Cancellation of Subscriptions

Online comments: 73

• Michael First

  Wonderful idea…I fully support this. It is so easy to be tricked into subscribing to services on-line/

  Comment added April 9, 2026 9:17pm

• SEAN HUBERTH

  I support this proposed rule

  Comment added April 10, 2026 8:02pm

• Jacob

  Please make it possible for me to leave my Equinox membership I am now forced into a $400 subscription I can’t leave for an entire year. The facilities are packed and suboptimal. It’s a lifestyle scam.

  Comment added April 10, 2026 8:24pm

• Anonymous

  This was such a good idea when it was proposed on the Federal level before it was blocked by Trump. So, yes, please!! Free trials turning into huge bills. There should be a click to cancel for everything.
  Honestly, I don’t mind when a service asks you if you want a huge discount instead of cancelling—keep that option, please! Gyms are a huge issue. Those need to be much easier to cancel!!! I know people who had their credit ruined because of gym memberships!

  Comment added April 11, 2026 11:22am

• Anonymous

  This is a rule that absolutely needs to happen. We deserve protections, and the end of being held hostage by corporations, and forced to fight loopholes and red tape just to cancel a subscription program. I want it to be easy. I want to be able to do it with a click of a button, not have to go through a ten-step process that only ends in frustration (and sometimes, requires me to pay MORE just to cancel!) I’ve faced it time and time again, especially with gym memberships that require me to fight a front desk person just to cancel a subscription I’m not even using! I’m sick of it!

  I welcome this rule wholeheartedly, and I thank the team that is pushing this rule forward. I truly hope it passes. It will be for the better of all New Yorkers.

  Comment added April 11, 2026 8:14pm

• Robert Stribley

  Consumers should absolutely be able to cancel any subscription as easily as they initially subscribed. This is not an only a basic consumers rights issue, but it also affects the digital privacy of Americans and we need a federal framework for digital privacy rights, as well.

  Comment added April 11, 2026 8:22pm

• Marie Kaplan

  In essence, at will employment is a subscription agreement between an individual and a company. I assume this initiative will allow companies to part ways with an unwanted employee with a simple click, no explanations, and no recourse. I am in support of this change!

  Comment added April 11, 2026 8:26pm

• Stalin, Joe

  The bourgeoisie stole my lunch money in 1917 and I’m still waiting for the people’s commissar to redistribute it.

  Comment added April 11, 2026 8:37pm

• Anonymous

  This is a rule that protects consumers. I’m all for it!

  Comment added April 11, 2026 8:42pm

• Steven Vascellaro

  I am fully in favor of this. I remember having to call customer support to cancel my subscription to WIRED

  Comment added April 11, 2026 8:42pm

• Benjamin Zweig

  I agree with this rule. Consumers should have clarity and consistency on cancelling subscriptions.

  Comment added April 11, 2026 8:47pm

• taylor robin

  There’s basically no reason not to make this a rule. Fully approve–get on Adobe about this.

  Comment added April 11, 2026 8:57pm

• Freddy Vasquez

  Great idea, will be especially helpful for people trying to cancel gym memberships

  Comment added April 11, 2026 9:12pm

• Austin

  I strongly support this proposal to make subscriptions easier to cancel.

  Comment added April 11, 2026 9:18pm

• Sanaa Shah

  excellent initiative! fully support! when can we provide names of companies that engage in these practices?

  Comment added April 11, 2026 9:25pm

• Yandel Goris

  I strongly support this proposed rule. For far too long, companies have used misleading and covert business practices to trap New Yorkers into “forever” subscriptions that are extremely difficult to cancel or escape. Consumers should have the option to cancel their subscription at any time without penalty or delay. All consumers should be able to opt out of a subscription as easily as subscribing. This proposed rule will finally put an end to these deceptive practices and will set the national standard for consumer protection in the marketplace.

  Comment added April 11, 2026 9:41pm

• Anonymous

  This is a great idea, and will help save countless new yorkers both time and money

  Comment added April 11, 2026 9:49pm

• Liz

  I am all for this…thank you for asking and caring! It’s refreshing!

  Comment added April 11, 2026 9:50pm

• Darrien Glasser

  Not sure how anyone could not support this. Cancelling subscriptions is such a pain. This would be such a boon to New Yorkers.

  Comment added April 11, 2026 10:01pm

• Anonymous

  I agree with the rule. Make subscriptions easier to cancel!

