On July 10, 2026, New York City Department of Consumer and Worker Protection (DCWP) finalized and adopted its “Click-to-Cancel Rule,” which takes effect on Oct. 1, 2026. The Rule remains largely unchanged from the March 25, 2026, Notice of Public Hearing and Opportunity to Comment, which we previously covered.
Adoption of the Click-to-Cancel Rule follows the DCWP’s recently adopted “Hotel Junk Fees” Rule banning hidden fees on hotel stays. DCWP has also proposed a “Junk Fees Rule,” which would apply to businesses beyond hotels. The proposed rule would make it a deceptive and unconscionable trade practice to advertise, display, or offer a price for a good or service without clearly and conspicuously disclosing the total price, including all mandatory fees and charges. “For years, companies have built their business model around making it harder for working people to hold onto their money,” said Mayor Mamdani in a press release. “Whether it’s hidden fees that suddenly appear at checkout or subscriptions that take one click to sign up for and a dozen steps to cancel, the result is the same: working people pay more while corporations profit. That ends now. If you can sign up with one click, you can cancel with one click.”
“The Mamdani Administration is shutting the door on the era of fleecing New Yorkers with junk fees and subscription traps,” said Commissioner Samuel A.A. Levine. “These two rules will ensure that the price you see is the price you pay—no hidden charges, no endless subscription services and no advantages for businesses that cheat. Requiring companies to compete on price will lower costs for all New Yorkers and level the playing field for honest businesses.”
Click-to-Cancel Rule Highlights
The rule applies to a subscription for any type of goods or services that meets the definitions of automatic renewals (plans in which a paid subscription or purchasing agreement is automatically renewed at the end of a definite term for a subsequent term) or continuous service offers (plans in which a subscription or purchasing agreement continues until the consumer cancels the service).
The rule requires that businesses:
- Provide Clear, Conspicuous Pre‑Purchase Disclosures: Businesses must disclose — prominently and in close proximity to consent requests — the description of the subscription, total cost and billing frequency, cancellation deadlines, cancellation methods, and the terms of any free trials, gifts, or temporary pricing (including when and how prices change) before requesting consumers’ consent or billing information.
- Offer Simple Cancellation Mechanisms: Businesses must allow consumers to cancel subscription plans at any time using a simple mechanism through the same medium they used to enroll (e.g., online sign‑up would require an online cancellation option) and through all methods in which the business allows consumers to provide consent to the subscription plan or renewal. Where the consumer enrolled in person, businesses must still offer online cancellation options “where practical.”
- Prohibit Cancellation Obstructions: Businesses are prohibited from obstructing or unreasonably delaying cancellation, expressly prohibiting businesses from hanging up on consumers who call to cancel, obscuring cancellation pathways, misrepresenting cancellation consequences or delays, or offering retention discounts or benefits while simultaneously obstructing or delaying cancellation.
- Issue Renewal and Change Notices: Businesses must issue advance notice: (a) 15 to 45 days before cancellation deadline for renewals for subscriptions with an initial paid term of one year or more; (b) 3 to 21 days before the first billing deadline for free trials longer than one month; and (c) 5 to 30 days before any material changes, including price increases. Businesses must also deliver notices via the consumer’s selected channel (email, text, app notification, etc.) and include cancellation instructions.
The rule goes into effect Oct. 1, 2026. After this date, companies found violating the rule face an initial $525 fine per violation and up to $3,500 for repeat offenses, and are liable for restitution of the amounts charged after a consumer’s first cancellation attempt.
Certain businesses — such as entities regulated by the Department of Financial Services, banks and other licensed financial institutions, and certain sellers of insurance — are exempt from the rule.
Hotel Junk Fees Rule Highlights
The rule applies to any person who offers, displays, or advertises the price of a stay in a hotel in New York City or who offers, displays, or advertises the price of a stay in a hotel to a New York City consumer.
The rule requires that businesses:
- Display All-In Pricing: Hotels and booking platforms must clearly disclose the total price of a stay, including all mandatory fees, whenever a price is advertised or displayed. Taxes and government-imposed fees may be excluded.
- Prohibit Misleading Fee Descriptions: Businesses may not misrepresent the nature, purpose, amount, or refundability of hotel fees or charges.
- Disclose Excluded Fees: Before a consumer pays, businesses must disclose any fees excluded from the advertised total price, the purpose and amount of those fees, and the final amount the consumer must pay.
- Disclose Deposit and Hold Policies: Before a consumer pays, businesses must disclose the hotel’s general deposit or hold policy, the standard hold/deposit amount, circumstances under which some or all of the deposit may be retained, and the approximate timeframe for release or refund.
Companies found violating the rule face an initial $525 fine per violation and up to $3,500 for repeat offenses.
