# New York automatic renewal law

> New York General Business Law §§ 527 and 527-a after the November 5, 2025 rewrite — the disclosure with a deadline to act, consent, price-increase consent or refund, the notices, and cancellation as easy as sign-up, with every requirement cited.

New York's automatic renewal law, General Business Law §§ 527 and 527-a, was rewritten effective **November 5, 2025**.
It covers automatic renewal and continuous service offers to New York consumers and is enforced by the Attorney General
with civil penalties.

**New York Automatic Renewal Law (Prohibited Service Offer Practices)** — N.Y. Gen. Bus. Law §§ 527, 527-a (Art. 29-BB). Effective 2021-02-09. Status: in force. Source: <https://www.nysenate.gov/legislation/laws/GBS/527-A>

Material terms disclosed before consent or billing information; affirmative consent; consent or a refund right for price increases; prompt retainable post-consent notice; cancellation as easy as sign-up, in the same medium and every consent medium; no obstruction; 15-45 day renewal notice (1-year terms renewing for 6+ months); 5 business day-30 day material-change notice; 3-21 day trial notice (trials over a month). AG enforcement; civil penalties $100-$1,000.

*Scope:* Consumers (personal, family or household purposes; definitions in § 527). Exempt (§ 527-a(4)): services under a municipal franchise, DFS-regulated entities, security alarm operators, banks/credit unions/financial institutions, and service contract sellers and administrators (Ins. Law § 7902). Related but not cataloged: GBL § 5-903 (renewal notice for service, maintenance or repair contracts for real or personal property). New York City consumers are also covered by the stricter DCWP "Click to Cancel" rule (US-NY.NYC.*, effective Oct. 1, 2026).

- Amendment: L. 2023, ch. 728 (S5941-B), effective 2023-12-13: 15-45 day renewal notice for initial paid terms of one year or longer.
- Amendment: L. 2025, ch. 58, Part W (S.3008-C/A.3008-C), effective 2025-11-05: Comprehensive rewrite of § 527-a (see file header).

## What changed in 2025 {#2025}

- The sign-up disclosure must include the **deadline to act** to stop further charges (by date or frequency) and the
  cancellation mechanisms, before consent or billing information is requested (§ 527-a(1)(a)).
- **Price increases** need the subscriber's affirmative consent, or a right to cancel within at least 14 days after the
  higher charge with a pro-rata refund (§ 527-a(1)(b-1)).
- The post-consent notice must include the terms, the charges, their frequency, the deadline to act and the
  cancellation mechanisms (§ 527-a(1)(c)).
- **Cancellation as easy as sign-up**, in the same medium and in every medium in which consent can be given; no
  obstruction, false information or unreasonable delay (§ 527-a(1)(d), (d-1), (e)).
- Notices of **material changes**, including price increases, at least 5 business days and no more than 30 days before
  the change (§ 527-a(1)(g)), and **trial notices** 3 to 21 days before the cancellation deadline for trials longer than
  a month (§ 527-a(1)(h)).

The 15-to-45-day **renewal notice** for initial paid terms of one year or longer has applied since December 13, 2023
(§ 527-a(1)(f)).

## "In the manner the consumer selected" {#consumer-selected}

New York's renewal, trial and change notices go out "in the manner the consumer selected" — text, email, app
notification or another channel you offer. A template cannot show that, so Checkbox asks: the compliance plan includes
a question for the human (`attest_ny_notice_channel`), and the reminder checks stay `needs_review` in New York until it
is answered. The same applies to the price-increase consent or refund right (`attest_ny_price_increase`), which no
notice can provide by itself.