  I’d also like something like this for companies to delete our data within a specific time period when you request (or at least make it unsellable).

  Comment added April 11, 2026 10:06pm

• Anonymous

  Thank you for doing this. It can be such a pain to unsubscribe to a service.

  Comment added April 11, 2026 10:31pm

• Anonymous

  This is a great idea!

  Comment added April 11, 2026 10:41pm

• Mason Chaz

  I fully support this rule and hope it comes into effect immediately

  Comment added April 11, 2026 11:09pm

• Ren

  Thank you – it’s about time we dealt with these awful companies. The companies just want to trap us and make it such a headache to cancel their services. They know what they are doing; they run on deceptive practices with the goal of only increasing their bottom line.

  Comment added April 11, 2026 11:34pm

• Kaizer Yousuf Hossain

  100% agree with this. End Dark Capitalist practices now and forever.

  Comment added April 11, 2026 11:36pm

• Monano Pierre-Paul

  That would be a wonderful rule, Mr. Mayor! One more thing, being able to cancel a subscription in just 1 click is one thing, them not taking you off their mailing/subscribers list even if you unsubscribe or block them from e/mailing you is another petty thing they do. THE NEW YORKER is a prime example of this. If I cancel a membership or unsubscribe from your mailing list then please leave me alone.

  Comment added April 11, 2026 11:36pm

• Sam

  Great idea

  Comment added April 12, 2026 12:33am

• hayley

  yes, companies are manipulative – love this!

  Comment added April 12, 2026 1:46am

• Anonymous

  Can you add a rule to opt out of having to endure the current Mayor?
  I did not suscribe to this.

  Comment added April 12, 2026 3:51am

• Evan

  I signed up for a newsletter to find a citation for a paper 3 years ago and I still have my information on the site even after contacting them multiple times. I hope this rule is able to be out into place!!

  Comment added April 12, 2026 7:08am

• Khadjiah

  I believe this should also include trying to downgrade subscriptions.
  Just a few days ago I tried to downgrade my annual Google Business subscription (I am at the end of my annual subscription). They notified me that there is going to be a price change, so I tried to downgrade my subscription because I don’t need all of the features my current subscription provides. It will not allow me to downgrade my subscription unless I change my current subscription to a monthly (flexible plan) subscription, wait for them to charge me, then downgrade to a lower tier.

  Not only that, whenever I tried to click on information for downgrading my business tier it would ALWAYS switch me out of my business account, into my personal one, and try to trick me into buying another business account.

  Comment added April 12, 2026 8:15am

• Sarah Madigan

  I strongly support this measure to make it more difficult for companies to create barriers to ending subscriptions.

  Comment added April 12, 2026 9:07am

• Cesario Tirado-Ortiz

  I have lost so much money due to impossible unable to delete subscriptions. Being a low income New Yorker, this would save me so much money and help me secure financial stability in the future.

  Comment added April 12, 2026 9:08am

• Anonymous

  Canceling subscriptions with a click is a great idea. It should extend to everything including cable who can pester you for hours before allowing you to cancel.

  Comment added April 12, 2026 10:50am

• Anonymous

  This is a really good rule. Some of the subscriptions I have made, have made it extremely hard to cancel once purchased and in some cases, I’ve had to figure out myself whether I was truly able to cancel or not. A suggestion is that this should be made common practice across everything, from shopping and returning items, to cancelling reservations and appointments. Additionally, corporations should be held to account when raising their prices, meaning not only sending short emails about price increases, but also holding off on charging customers, until they confirm that they want to continue with the price increased subscription. Thank you Mr. Mamdani for fighting for the youth and hard-working people in NYC.

  Comment added April 12, 2026 11:07am

• Anonymous

  I am fully in favor of this! Thank you for advocating for us

  Comment added April 12, 2026 11:59am

• Dee

  Making it difficult to cancel subscriptions suggests to me that companies are more interested in making money than being good to their customers. As if consistent price hikes for diminishing quality isn’t bad enough, going out of your way to make it difficult to keep our money is even worse.

  Comment added April 12, 2026 12:18pm

• Cristina

  I support this 100%!!!

