How to Prepare for New York City’s New Click-to-Cancel Rule

On October 1, 2026, New York City’s new click-to-cancel rule will take effect, creating the nation’s first municipal subscription-cancellation framework and establishing new compliance requirements for health and fitness facilities operating within the five boroughs.

While New York operators have already adapted to significant changes under the state’s automatic renewal law enacted last year, the city rule goes further by requiring cancellation through every enrollment channel, adding new consumer notice requirements, and creating city-specific enforcement authority and civil penalties. As a result, New York City operators must now comply with both state law and an additional layer of municipal requirements.

This marks the first time a municipality has adopted its own comprehensive subscription cancellation framework, signaling that local governments are becoming increasingly active in regulating recurring subscription services.

From the outset, HFA actively engaged throughout the rulemaking process on behalf of the industry. HFA supports clear, transparent, and consumer-friendly cancellation policies and has worked with lawmakers across the country to modernize laws for health clubs and studios in ways that protect consumers while remaining practical for businesses to implement.

As the rule moves from policymaking to implementation, HFA’s focus has shifted to helping members comply. HFA has developed a comprehensive "New York City Click-to-Cancel Compliance Guide" that explains the final rule, compares the city and state requirements side-by-side, provides practical implementation recommendations, and includes a compliance checklist to help facility operators prepare for October 1. (For more information, contact Cassie Losey, senior manager of state affairs.)

What’s Changing and How to Adjust

The final rule is the culmination of a broader consumer protection initiative launched by Mayor Zohran Mamdani. Earlier this year, his administration directed the New York City Department of Consumer and Worker Protection (DCWP) to increase enforcement of existing cancellation requirements, beginning with warning letters sent to nearly 200 health club operators reminding them of their obligations under current law. The city then proposed its click-to-cancel rule, initiating a formal rulemaking process that ultimately resulted in the adoption of the final regulation.

In its comments, HFA urged DCWP not to regulate beyond New York State’s recently enacted automatic renewal law, arguing that the state’s updated framework already provides comprehensive consumer protections. HFA cautioned that layering additional municipal requirements on top of state law would create an unnecessarily burdensome compliance landscape for operators, increase operational complexity, and result in inconsistent compliance obligations for businesses operating across multiple jurisdictions.

HFA also recommended several practical improvements to the proposed rule. Most notably, the association urged the city to clarify that legitimate membership retention, or “save” offers, such as membership freezes, discounted rates, or modified memberships, should remain permissible, provided they do not interfere with a consumer’s ability to cancel. The final rule incorporated that clarification, expressly confirming that businesses may continue offering these consumer-friendly options as long as they do not unreasonably delay or obstruct cancellation.