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New York City has become the latest jurisdiction to crack down on hard-to-cancel subscriptions.
The city’s new “click to cancel” rule, which took effect Thursday, requires businesses to make it easier for customers to end subscriptions that renew automatically. While New York state already requires a cancellation method as easy as sign-up, this gives the city authority to enforce similar protections locally and is providing a website portal for consumers to complain about violations.
“If a company can take your money with one click, you should be able to get your money back with one click,” said Mayor Zohran Mamdani in a news release Thursday.
New York City is the first municipality to adopt a click-to-cancel rule, according to city officials, joining a growing number of states that have enacted or strengthened laws governing automatic subscription renewals and cancellations as the possibility of a nationwide standard remains unsettled.
“Automatic renewals have been a pain point for consumers, and this is a popular topic with regulators, especially now given the increased focus on affordability, so I expect we’ll continue to see more of these laws on the state level,” said Gonzalo Mon, a partner with the law firm of Kelley Drye & Warren in Washington.
Complaints about ‘negative option’ subscriptions grow
So-called “negative option” subscription contracts — those that automatically renew unless consumers cancel them — have generated a growing number of complaints as their prevalence and use have increased, according to experts. While these subscriptions are easy to sign up for, they can be difficult to cancel.
Each year, U.S. adults spend an average of $1,080 on subscriptions, according to a survey by CNET, a media website focused on consumer technology. By generation, millennials spend the most annually, at an average $1,215. The survey was conducted online in April 2025 by YouGov and involved 2,440 adults.
The survey found that consumers spend an average of $205 annually on subscriptions they no longer use.
In 2024, the FTC received an average of nearly 70 consumer complaints per day about hard-to-cancel subscriptions, up from 42 daily in 2021, according to the agency.
Artificial intelligence may also be giving consumers a new way to deal with unwanted subscriptions. For example, Meta‘s new AI agent, Muse, says it can cancel subscriptions on a user’s behalf.
Meanwhile, more than half of states have rules that govern automatic renewals, Mon said.
“Although there are some variations, the laws generally address similar themes,” he said.
The laws typically require upfront disclosure of key terms, consumer consent and confirmation, and an easy way to cancel, Mon said. Some also require renewal reminders.
What’s going on at the federal level
The FTC finalized a national click-to-cancel rule in October 2024 under the Biden administration. It was quickly challenged in court by a range of business and trade groups, including the U.S. Chamber of Commerce and the National Federation of Independent Businesses.
About a week ahead of the rule taking effect in mid-July 2025, the Eighth Circuit Court of Appeals vacated it on procedural grounds.
However, the FTC may make another attempt at a federal rule. In a March 13 notice this year, the agency sought public input on whether to update its decades-old Negative Options Rule, including whether to adopt provisions of the vacated click-to-cancel rule. Comments were due April 13.
Given the notice, “it’s likely that the FTC will move forward, but we don’t know how or when,” Mon said.
It’s likely that the FTC will move forward, but we don’t know how or when.
Gonzalo Mon
Partner with Kelley Drye & Warren
In the meantime, the FTC has continued to pursue companies over their subscription practices using existing federal consumer-protection laws.
For example, the agency announced a $35 million settlement in May with Shutterstock over allegations of unfair and deceptive practices that included making subscriptions difficult to cancel.
Additionally, several bills that seek to authorize click-to-cancel rules are pending in Congress, including the bipartisan and bicameral Unsubscribe Act. Among other provisions, the measure would require companies that offer subscriptions to provide easy cancellations and to get consumers’ approval before charging them after a free or reduced-cost period.