  Comment added April 12, 2026 1:02pm

• Jessica

  Fully support this, there are many companies and gyms that make it unreasonably difficult to cancel subscriptions. In a digital world, this impacts everyone but exploits older New Yorkers the most. There are companies such as ScentBird for example, that of course make it easy to sign up but say you have to email support to cancel. Even then if you’re not on top of it, they will continue to charge you, even after you expressed your wish to cancel via email. I’ve heard of companies like BrainMD that make it equally as puzzling and difficult to cancel a subscription. Just thought those companies deserved a mention since they treat their customers who fall prey to their subscription service horribly. A company should have to earn our loyalty, not trap us. Hopefully New York can get this done. Thank you.

  Comment added April 12, 2026 1:25pm

• Anonymous, RM

  Support it! Equinox is the worst offender here.

  Comment added April 12, 2026 1:42pm

• Tee

  I support this. It should be as easy to cancel as it is to subscribe.

  Comment added April 12, 2026 2:00pm

• Joshua S

  I think it’s a fantastic idea. PS: Planet Fitness is a big offender here!

  Comment added April 12, 2026 2:41pm

• Anonymous

  I support!

  Comment added April 12, 2026 4:53pm

• Anon

  This is a great idea.

  Comment added April 12, 2026 6:09pm

• Anonymous

  This is a fantastic idea and well beyond time for this. Companies that make subscribing so easy and make cancelling that subscription unnecessarily complex or difficult (by having to send a postmarked letter? come on) have been using that to squeeze extra months of fees out of their userbase forever. This is a much needed first step to demanding corporate responsibility and reigning in their deceptive and manipulative tactics at the consumer’s dime. Maybe we can go after the cable company promotions next.

  Comment added April 12, 2026 7:55pm

• Larissa King

  I recently spent nearly an hour attempting to cancel a subscription to online grocery store Thrive Market. There was no cancellation option in the account settings, and I had to repeatedly request my account cancellation from a chatbot that was programmed not to take no for an answer. After requesting cancellation 5 times, it finally accepted.

  Comment added April 12, 2026 8:27pm

• Kinsen

  What a great and common sense way to cancel subscriptions.

  Now companies can spend their time making their subscriptions worth it instead of designing ever worse cancellation pages.

  Comment added April 13, 2026 2:05am

• Amy

  I work in tech. I know how companies ignore inconvenient usability heuristics to keep consumers trapped in their digital ecosystems. They collect data on your every click and keystroke – often even recording your screen!! – to see how visitors navigate their sites and know where people are going to try to accomplish certain tasks. They are also running experiments on you constantly (which may take the form of A/B testing or beta testing, for example) without your knowledge to see which changes to their site or marketing campaigns result in manipulating customers to perform the desired action (conversion). The changes or design issues that get attention and investment are the ones that generate revenue. If a company can design a simple, intuitive subscription flow they can absolutely design its counterpart for cancellation. And don’t even get me started on the companies that require you to call or use a customer service chat to cancel, when they can use social desirability biases to pressure you into continuing to remain a customer. At present, there’s no incentive for companies to make any changes to cancellation experiences that benefit consumers and negatively impact their bottom line. As they say, “When there’s a will, there’s a way,” but currently there is no will. Please, NYC, do this and create model legislation for other cities and states to follow suit.

  Examples:
  – Recording of customer use of a website: https://www.pendo.io/session-replay-demo/hv/
  – Capturing customer interactions, and pairing it with individual, uniquely identifying customer information (attributes) to push you into spending more money:
  —— Adobe Analytics https://experienceleague.adobe.com/en/docs/core-services/interface/services/customer-attributes/attributes
  —— Qualtrics https://www.qualtrics.com/customer-experience/digital-analytics/
  – A/B testing software a company can subscribe to that allows them to conduct experiments on customers to see which version (variant) of a site results in customers spending more money: https://www.optimizely.com/products/web-experimentation/

  Comment added April 13, 2026 7:34am

• Philip Matuskiewicz

  This rule should also extend to the telecom operators like Verizon and Sirius XM. With Verizon it was very easy to open a new line in store, but the store was not able to cancel any lines, I had to call into their customer support center, wait on hold for 60+ minutes, and then go through all sorts of retention acts before they’d cancel it for me in December. Cable TV isn’t any better. I’m in strong support of such rules that require cancellation to be an equal effort to opening up the account in the first place.

  Comment added April 13, 2026 9:19am

• Suzanne C

  I’ve received many spam emails that either dont have an unsubscribe button or the button directs me to a “404 page not found” site. How will you address this?
  Also, how will you address the behind the scenes sale of our contact info to others?

