Are state automatic-renewal laws stronger than the federal rule?

In some cases yes, some state laws impose stricter requirements than the vacated 2024 federal rule.

Is there city-level subscription enforcement too?

Yes — New York City signaled in early 2026 it would prioritize enforcement against deceptive subscription practices.

State Automatic Renewal Laws: What Protections Do You Actually Have?

Published 2026-06-08 · TrimWell Media

Direct answer: Roughly 30 U.S. states have enacted their own automatic-renewal laws, some of which are stricter than the federal Click-to-Cancel rule that was vacated in 2025, meaning meaningful consumer protections already exist at the state level regardless of federal rulemaking timing.

Why states moved first

State legislatures have historically acted faster than federal rulemaking on subscription and auto-renewal issues, in part because state consumer-protection statutes don't require the same lengthy notice-and-comment process federal agencies must follow.

What these laws typically require

Common provisions include clear disclosure of automatic-renewal terms before purchase, reminder notices before certain renewal charges (especially after free trials), and simple online cancellation for anything sold online.

Enforcement beyond the FTC

Some cities have begun taking their own action as well — New York City's Department of Consumer and Worker Protection, for example, signaled in early 2026 that it would prioritize investigating deceptive subscription practices under a mayoral executive order.

What this means practically

Even with the federal Click-to-Cancel rule still in rulemaking limbo, most consumers already have meaningful legal protection through ROSCA at the federal level and their own state's automatic-renewal law, which is worth knowing if a company makes cancellation unreasonably difficult.

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Frequently Asked Questions

How many states have automatic-renewal laws?: Roughly 30, as of 2026.
Are state automatic-renewal laws stronger than the federal rule?: In some cases yes, some state laws impose stricter requirements than the vacated 2024 federal rule.
Is there city-level subscription enforcement too?: Yes — New York City signaled in early 2026 it would prioritize enforcement against deceptive subscription practices.