New York subscription auto-renewal law
Effective 2025-11-05 · Last reviewed 2026-06-26
The statute
N.Y. Gen. Bus. Law § 527-a (as amended eff. November 5, 2025, by Part W of the 2025-2026 NYS Transportation, Economic Development and Environmental Conservation Budget Bill, signed May 9, 2025)
Effective 2025-11-05
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N.Y. Gen. Bus. Law § 527-a (as amended eff. December 13, 2023, adding long-term renewal reminder requirement)
Effective 2023-12-13
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N.Y. Gen. Bus. Law § 527 (definitions for Article 29-BB)
Effective 2023-12-13
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What it addresses
Each requirement below is stated in plain English first, then cited to the statute so you can read the primary source.
Disclosure before purchase
The statute prohibits a business making an automatic renewal or continuous service offer from failing to present to the consumer, in a clear and conspicuous manner, the material terms of the offer — including a description of the product or service subject to renewal, the amount of costs that will be charged, the frequency of charges, the deadline by date or frequency by which the consumer must act to prevent or stop further charges, and the cancellation mechanisms — before consent to the offer or billing information has been requested, and in visual proximity (or, for voice offers, temporal proximity) to the request for consent. If the offer also includes a free gift or trial, or the price is temporary, the offer must include a clear and conspicuous explanation of 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)Read the statute →
Affirmative consent
The statute prohibits a business from charging 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 terms of the automatic renewal or continuous service offer, including terms of an offer made at a promotional or discounted price for a limited period of time. (Added/clarified by November 5, 2025 amendment.)
N.Y. Gen. Bus. Law § 527-a(1)(b)Read the statute →
Acknowledgment / confirmation
The statute requires a business to provide a notice promptly following the consumer's affirmative consent, in a manner capable of being retained by the consumer. The notice must include: (i) the terms of the automatic renewal or continuous service agreement; (ii) the amount of costs that will be charged; (iii) the frequency of charges; (iv) the deadline by date or frequency by which the consumer must act to prevent or stop further charges; and (v) the cancellation mechanisms described in paragraphs d and d-1.
N.Y. Gen. Bus. Law § 527-a(1)(c)Read the statute →
Cancellation mechanism
The statute requires a business to provide the consumer with the option to cancel at any time using a simple cancellation mechanism that is as easy to use as the mechanism the consumer used to provide consent and that is through the same medium the consumer used to provide consent (§ 527-a(1)(d)). The statute also requires providing the option to cancel through any other medium by which a consumer can consent to the subscription or any price increase (§ 527-a(1)(d-1)). Additionally, the statute prohibits imposing unreasonable or unlawful conditions on cancellation, refusing to acknowledge cancellation, obstructing, or unreasonably delaying a cancellation request. The statute provides examples of unreasonable conditions including hanging up on consumers who call to cancel or misrepresenting the reasons for delays. A business may present a discounted offer, retention benefit, or information about the effect of cancellation during the process, provided it does not obstruct or unreasonably delay cancellation (§ 527-a(1)(e)). (Provisions d, d-1, and e added/expanded by November 5, 2025 amendment.)
N.Y. Gen. Bus. Law § 527-a(1)(d), (d-1), (e)Read the statute →
Renewal reminder
The statute requires a business to notify a consumer of an automatic renewal or continuous service charge when the offer carries an initial paid term of one year or longer and the renewal term is six months or longer. Notice must be sent at least fifteen days before, but not more than forty-five days before, the cancellation deadline for such automatic renewal, in the manner selected by the consumer (which may include text, email, app notification, or any other notification channel offered by the business). The notice must include instructions on how to cancel. (Originally added effective December 13, 2023; carried forward in November 5, 2025 amendment.)
N.Y. Gen. Bus. Law § 527-a(1)(f)Read the statute →
Free-trial conversion notice
The statute requires a business to notify a consumer of an upcoming automatic renewal or continuous service charge when the offer includes a free gift or trial period of more than one month followed by a paid period. Notice must be sent at least three days before, but not more than twenty-one days before, the cancellation deadline for the first chargeable period, in the manner selected by the consumer. The notice must include cancellation instructions. (Added by November 5, 2025 amendment.)