## Every New York requirement in the catalog {#catalog}

| Requirement | Citation | Applies when | Timing | Severity | Checkbox checks |
|---|---|---|---|---|---|
| **Disclose the material terms before consent or billing information is requested, next to the consent request** Present, clearly and conspicuously, the material terms of the offer — including a description of the product or service subject to renewal, the amount that will be charged, the frequency of charges, the deadline (by date or frequency) by which the consumer must act to stop further charges, and the cancellation mechanisms — before consent to the offer or billing information is requested, and in visual proximity (for voice offers, temporal proximity) to the request for consent. | N.Y. Gen. Bus. Law § 527-a(1)(a); § 527(2) | always | — | critical | `signup.disclosure.autorenew_language`, `signup.disclosure.price`, `signup.disclosure.frequency`, `signup.disclosure.cancellation_policy`, `signup.disclosure.term_length`, `signup.disclosure.proximity`, `signup.disclosure.conspicuous` |
| **Explain how and when a trial or temporary price changes, and the later price** If the offer includes a free gift or trial, or the price is temporary, clearly and conspicuously explain how and when the price will change and the price or prices that will subsequently be charged. | N.Y. Gen. Bus. Law § 527-a(1)(a) (second sentence) | free trial | — | critical | `signup.disclosure.trial_terms`, `signup.disclosure.price` |
| **Obtain affirmative consent before charging for the initial term** Do not charge the consumer or the consumer's account with a third party for the initial term of an automatic renewal or continuous service without first obtaining the consumer's affirmative consent to the agreement containing the renewal terms, including terms offered at a promotional or discounted price for a limited time. | N.Y. Gen. Bus. Law § 527-a(1)(b) | always | — | critical | `signup.consent.affirmative`, `signup.consent.not_prechecked` |
| **Price increases need consent, or a post-charge cancellation right with a pro-rata refund** Before charging an increased price (or a price higher than the one disclosed at sign-up), either obtain the consumer's affirmative consent to the increased price, or let the consumer cancel at any time within at least fourteen days after that charge and refund the price of the remaining term on a pro-rata basis. Consent is required only once per increase. | N.Y. Gen. Bus. Law § 527-a(1)(b-1) | always | — | high | `reminder.price_change` |
| **Send a retainable notice promptly after consent with the terms, charges, deadline and cancellation mechanisms** Promptly after the consumer consents, provide a notice the consumer can retain that includes: the terms of the agreement; the amount that will be charged; the frequency of charges; the deadline (by date or frequency) by which the consumer must act to stop further charges (for a trial, the date to cancel before the first charge); and the cancellation mechanisms. | N.Y. Gen. Bus. Law § 527-a(1)(c) | always | — | high | `confirmation.email.sent`, `confirmation.email.terms`, `confirmation.email.cancellation_instructions`, `confirmation.email.trial_terms` |
| **Cancellation as easy as sign-up, in the same medium** Give the consumer the option to cancel at any time using a simple cancellation mechanism that is as easy to use as the mechanism used to consent and that is available through the same medium the consumer used to consent (an online sign-up must be cancellable online). | N.Y. Gen. Bus. Law § 527-a(1)(d) | always | — | critical | `cancel.online_available`, `cancel.mechanism_findable`, `cancel.flow_friction`, `config.portal_cancel_enabled` |
| **Cancellation through every medium in which consent can be given** Allow cancellation at any time through all mediums by which the business allows consumers to consent to the automatic renewal, continuous service or any price increase. Where consent was obtained in person, in addition to an in-person method where practical, offer cancellation online or by telephone. | N.Y. Gen. Bus. Law § 527-a(1)(d-1) | always | — | high | `cancel.online_available`, `cancel.mechanism_findable` |
| **Do not obstruct, condition, ignore or unreasonably delay cancellation** Do not impose unreasonable or unlawful conditions on, refuse to acknowledge, obstruct, or unreasonably delay a cancellation request or attempt — e.g. hanging up on callers, giving false information about how to cancel, misrepresenting the consequences or costs of cancelling, or misrepresenting the reasons for processing delays. Discount/retention offers or information about the effect of cancelling are allowed only if they do not obstruct or unreasonably delay the cancellation. | N.Y. Gen. Bus. Law § 527-a(1)(e) | always | — | high | `cancel.flow_friction`, `cancel.confirmation` |
| **Renewal notice for initial paid terms of one year or longer** For an initial paid term of one year or longer that renews for a paid term of six months or longer, notify the consumer of the renewal charge 15 to 45 days before the cancellation deadline, in the manner the consumer selected (text, email, app notification or any other channel the business offers), with instructions on how to cancel. | N.Y. Gen. Bus. Law § 527-a(1)(f) | term ≥ 12 months | 15-45 days before the cancellation deadline | high | `reminder.annual_renewal` |
| **Notice of material changes, including price increases, 5 business days to 30 days in advance** Give consumers a clear and conspicuous notice of any material change to the terms, including any price increase, at least five business days and no more than thirty days before the change, through the consumer-selected channel used for renewal notices. | N.Y. Gen. Bus. Law § 527-a(1)(g) | always | 7-30 days before the price change | high | `reminder.price_change` |
| **Notice before a free gift or trial of more than a month converts to paid** If the offer includes a free gift or trial for more than a month followed by an automatic charge, notify the consumer 3 to 21 days before the cancellation deadline for the first chargeable period, in the manner the consumer selected (text, email, app notification or another channel offered), with instructions on how to cancel. | N.Y. Gen. Bus. Law § 527-a(1)(h) | free trial, trial ≥ 31 days | 3-21 days before the cancellation deadline | high | `reminder.trial_ending`, `config.trial_reminder_enabled` |
| **NYC: disclose the material terms before consent or billing information, next to the consent request** Before requesting consent or billing information, clearly and conspicuously disclose the material terms — the product, the amount and frequency of charges, the deadline (by date or frequency) by which the consumer must act to stop further charges, how to cancel, and any trial or temporary-price terms — in visual proximity to the request for consent. | 6 RCNY § 5-110.1(b) | always | — | critical | `signup.disclosure.autorenew_language`, `signup.disclosure.price`, `signup.disclosure.frequency`, `signup.disclosure.cancellation_policy`, `signup.disclosure.term_length`, `signup.disclosure.trial_terms`, `signup.disclosure.proximity`, `signup.disclosure.conspicuous` |
| **NYC: cancellation as easy to use as the consent mechanism, in the same medium** Provide a cancellation mechanism that is as easy to use as the mechanism the consumer used to consent and that is available through the same medium (an online sign-up must be cancellable online). | 6 RCNY § 5-110.1(c) | always | — | critical | `cancel.online_available`, `cancel.mechanism_findable`, `cancel.flow_friction`, `config.portal_cancel_enabled` |
| **NYC: offer online cancellation (website or email) for in-person sign-ups** Allow cancellation through every medium in which consent can be given. Where consent was obtained in person, also offer an online cancellation mechanism (website or email) — a telephone line alone is not enough (state law allows online or phone). | 6 RCNY § 5-110.1(d) | always | — | high | `cancel.online_available`, `cancel.mechanism_findable` |
| **NYC: do not obstruct, ignore or unreasonably delay cancellation (save offers included)** Do not obscure cancellation instructions, hang up on consumers, refuse to acknowledge a cancellation request or unreasonably delay processing it; save (retention) offers are allowed only if they do not impose unreasonable conditions on, or unreasonably delay, the cancellation (§ 5-110.1(e)(2)). | 6 RCNY § 5-110.1(e) | always | — | high | `cancel.flow_friction`, `cancel.confirmation` |
| **NYC: renewal notice 15-45 days before the cancellation deadline for one-year-plus terms** Where the initial paid term is one year or longer and the plan renews for a paid term of six months or longer, notify the consumer 15 to 45 days before the cancellation deadline, in the manner the consumer selected (text, email, app notification or another channel offered), with instructions on how to cancel. | 6 RCNY § 5-110.1(g) | term ≥ 12 months | 15-45 days before the cancellation deadline | high | `reminder.annual_renewal` |
| **NYC: notice of material changes, including price increases, 5 business days to 30 days in advance** Give the consumer a clear and conspicuous notice of any material change to the terms, including a price increase, at least five business days and no more than thirty days before the change, in the manner the consumer selected. | 6 RCNY § 5-110.1(h) | always | 7-30 days before the price change | high | `reminder.price_change` |
| **NYC: notice 3-21 days before a free trial of more than a month converts to paid** If a free gift or trial lasts more than a month and is followed by an automatic charge, notify the consumer 3 to 21 days before the cancellation deadline for the first chargeable period, in the manner the consumer selected, with instructions on how to cancel. | 6 RCNY § 5-110.1(i) | free trial, trial ≥ 31 days | 3-21 days before the cancellation deadline | high | `reminder.trial_ending`, `config.trial_reminder_enabled` |
| **NYC: refund everything charged after the consumer's first attempt to cancel** A business that violates the rule must refund every amount charged after the consumer's first attempt at cancellation. Honour the first cancellation attempt (confirm it and stop charging) so no charge follows it. | 6 RCNY § 5-110.2 | always | — | high | `cancel.confirmation`, `cancel.flow_friction` |

