New York City's click-to-cancel rule took effect on October 1, 2026, adding city penalties and a refund rule to the subscription rules New York State updated in November 2025 and California in July 2025. For you, the date that decides whether you pay is the last day you can cancel under your terms, not the renewal date on your receipt, and in New York City the date of your first cancellation attempt now matters too. New York's reminders are timed around that cancellation deadline, and most short free trials trigger no legal reminder at all, so track the deadline yourself.
Key takeaways
- The date that decides whether you pay is the cancellation deadline, and it can come before the renewal date. Apple can charge up to 24 hours before a new period starts, and Google Play may place a hold on your card up to 48 hours before.
- State reminder laws mostly cover trials longer than a month and plans of a year or more. California requires a reminder 3 to 21 days before a trial of more than 31 days ends and 15 to 45 days before a plan of one year or longer renews; New York State and City count the same windows back from your cancellation deadline.
- After an unwanted charge, your billing-error notice must reach a credit card issuer within 60 days after it sent the first statement showing the charge. For debit cards, your bank must get notice of an error within 60 days after it sent the statement.
- Cancelling usually stops the next charge, not the access you have paid for. Google Play keeps your access until the paid period ends, and Minnesota law makes a cancelled auto-renewal end at the close of the current term.
What it means for you
- On a free trial now: find the exact cancellation deadline in the sign-up confirmation. If the trial lasts a month or less, most state laws require no reminder (Illinois is an exception for trials of 15 days or longer), so set your own. The dated example below shows each step.
- On an annual plan: California, New York, Illinois and Colorado require a reminder at least 15 days before renewal or the cancellation deadline, and Virginia does when the renewal extends the agreement by more than 12 months. Each state attaches conditions, such as New York's rule that the plan must renew for at least 6 months; see the comparison table.
- Subscribed through Apple or Google: cancel in the store, not the app. Allow at least a full day before the trial or period ends, and remember that deleting the app doesn't cancel anything.
- California or New York residents: California also requires 7 to 30 days' notice of a price change. In New York, a company that raises your price without consent must let you cancel within at least 14 days of the charge and refund the rest. In New York City, a business that breaks the rule is liable for anything it charged after your first attempt to cancel.
- Disputing a charge: the clock runs from the date the statement is sent, not the charge date, and it protects errors such as unauthorized charges, not every renewal you forgot to cancel. See the section on deadlines after a bad charge.
The six dates in a subscription
Every subscription, from a meal-kit box to a gym membership or a software license, runs on the same handful of dates. Your terms or the confirmation email should state most of them.
- Sign-up date. It starts the trial or first term and decides which version of a state law applies. California's 2024 amendments, for example, apply only to contracts entered into, amended or extended on or after July 1, 2025.
- Trial or promotional-price end. The last day before the full price applies.
- Cancellation deadline. The last moment you can cancel and avoid the next charge. New York's law requires sellers to disclose this "deadline by date or frequency" before you consent.
- Renewal or charge date. When the next period begins and the payment is taken, or when the store pre-authorizes it.
- Price-change date. When a new price takes effect, which starts the notice clocks in some states.
- Statement date. The date your card or bank statement showing the charge is sent. This starts the federal 60-day dispute windows.
Federal law sets none of the reminder dates. The Restore Online Shoppers' Confidence Act requires online sellers to disclose material terms, get express consent and offer simple ways to stop recurring charges, but it sets no reminder timetable. The FTC's 2024 click-to-cancel rule was vacated, and the agency asked for comment on a new approach in March 2026. The dates therefore come from state and city law, your contract and payment rules.
Reminder windows by state
The table compares the timing duties in seven state and city laws, as published in October 2026. "Before the deadline" means counted back from the cancellation deadline in your terms. "Before renewal" means counted back from the renewal date.
| Jurisdiction | Free trial reminder | Renewal reminder | Price or terms change |
|---|---|---|---|
| California | Trials or promo prices lasting more than 31 days: 3 to 21 days before they end | Initial term of 1 year or longer: 15 to 45 days before renewal; plus an annual reminder | Fee change: 7 to 30 days before it takes effect |
| New York State | Trials of more than a month: 3 to 21 days before the deadline for the first paid period | Initial paid term of 1 year or longer that renews for 6 months or longer: 15 to 45 days before the deadline | Material change, including price increases: 5 business days to 30 days before |
| New York City | Same as New York State | Same as New York State | Same as New York State |
| Minnesota | Trials of more than 30 days: 5 to 30 days before they end | Continuous service: written notice at least once per calendar year | Material change: before it takes effect |
| Virginia | Trials of more than 30 days: within 30 days of the end | Renews after more than 30 days and extends the agreement more than 12 months: 30 to 60 days before the deadline or term end | Material change: before it takes effect |
| Colorado | No set window; you must be able to cancel before paying | 25 to 40 days before each renewal; for terms under 12 months, before each renewal that extends the contract past another 12 continuous months | Material change: notice, no set window |
| Illinois | Trials or promo periods of 15 days or longer: at least 3 days before the deadline | Term of 12 months or more that renews for more than a month: 30 to 60 days before the deadline | No set window in the act |
Sources by row: California Bus. & Prof. Code §17602; New York budget bill A.3008-C, Part W amending GBL §527-a; NYC DCWP Click to Cancel rule; Minnesota Stat. §325G.57; Virginia Code §59.1-207.46; Colorado Rev. Stat. §6-1-732 (consolidated copy); 815 ILCS 601/10.