  Comment added April 13, 2026 9:27am

• Anonymous

  I FULLY SUPPORT.

  End predatory practices from corporate America. One click cancel must happen.

  Comment added April 13, 2026 1:07pm

• Lainie Fefferman

  I think click to cancel would help a huge number of people – definitely pro!

  Comment added April 13, 2026 4:11pm

• Jascha Narveson

  There is no good reason not to have this law. The only reason to make canceling subscriptions hard is for corporations to trap people into paying money against their will.

  In a rational world this would be a no-brainer.

  Comment added April 13, 2026 4:12pm

• Amery Rock

  I agree with rules that restrict how corporations can make people unsubscribe from their services. I subscribed to an app recently called MyFitnessPal. It cost about $20 a month to subscribe but a subscription is also available annually at about $80 a month. I initially signed up for the $20 a month plan so that I could see whether or not I would enjoy using the app and that it would be useful to me. After determining that I did want to continue to use the app. It took me about 3 months to figure out how to unsubscribe from the $20 a month plan. There was no option to easily switch from the $20 a month plan to the $80 annual plan. I had to literally cancel my subscription for a month and I’m going to have to sign up a month later for my $80 plan. Unnecessary

  Comment added April 13, 2026 5:16pm

• Anna McPherran

  STRONGLY IN FAVOR, thank you!

  Comment added April 13, 2026 8:47pm

• Cee m

  Wonderful! I don’t subscribe to almost anything because of the current automatic renewals…. having read/heard about so many people having trouble when they want to cancel a subscription.
  This not only hurts me, but the business that is seeking my dollars.

  Comment added April 15, 2026 11:32am

• Brett Frischmann, Sarah Rajtmajer, Evan Selinger, and Moshe Vardi

  Comments from Brett Frischmann, Charles Widger Endowed University Professor in Law, Business and Economics, Villanova University; Sarah Rajtmajer, Associate Professor, College of Information Sciences and Technology, The Pennsylvania State University; Evan Selinger, Professor of Philosophy, Rochester Institute of Technology; and Moshe Vardi, University Professor, Karen Ostrum George Distinguished Service Professor in Computational Engineering at Rice University.

  It is a great idea to require symmetry in digital contracting so that it is just as easy/difficult to enter a contractual or other commercial arrangement as it is to withdraw from it. In general, symmetrical design is a good idea. It is fair, and it can enable consumers to exercise their autonomy meaningfully.

  One significant problem with “click-to-cancel” rules, however, is the premise that one click (or even a few) is enough to enter or withdraw, subscribe or unsubscribe. It is way too easy to enter subscriptions and other contractual arrangements in the first place. There is extensive literature on the topic. Click-to-contract (one-click contracting) is a pervasive social problem, and it is not solved by click-to-cancel. See, e.g., Brett Frischmann and Moshe Vardi, Better Digital Contracts with Prosocial Friction-in-Design, 65 JURIMETRICS J. 1 (2025); Brett Frischmann and Evan Selinger, Re-Engineering Humanity (Cambridge University Press 2018).

  Companies use asymmetrical friction-in-design to engineer user behavior and trap consumers: The “easy to enter (frictionless), but difficult to escape (friction-full)” set-up not only traps consumers in bad deals and commercial relationships; it also destroys privacy and supports surveillance capitalism. See Brett Frischmann and Sarah Rajtmajer, Defending Consent in Privacy Law, at https://ssrn.com/abstract=6204478.

  The solution is not simply to eliminate friction stacked against cancellation, however. In addition to making cancellation/withdrawal easier, the DCWP should make entering digital subscriptions and related contractual arrangements more difficult. At a minimum, consent should be meaningful and not illusory. Notice and clear and conspicuous disclosures coupled with some action to manifest assent (like clicking a virtual button) is not enough. Studies show: No one reads; people just click without thinking. And this is not natural, necessary, or inevitable; it is a direct consequence of the same type of asymmetrical friction-in-design. See id.

  The DCWP should require better design. Prosocial friction-in-design that teaches and confirms understanding is possible and need not be overbearing. Simply put, and as explained in a series of publications cited above, the party drafting and designing consent mechanisms should bear the burden of generating reliable evidence that a person actually understands the consequential terms to which the person agrees.

