called junk fees, is a different matter, covered further down.
What the rule requires of subscription sellers
In the release’s words, the rule “requires clear disclosures and affirms consumers’ rights when purchasing, enrolling in or canceling subscriptions for services or goods.” DCWP’s click-to-cancel page turns that into four duties for companies: they must clearly explain subscription terms, clearly disclose consumers’ rights when buying or cancelling, provide a straightforward cancellation process in the same method as sign-up, and not ask consumers to pay to ship back things that were given for free.
The same summary lists exemptions for businesses regulated by the New York State Department of Financial Services, banks, credit unions and certain licensed operators. DCWP’s release says the rule applies citywide to businesses offering subscriptions, and the law firm’s list shows that the coverage has limits.
Penalties that start at $525
DCWP’s page says civil penalties start at $525 for violations and that businesses may also be required to refund consumers. The word “start” is the agency’s: $525 is a floor, not a fixed fine. DLA Piper’s summary says the schedule rises from $525 for a first violation to $3,500 for a third or later violation, counted per distinct violation. That ladder comes from the law firm’s reading of the rule, not from the DCWP release, which gives only the starting figure…