The rule went into effect on Feb. 21, 2026, with the deposit and hold requirement provisions effective Jan. 22, 2027.
Proposed Junk Fee Rule Highlights
The proposed rule would make it a deceptive and unconscionable trade practice to advertise, display, or offer a price for a good or service without clearly and conspicuously disclosing the total price, including all mandatory fees and charges. The proposed rule would apply generally to any person or business offering, displaying, or advertising goods or services in New York City or to New York City consumers.
- Advertised Prices Must Include Mandatory Fees: The proposed rule would require that any advertised or displayed price must include all mandatory fees and charges that a consumer must pay to purchase the product or service. Mandatory fees include fees that are not reasonably avoidable by consumers, fees that are difficult to remove during the purchasing process, and charges for aspects of the product or service that a reasonable consumer would expect to be included in the advertised offering.
- Total Price Must Be Prominent: The proposed rule would require businesses to display the total price at least as prominently as any other pricing information. This requirement applies whether pricing is expressed as a fixed amount, hourly rate, monthly fee, or per-unit charge.
- Additional Fee Breakdown Before Purchase: Before a consumer consents to pay, businesses would be required to provide a clear breakdown of any fees excluded from the advertised total price, the nature, purpose, and amount of those charges, the product or service associated with the charge, and the final amount the consumer must pay. Taxes, government-imposed fees, and certain actual shipping or postage charges may be excluded from the advertised total price but must still be disclosed before payment.
- Recordkeeping Requirements: The proposed rule would require that business maintain records sufficient to substantiate the basis, purpose, amount, and refundability of fees and charges; businesses would be required to provide those records to DCWP upon request. Failure to maintain or produce required records might create a presumption in an enforcement action that DCWP’s allegations regarding those fees are true.
Companies found violating the rule as proposed would face an initial $525 fine per violation and up to $3,500 for repeat offenses.
DCWP will hold a public hearing on the proposed Junk Fees Rule on Aug. 7, 2026, at 11:00 a.m. ET; any person or party interested in submitting comments should do so by Aug. 7, 2026.
Takeaways for Businesses
New York City’s Click-to-Cancel Rule, Hotel Junk Fees Rule, and proposed Junk Fees Rule reflect a growing regulatory trend toward comprehensive price and subscription transparency requirements. And, if adopted, New York City’s Junk Fees Rule would create one of the broadest local all-in pricing requirements in the United States.
Businesses advertising to New York City consumers should consider reviewing their online checkout flows, pricing displays, subscription offerings, booking platforms, and fee practices to confirm that mandatory charges are included in advertised prices and supported by appropriate documentation. And Companies using negative option features — automatic renewals, continuity programs, trial‑to‑paid conversions, or bundled offers — should consider proactively evaluating their disclosures, consent mechanisms, renewal-notification practices, and cancellation pathways to comply with the nationwide patchwork of requirements.
We have provided ongoing analysis and commentary regarding developments concerning all-in-pricing requirements in advertising and auto-renewal subscriptions, including the prior client alerts and blog posts listed below:
- NYC Proposes New Rules for Auto-Renewal Subscriptions (April 8, 2026)
- FTC Seeks Comment on Potential Updates to Negative Option Rule (March 16, 2026)
- Eighth Circuit Vacates FTC’s ‘Click-to-Cancel’ Rule (July 11, 2025)
- FTC Extends ‘Click-to-Cancel’ Rule Deadline (May 23, 2025)
- FTC Issues FAQs on ‘Junk Fees’ Rule (May 15, 2025)
- FTC Alleges Fintech Cleo AI Deceived Consumers (March 31, 2025)
- FTC Alleges Fintech Dave, Inc. Deceived Consumers (Nov. 15, 2024)
- CFPB Launches Public Inquiry into Rising Mortgage Closing Costs and ‘Junk Fees’ (June 4, 2024)
- FTC Takes Action Against Doxo, Citing Junk Fees (June 3, 2024)
- California AG Publishes FAQs on California’s ‘Junk Fee’ Law (May 30, 2024)
- Tim Butler Quoted in LA Times Article on California ‘Junk Fees’ (Apr. 11, 2024)
- CFPB Releases Report Highlighting Junk Fees on Mortgage Servicing (March 23, 2024)
- CFPB Unveils Final Rule Banning ‘Excessive’ Credit Card Late Fees (Mar. 13, 2024)
- CFPB Issues Proposed Rule to Stop ‘Junk Fees’ on Bank Accounts (Feb. 1. 2024)
- FTC Proposed Rule Targeting ‘Junk Fees’ (Oct. 16, 2023)
- CFPB Issues Advisory Opinion on ‘Illegal Junk Fees’ By Large Financial Firms (Oct. 12, 2023)