  Before closing, it is important to clarify that we fully appreciate the intention to protect consumers trapped in a web of online services and subscriptions. Providing them with a reasonable way out is a laudable goal. And we also appreciate the concern about the perfect being the enemy of the good. While not perfect, the proposed rules seem like a radical improvement for the good because it would provide consumers with an easy way to escape. In the short run, this may be accurate. But we are much less confident about the impact of the proposed rules over the medium to long run, and briefly, here is why. The rules could backfire if they provide the illusion of sufficient consumer protection. While there might be a rush to take advantage of the rules in the short run, it is unclear whether consumers would continue to do so over time. Finally, perhaps the worst impact of the current proposed rules is that the rules effectively endorse and normalize the frictionless one-click approach.

  Comment attachment
  ReengineeringHumanity-EXCERPT.pdf

  Comment added April 15, 2026 12:11pm

• Anonymous

  Please look in to New York Daily News—they have a completely labyrinthine process just to cancel. When you go to your account dashboard and click cancel subscription, the page just keeps loading.

  Comment added April 15, 2026 7:34pm

• Aria H

  To Whom It May Concern: The Department of Consumer and Worker Protection (DCWP)

  Re: Rules Relating to Cancellation of Subscriptions REFERENCE NUMBER: 2026 RG 020

  I am writing to express my support to the proposed rule by The Department of Consumer and Worker Protection (DCWP) of New York City to add rules to ensure that consumers can easily cancel subscriptions and are not subject to deceptive and unconscionable trade practices relating to the cancellation of subscriptions.

  Subscription-based services, while convenient, have long been used by predatory corporations to take advantage of consumers and rack millions in revenues. This unfair practice takes money away from the pockets of consumers and puts it on greedy hands. By incorporating this proposed rule, DCWP will be protecting consumers from these predatory practices and help consumers have a voice in this matter.

  According to a working paper by the National Bureau of Economic Research, forgotten subscriptions alone can account for 14% to 200% of additional revenue. Often, these subscriptions are not easy to cancel either—recently, Equinox lost a class action lawsuit in which it paid back $600,000 because of its previously hard to cancel subscriptions. The newly proposed rule will allow New York City to further challenge companies like Equinox to protect consumers.

  I respectfully urge DCWP to act in our best interests and champion the successful enaction of this rule.

  Thank you,

  Aria H

  Comment added April 16, 2026 12:10am

• Chris Cooper

  I’m a former government-accredited forensic investigator, and a UI/UX design professional. In mid-2025, I tried to cancel our internet service from a well-known telecommunication company. What should have taken minutes consumed months, generated nearly 1000 pages of evidence, and is now the foundation of a court case I am preparing.

  Our records indicate that there are multiple federal, state, and local statutes have been violated. Here the cancellation systems seem engineered to prevent or delay cancellations. Even after confirmed cancellation, the company charged a full billing cycle, promised a pro-rata refund, and never delivered it, despite repeated follow-up for months.

  I am motivated to assist anyone working to end subscription traps, and I applaud the campaign’s work. If the federal rule got pushed back, state action is essential until federal legislation catches up.

  I am open to contribute in any way, to help push for systemic change in this area – which affects millions of tired Americans who can’t cancel their subscription due to apparent ‘Engineered friction’. Of this friction – I have documented a very long list of specific examples. This has to stop.

  I am also keen to speak personally on this – at the hearing in May.

  Comment added April 16, 2026 11:54am

• Nicole w

  I am writing to express my strong support for the proposed “Click to Cancel” rule. As a resident of New York City, I believe this is a common-sense measure that protects consumers from predatory business practices.
  For too long, companies have made it incredibly simple to sign up for a service while intentionally making the cancellation process difficult, confusing, or time-consuming. This “subscription trap” creates an unfair burden on busy New Yorkers and often results in people paying for services they no longer want or need simply because the exit path is hidden behind phone queues or complicated interfaces.
  Requiring businesses to make cancellation as easy as enrollment is a matter of basic fairness and transparency. I applaud the DCWP for taking a lead on this issue to ensure that our consumer protection laws keep up with modern digital subscriptions.
  I fully support the adoption of this rule and thank the Department for its work on behalf of NYC consumers.

  Comment added April 20, 2026 1:23pm

• Lisa Sorin

  The Bronx Chamber of Commerce is critical in helping local businesses in the Bronx grow, thrive, and remain competitive. The Chamber is supportive of the Department of Consumer and Worker Protection’s proposed rule to make it easier for consumers to cancel subscriptions.

