New York City’s “Click to Cancel” Rule Goes Into Effect

This month, New York City’s rule on subscription traps took effect, protecting New Yorkers from confusing, time-consuming hurdles that make it difficult to cancel a subscription. The rule requires that companies must provide consumers with a straightforward cancellation process in the same method as sign up. The rule will be enforced by the city’s Department of Consumer and Worker Protection and establishes civil penalties for violations.

The FTC previously adopted a click-to-cancel rule in 2024, but it was vacated last year by the Eighth Circuit—not because of any issue with the rule’s substance, but rather due to an alleged procedural defect with its adoption. Since then, EPIC has continuously urged the FTC to crack down on predatory business practices that trap people into buying products or services with perpetually recurring charges. EPIC has repeatedly called on the FTC to renew the click-to-cancel rulemaking to protect consumers. 

EPIC has long advocated against the use of dark patterns in subscription cancellation processes because they deter customers from canceling subscriptions, forcing them to give up more money and enabling companies to continue collecting, retaining, and using consumers’ personal data.