## New York City {#nyc}

**New York City "Click to Cancel" Rule (DCWP)** — 6 RCNY §§ 5-110 to 5-110.3. Effective 2026-10-01. Status: in force. Source: <https://www.nyc.gov/content/dam/nycgov/nyc-main/pdf/2026/Click-to-Cancel-Rule.pdf>

City rule mirroring GBL § 527-a: material terms (including the deadline to act) before consent or billing information; cancellation as easy as consent, in the same medium and every consent medium, with an online option (website or email) for in-person sign-ups; no obstruction or unreasonable save offers; 15-45 day renewal notice (initial term of one year or more renewing for six months or more) and 3-21 day trial notice (trials over a month) in the consumer-selected channel; 5 business day-30 day material-change notice. Violators refund every amount charged after the first cancellation attempt (§ 5-110.2); DCWP penalties $525 / $1,050 / $3,500. Evaluated under US-NY (the jurisdiction model has no city level).

*Scope:* New York City consumers. Exempt (§ 5-110.3): municipal franchise holders (e.g. cable), DFS-regulated entities, licensed alarm operators, banks and licensed financial institutions, and service-contract sellers. Territorial reach and interaction with state AG enforcement are open question 9 (hence medium confidence).

- Amendment: DCWP Notice of Adoption (proposed Apr. 8, 2026; hearing May 8, 2026; adopted July 10, 2026), effective 2026-10-01: Adds 6 RCNY Part 8 "Click to Cancel" (§§ 5-110 to 5-110.3).

> **Not legal advice**
>
> Rules drafted from the statute text and updated as new statutes come into effect. Automated checks, not legal advice.