  Consumers shouldn’t have to deal with confusing systems just to cancel something they signed up for. Clear and simple cancellation processes build trust, and that trust is good for business. From our perspective, most businesses want to keep customers because they provide a good service, not because cancellation is difficult. Setting a clear standard across the board helps prevent bad actors from gaining an unfair advantage.

  As this rule moves forward, we encourage DCWP to keep implementation straightforward and flexible, while keeping in mind that businesses should be able to comply without needing expensive system upgrades or complex changes.

  Overall, we think this is a smart step that protects consumers while still working for small businesses. With thoughtful implementation, it can strengthen trust without creating unnecessary burdens.

  Comment attachment
  4.30.26-Click-to-Cancel-Comments.pdf

  Comment added April 30, 2026 10:13am

• Anonymous

  Attached screenshot of my cancelled MGM in 2024 and they STILL BILL me and say I never cancelled. Services like HULU / Disney let you sign up on apps but require that you cancel on web browser but don’t provide a link it took me over 1.5 hours to cancel and still had a back & forth if it was really cancelled. I’m 73 and now will NEVER sign up for anymore services because I don’t want the aggravation & fighting to not be CHARGED continuously after I cancel. Companies should be required to send an email attesting that in fact your account has been cancelled. Apple is the ONLY company that lists your subscriptions and lets you cancel in their app and you can directly contact Apple via chat service if any issues with questions or issues in real time.

  Comment attachment
  Screenshot-2026-04-30-at-10.51.03 AM.pdf

  Comment added April 30, 2026 11:08am

• Will V

  Yes! I fully support this law. It’s about time. New York Sports Club and Blink have gotten away with this for years! They’re outright criminals. But we all know it’s happening everywhere, especially with online services. Protect consumers!

  Comment added May 4, 2026 11:45am

• Kaitlin Caruso

  Please see my attached comment in support of the proposed rule.

  Comment attachment
  K-Caruso-Click-to-Cancel-Comment-5.4.pdf

  Comment added May 4, 2026 3:14pm

• B. Lynn Follansbee

  Please see attached comments.

  Comment attachment
  USTelecom-Letter-NYC-DCWP-Click-to-Cancel-Rules-.pdf

  Comment added May 5, 2026 4:10pm

• Laura Smith, Legal Director, TINA.org

  TINA.org’s comment is attached.

  Comment attachment
  5_6_26-TINA-comment-re-NYC-Click-to-Cancel-proposal.pdf

  Comment added May 6, 2026 11:34am

• Dustin Brighton

  May 7, 2026

  Commissioner Samuel A.A. Levine Department of Consumer and Worker Protection 42 Broadway, 5th Floor New York, NY 10004

  Re: Comments on Proposed Rule – Cancellation of Subscriptions (“Click-to-Cancel”)

  RE: Industry Opposition to Current Proposed “Click to Cancel” Rule

  Dear Commissioner and Members of the Department of Consumer and Worker Protection:

  On behalf of the Evergreen Subscription Organization, I respectfully submit the following comments in response to the Department’s proposed rule regarding subscription cancellation (“click-to-cancel”).

  We appreciate the Department’s goal of ensuring that consumers can easily and transparently cancel subscription services. Consumers should not face unnecessary barriers, delays, or deceptive practices when seeking to end a recurring relationship. We support clear, accessible, and efficient cancellation mechanisms.

  However, we write to express concern that, as currently drafted or potentially interpreted, the proposed rule could effectively eliminate or unduly restrict lawful and beneficial retention (“save”) offers. We urge the Department to clarify that such offers remain permissible, provided that consumers retain the ability to cancel immediately, easily, and without friction. 1. Retention Offers Are a Legitimate and Pro-Consumer Practice

  Retention or “save” offers—such as discounts, plan downgrades, billing pauses, or alternative service tiers—are a standard and widely accepted feature of subscriptionbased commerce. These options often benefit consumers by:

  • Allowing them to reduce costs rather than fully cancel services they still value;

  • Providing flexibility during temporary financial or usage changes; and

  • Increasing transparency around available service options.

  Eliminating or discouraging these interactions would reduce consumer choice and could lead to more cancellations that do not reflect the consumer’s true preferences.

  2. The Proposed Rule Risks a De Facto Prohibition on Save Offers

  While the rule does not explicitly ban retention offers, its emphasis on “one-click” cancellation and the prohibition on additional steps could be interpreted to disallow any intervening screen or offer. Such an interpretation would create a de facto ban on save flows, even when those flows are:

  • Clearly presented,

  • Non-deceptive, and

  • Easily bypassed.