The conditions behind the numbers
- California exempts banks and credit unions, insurers, alarm companies, service-contract sellers, and services provided under a local-government or utilities-commission franchise or regulated by the state utilities commission, the FCC or FERC, according to §17605. If a plan qualifies for both the trial reminder and the one-year-term reminder, the statute requires only the one-year-term notice, 15 to 45 days before renewal. The trial reminder can be skipped if you signed up offline and the business has no email, phone number or other electronic way to reach you. The statute requires the annual reminder for "annual" auto-renewal and continuous-service agreements but sets no day window for it.
- New York State's current rules took effect on November 5, 2025, 180 days after the governor signed the bill on May 9, 2025. Reminders must go through the channel you select, such as text, email or app notification, and must include instructions for cancelling.
- New York City's rule, adopted by the Department of Consumer and Worker Protection, took effect on October 1, 2026. It mirrors the state timings. It adds penalties starting at $525, and a business found in violation owes you whatever it charged after your first attempt to cancel. That makes the date of your first cancellation attempt worth recording.
- Minnesota's law took effect on January 1, 2025, for contracts entered into, modified or renewed on or after that date, according to the session law.
- Virginia's 2026 amendments (2026 Acts, chapters 931 and 932) require a cancellation option through each channel you could use to sign up, with a separate rule for in-person sign-ups. They took effect in 2026; Virginia's laws generally take effect on July 1.
- Colorado's 25-to-40-day notice has applied to contracts made since January 1, 2022, under HB21-1239. A 2025 law, SB25-145, tightened the cancellation rules, so people who signed up online must be offered a one-step online cancellation link, and widened who counts as a consumer (bill history).
A free trial, dated step by step
Illustrative example. A California resident signs up on a company's own website on Monday, October 5, 2026, for a 60-day free trial of a meal-kit service. The trial then converts to a $12 monthly plan billed to a credit card, and the card's statement closes on the 20th of each month. The terms say the trial covers October 5 through December 3 and the first charge comes on December 4. Every date below was counted in calendar days.
Reminder window opens = trial expiration − 21 days
Reminder window closes = trial expiration − 3 days
Dispute deadline = date of first statement showing the charge + 60 days
trial expiration: the end of the free period (here, the start of December 4, the charge date)
statement date: the date the card issuer sends the statement
| Date | What happens | Rule |
|---|---|---|
| Mon, Oct 5, 2026 | Trial starts; confirmation with cancellation steps due | CA §17602(a)(3) |
| Fri, Nov 13 to Tue, Dec 1, 2026 | Reminder must be sent in this 19-day window | CA §17602(b)(1)(A), 3 to 21 days |
| Thu, Dec 3, 2026 | Last free day; cancel by now to avoid the charge | Your terms |
| Fri, Dec 4, 2026 | First $12 monthly charge | Your terms |
| Sun, Dec 20, 2026 | Statement showing the charge is sent | Card account terms |
| Mon, Jan 4, 2027 | Second monthly charge | Your terms |
| Thu, Feb 18, 2027 | Last day for a billing-error notice on the December 4 charge to reach the issuer | Reg Z §1026.13(b), 60 days |
| Any later price rise | Notice due 7 to 30 days before the new price takes effect | CA §17602(g)(2) |
The numbers show three things. A reminder sent on November 13 leaves 20 days to decide before the last free day, while one sent on December 1 leaves 2, and both are on time. The dispute window for the first charge closes on February 18, 2027, 76 days after the charge, because it runs from the statement and not from the charge. And with a 30-day trial instead of 60, California would require no trial reminder at all, because its rule starts above 31 days.
If the same trial converted to an annual plan instead, the dates would shift. California's 15-to-45-day notice applies to plans with an initial term of one year or longer. When an offer qualifies for both that notice and the trial notice, §17602(b) requires only the 15-to-45-day one. The statute doesn't say whether a long free trial followed by a yearly plan counts as both, so for an annual plan, mark the trial deadline yourself.
The same trial bought through Apple's App Store moves the safe date earlier. Apple's Media Services terms say it charges no more than 24 hours before a new period starts, so the charge could come on December 3. Cancelling by December 2 avoids that overlap.
Cancelled vs. access ended
Three different dates get called "cancellation": the day you cancel, the day the cancellation takes effect, and the day your access stops. They rarely match.
- Auto-renewing terms usually run to the end. Under Minnesota §325G.59, cancelling an auto-renewing agreement takes effect at the end of the term in which you give notice. Cancelling a continuous service must take effect within 31 days of your verified notice, unless you choose a later date.
