NYC’s “Click to Cancel” rule takes effect, mandating same‑method subscription cancellations

Qué ocurrió

On October 26, 2026 New York City’s subscription‑trap rule became effective, requiring companies to let consumers cancel a subscription using the same method they used to sign up. The rule is enforced by the Department of Consumer and Worker Protection and provides for civil penalties for non‑compliance. It builds on a similar FTC rule that was vacated by the Eighth Circuit.

Por qué es importante para la confianza y el cumplimiento

• Its status is in effect. It is in force now.
• The rule creates a clear, enforceable right for consumers to cancel services, reducing predatory practices and limiting unnecessary collection of personal data.
• Takes effect October 26, 2026.

Who is affected

Recommended actions

1. Review consent, cookie and tracking practices against the requirement.
2. Check that privacy notices describe the practices this addresses.
3. Confirm access, correction, deletion and opt-out requests are handled within the required time.
4. Revisit retention schedules and data minimisation for the data involved.