  We recommend that the Department explicitly permit the presentation of retention offers, so long as:

  • A clear and conspicuous “Cancel” option is presented on the same screen; and

  • Consumers can complete cancellation in a single, uninterrupted action if they choose.

  3. Alignment with Existing Legal Frameworks

  New York State law and other regulatory frameworks have historically permitted retention offers, provided that cancellation remains straightforward and accessible. Departing from this approach at the municipal level risks creating inconsistency and confusion for both consumers and businesses.

  A clear statement preserving save offers would align the rule with existing legal norms while still advancing the Department’s consumer protection goals.

  4. Avoiding Unintended Consequences A rigid interpretation of “one-click” cancellation that excludes retention interactions could:

  • Reduce consumer access to beneficial pricing or service alternatives;

  • Incentivize businesses to remove flexible plan options altogether; and

  • Create a less dynamic and less consumer-responsive marketplace.

  Importantly, consumers who wish to cancel immediately should always be able to do so. But those who are open to alternatives should not be deprived of that opportunity.

  5. Recommended Clarification

  To address these concerns, we respectfully request that the final rule include language clarifying that:

  “A business may present a retention or modification offer during the cancellation process, provided that the consumer is simultaneously presented with a clear, conspicuous, and readily accessible option to complete cancellation immediately without additional steps.”

  Such clarification would preserve consumer choice while ensuring that cancellation remains frictionless and effective.

  We appreciate the opportunity to comment on this important proposal and would welcome further engagement with the Department on how to balance ease of cancellation with preserving beneficial consumer options.

  Thank you for your time and consideration.

  Sincerely,

  Dustin Brighton

  Executive Director Evergreen Subscription Organization

  Comment attachment
  ESO-Letter-of-Opposition-to-LA.-HB-750-F.pdf

  Comment added May 7, 2026 11:25am

• American Economic Liberties Project (AELP)

  The American Economic Liberties Project (AELP) submits this comment to support the New York City Department of Consumer and Worker Protection’s (DCWP) proposed “Click to Cancel” rules, which would ensure that consumers can cancel subscriptions as easily as they can sign up for them and protect consumers from deceptive and unconscionable trade practices relating to subscription offers.
  New Yorkers have been clamoring for such common sense consumer protections for years. Back in 2023, when the Federal Trade Commission proposed a similar rule under Chair Lina Khan, it received thousands of supportive comments from around the country—including from individuals in New York City and New York State. See, e.g., https://www.regulations.gov/document/FTC-2023-0033-0001/comment?filter=%22new%20york%22.
      We applaud the Mamdani administration for tackling these long-festering anti-consumer practices with urgency and alacrity. Whereas current Federal Trade Commission (FTC) Chair Ferguson took six months to take any steps to start reviving efforts relating to this issue after a procedural setback in court, under Commissioner Sam Levine, the DCWP moved about twice as quickly, proposing rules within the Mamdani administration’s first 100 days.
  As noted in our attached recent comment to the FTC, one-off enforcement efforts have proven to be insufficient deterrence across the subscription economy, so every day matters in bringing relief to beleaguered consumers. We urge the DCWP to finalize these rules quickly.

  Comment attachment
  2026-4-13-AELP-Comment-re-Prenotification-Negative-Option-Plans-aka-Click-to-Cancel-FINAL-FTC-2026-0265-0067.pdf

  Comment added May 7, 2026 6:48pm

• Brad Lipton and Noa Rosinplotz, Roosevelt Institute

  May 8, 2026

  Dear New York City Department of Consumer and Worker Protection,

  Based in New York City, the Roosevelt Institute is a think tank, a student network, and the nonprofit partner to the Franklin D. Roosevelt Presidential Library and Museum. Roosevelt’s think tank engages in critical research and policy development to advance new ideas that rebalance power and repair past harms—so that our economy and society work for everyone.

  The Roosevelt Institute is glad that the Department of Consumer and Worker Protection is considering adding rules to ensure that consumers can easily cancel subscriptions and are not subject to deceptive and unconscionable trade practices relating to the cancellation of subscriptions. To the degree that it is helpful in your consideration of the rule, the Roosevelt Institute has analyzed the potential benefits of the proposed rule, applying the methodology used by the Federal Trade Commission (FTC) in its similar rulemaking with appropriate adjustments for New York City.