N.Y. Gen. Bus. Law § 527-a(1)(h)Read the statute →
Price-change notice
The statute imposes two related obligations when a price increases. First (§ 527-a(1)(g)): the business must provide the consumer who accepted the offer with a clear and conspicuous notice of any material change to the terms — expressly including any price increases — at least five business days before, but no more than thirty days before, the date of the change, in the same manner required by paragraph f (i.e., via the channel selected by the consumer). Second (§ 527-a(1)(b-1)): the business may not charge the consumer a price higher than what was disclosed, or charge following a price increase, without either (i) first obtaining the consumer's affirmative consent to the increased price, or (ii) allowing the consumer to cancel within at least fourteen days after such charge and refunding the consumer the price of the remaining term on a pro rata basis. The statute provides that a business is not required to obtain affirmative consent to a price increase more than once before charging the increased price. (Both provisions added by November 5, 2025 amendment.)
N.Y. Gen. Bus. Law § 527-a(1)(b-1) and (g)Read the statute →
Penalties and enforcement
Civil penalty (court-imposed on AG application): up to $100 for a single violation and up to $500 for multiple violations resulting from a single act or incident. For a knowing violation: up to $500 for a single violation and up to $1,000 for multiple violations resulting from a single act or incident. The Attorney General may also seek an injunction and direct restitution. A business is not liable if it shows by a preponderance of evidence that the violation was not intentional and resulted from a bona fide error notwithstanding reasonable procedures. Source: N.Y. Gen. Bus. Law § 527-a(3), verified at https://codes.findlaw.com/ny/general-business-law/gbs-sect-527-a/ and corroborated by https://www.consumerfinancemonitor.com/2023/12/20/new-york-enacts-new-requirements-for-subscription-auto-renewals-and-credit-card-surcharge-pricing/
Attorney General enforcement: The AG may seek injunctive relief, restitution, and civil penalties under § 527-a(3). No major publicized AG enforcement actions specifically under § 527-a were located in this research as of June 2026, though the AG's office has historically been active in subscription-billing enforcement under GBL § 349 (deceptive acts and practices), which may provide a parallel private right of action. The Kelley Drye June 2025 alert (https://www.kelleydrye.com/viewpoints/blogs/ad-law-access/ny-quietly-amends-automatic-renewal-law) notes the November 2025 amendments echo the FTC's Negative Option Rule, which was vacated federally in early 2025, increasing state-level enforcement significance. Pollock Cohen (https://www.pollockcohen.com/media/blog/2024-10-28-new-yorks-new-auto-renewal-law) notes class-action lawsuit exposure as a practical compliance risk, likely channeled through GBL § 349(h). Pending 2025 legislation (NY S5615A / A3928) appeared in search results and may further amend the statute; status as of June 2026 was not verified in this research.
Caveats
1. Statutory text verified primarily through FindLaw (current as of January 1, 2026) and the indexed NY Senate open-legislation page; the NY Senate page is JavaScript-rendered and full text was obtained through the indexed prior version. Readers should verify the current official text at https://www.nysenate.gov/legislation/laws/GBS/527-A before relying on this dataset. 2. The full text of § 527-a(1)(d-1) (additional cancellation mechanism) was truncated in available sources; the description above is drawn from secondary law-firm summaries (Kelley Drye, Perkins Coie) and should be verified against the statutory text. 3. The definition of 'consumer' in N.Y. Gen. Bus. Law § 527 was not fully retrieved in this research; it is uncertain whether the statute covers only personal/family/household transactions or also commercial/B2B arrangements. The Perkins Coie alert implicitly treats NY as narrower than Colorado (which expressly expanded its definition to 'any person'), but this researcher did not verify § 527's precise text. 4. The 'bona fide error' safe harbor (§ 527-a(3)) — its precise scope — was not fully analyzed; the full statutory text should be reviewed. 5. GBL § 349 (deceptive acts and practices) may independently impose obligations and provide a private right of action with different remedies (actual damages, attorney fees, $50 statutory minimum); this was not analyzed here. 6. Pending 2025 bills (NY S5615A / A3928) may further amend the statute; their status as of June 2026 was not confirmed. 7. The November 5, 2025 amendments are in force as of the research date (June 2026) and represent the current operative law; the prior December 2023 amendment's renewal-reminder requirement is incorporated into the current § 527-a(1)(f).
Last reviewed 2026-06-26
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