In 2024, the FTC finalized its “click-to-cancel” rule, which tried to make it as easy for consumers to cancel their enrollment in recurring subscriptions ias it was to sign up. In 2025, the Eighth Circuit vacated that rule on notice-and-comment grounds.
Today, New York City’s Department of Consumer and Worker Protection proposed its own version of the rule. Given that the City’s DCWP Commissioner was the Director of the FTC’s Bureau of Consumer Protection at the time of the 2024 FTC rule, it is not surprising that the rule has many of the features of the vacated federal rule. The City’s announcement is available here.