  The FTC’s methodology offers low and high estimates of the benefits of the rule. These estimates are based on the rule’s direct consumer benefit of easier subscription cancellations, which will create time savings for consumers when cancelling subscriptions and, in some circumstances, save consumers months of subscription fees by successfully cancelling subscriptions earlier. According to our analysis, those benefits for the adult population of New York City would range from $21.5 million to $162.5 million per year, saving New Yorkers at least 600,000 hours per year. Over the course of 10 years, the total economic benefits we calculate from the rule (that is, present discounted value) would range from $197.3 million to $1.491 billion. We also perform a sensitivity analysis that shows these estimates are not significantly affected by different numerical assumptions and discuss factors that could lead these estimates to overstate or understate the benefits from this rule.

  While some of the factors we identify in our sensitivity analysis suggest this approach could overestimate benefits (for example, if proximity makes it easier for New Yorkers to cancel subscriptions in person), on balance it seems likely that our estimates significantly understate the benefits of the rule due to effects that the FTC did not attempt to quantify. Specifically, New Yorkers may benefit from a more competitive marketplace in which companies, aware that it is now easier to cancel subscriptions, provide better quality or prices to keep consumers from cancelling. Additionally, the rule may improve consumer confidence in using subscriptions and increase the number of consumers who are willing to subscribe and obtain the convenience and possible cost savings that subscriptions can provide, benefiting scrupulous businesses as well. And New York consumers may be spared the cost of additional unwanted subscriptions that will be easier to cancel.

  We have explained our analysis in the attached appendix.

  Thank you for your work on this rulemaking.

  Sincerely,

  Brad Lipton
  Director, Corporate Power and Financial Regulation
  Roosevelt Institute

  Noa Rosinplotz
  Senior Research Associate
  Roosevelt Institute

  Comment attachment
  Roosevelt-Institute-Submission-to-NYC-5.8.26.pdf

  Comment added May 8, 2026 11:00am

• Jessica Walker, Manhattan Chamber of Commerce

  The Manhattan Chamber of Commerce supports DCWP’s goal of ensuring consumers can easily cancel subscriptions but raises four concerns with the proposed rule: it should clearly exclude business-to-business transactions, which involve negotiated contracts unlike consumer sign-ups; the “same medium” cancellation requirement is unnecessary so long as the cancellation mechanism is simple and easy; the restriction on presenting “save offers” at cancellation should be struck because retention discounts often benefit consumers, particularly those considering switching providers; and the exemptions list should be expanded to cover telecommunications and other providers regulated by the Federal Communications Commission and New York State Public Service Commission, where duplicative City rules conflict with existing federal authentication requirements and fail to account for practical realities like number porting, device installment contracts, and bundled services.

  Comment attachment
  DCWP-WRITTEN-COMMENTS-MAY-2026-CLICK-TO-CANCEL.pdf

  Comment added May 8, 2026 11:28am

• Anonymous

  I strongly support NYC’s proposed rule on cancellation of subscriptions. I recently experienced an issue with Hers where I was charged again for a prescription subscription, but I do not believe the renewal terms were clearly communicated to me.

  When I reviewed the messages from the prescribing provider, the messages focused on the medication, dosage, side effects, and treatment instructions. I did not see a clear statement explaining that I would be automatically charged again, the renewal date, the amount of the future charge, or how to cancel before being charged. I also receive text messages from the company, but I did not receive a clear renewal reminder before the charge.

  When I contacted customer service, I was told that the person who prescribed the medication had informed me about the automatic charge. Based on the messages available to me, that is not accurate. A consumer should not have to search through medical messages, account pages, emails, and texts to figure out whether a company is going to charge them again.

  This is why strong subscription cancellation and renewal rules are needed. Companies should be required to clearly disclose automatic renewal terms at the time of purchase, send a clear reminder before renewal charges, provide a simple cancellation method, and give prompt refunds when consumers are charged without clear notice. Prescription and telehealth subscription services should not be able to bury renewal terms or rely on vague claims that a consumer was informed when the actual messages do not clearly show that.

  Comment added May 8, 2026 4:23pm

• Matthew Henning

  Please see attached submission on behalf of Tech:NYC

  Comment attachment
  Tech_NYC-NYC-DCWP-Click-to-Cancel-comments.pdf

  Comment added May 8, 2026 4:46pm