- Online cancellation ends the renewal, not the period. California requires businesses that sell online to let you end the automatic renewal online "immediately" through a prominent link or a pre-formatted email. The statute deals with stopping the renewal and sets no refund for time already paid.
- Mid-term price rises in New York come with a refund route. A business that charges a higher price without your consent must let you cancel within at least 14 days after that charge and refund the rest of the term on a pro rata basis.
App store subscriptions
When Apple or Google bills you, the store's dates apply. Apple's cancellation help page tells trial users to cancel at least 24 hours before the trial ends. Google's subscription help page says you keep access for the time you have already paid. Its example: a yearly plan bought January 1 and cancelled July 1 runs to December 31 and is not charged again. The same page says Google may place an authorization hold up to 48 hours before the next renewal period, and that uninstalling the app does not cancel the subscription.
Refunds also go through the store. Apple handles requests at reportaproblem.apple.com, according to its refund help page, and says to allow 24 to 48 hours for an update.
Deadlines after a bad charge
If a charge you didn't agree to slips through, federal payment rules give you a fixed window that starts at the statement, not the charge. These windows cover errors as the rules define them, such as an unauthorized charge or a service not delivered as agreed. A renewal you consented to and simply forgot to cancel may not qualify, so the cancellation deadline is still the date that protects you best.
Credit card charges
Under Regulation Z, 12 CFR 1026.13, a billing-error notice must be in writing, must reach the issuer at the address it discloses for billing errors, and must give your name and account number and say why you believe there is an error. It has to arrive no later than 60 days after the issuer sent the first statement showing the charge. Billing errors include charges for goods or services you did not accept or that were not delivered as agreed. The issuer must acknowledge your notice within 30 days and resolve it within two complete billing cycles, and no later than 90 days. Until then, you need not pay the disputed amount. If you pay the card through the issuer's own autopay plan, the issuer can't deduct the disputed amount if your notice arrives at least 3 business days before the scheduled payment.
Debit card and bank debits
Regulation E, 12 CFR 1005.11, gives you 60 days after the bank sends the statement on which an error first appears. Notice can be oral or written, but the bank may ask for written confirmation within 10 business days. The bank then has 10 business days to investigate, or up to 45 days (90 days for debit card purchases) if it provisionally credits your account within those 10 business days. Regulation E covers unauthorized and incorrect transfers, not disputes about the quality of a service. That makes it more useful to stop the payment before it happens, as the FAQ below explains.
This guide explains general rules as of October 2026 and is not legal advice. The terms you agreed to and the law where you live decide any particular case.
Frequently asked questions
Do these laws cover subscriptions I buy for my small business?
Usually not, because most define a consumer as someone buying for personal, family or household purposes. Colorado is the main exception: since February 16, 2026, under SB25-145, its law covers "a person that" seeks or acquires goods or services, with no personal-use limit, for contracts offered or renewed on or after that date. Virginia's definition also covers small businesses, meaning independently owned firms with 250 or fewer employees or average annual gross receipts of $10 million or less.
Are my bank, phone plan and insurance covered by these rules?
Often not. California exempts insurers, banks and credit unions, alarm companies, service-contract sellers, services provided under a local-government franchise and services regulated by the state utilities commission, the FCC or FERC. New York exempts banks, entities regulated by its Department of Financial Services, alarm operators, services provided under a local government franchise and service-contract sellers. Minnesota and Colorado also exempt services regulated by the FCC, under Minnesota §325G.62 and Colorado §6-1-732(5). New York City rejected an exemption for FCC-regulated telecom companies, so its rule applies to them.
What if a subscription box arrives that I never agreed to?
In California, New York and Minnesota, goods sent under an automatic renewal or continuous service without your affirmative consent count as an unconditional gift. You may keep, use or dispose of them, and you owe nothing, including return shipping. The rules are in California §17603, New York §527-a and Minnesota §325G.61.
How can I tell an Apple subscription is really cancelled?
Open the subscription in your Apple Account settings. Apple says that if there is no Cancel button, or you see an expiration message in red text, the subscription is already cancelled. If it isn't listed at all, Apple suggests searching your email for "receipt from Apple" to find which account was billed, or checking your statement because another company may be billing you.
Can my bank stop a recurring payment before it goes through?
Yes, for preauthorized transfers from your account. Under 12 CFR 1005.10(c), you can tell your bank orally or in writing at least 3 business days before the scheduled date. The bank can require written confirmation within 14 days of an oral request, and the order stops binding if you don't send it. The CFPB suggests also telling the company you are revoking permission, and notes that banks generally charge a fee for stop-payment orders.
Calendar reminders to set now
- For each subscription, find the cancellation deadline in the confirmation email or account page. Put it in your calendar, not the renewal date.
- Set an alert 3 days before each trial deadline, and a second one 2 days before if the trial is billed through Apple or Google.
- For annual plans, set an alert 6 weeks before renewal. If you live in California or New York and no reminder has arrived by about 2 weeks before the deadline, check your notification settings and the account page.
- When you cancel, save the confirmation and note the date of your first attempt, especially in New York City.
- For each card statement, note the statement date plus 60 days as your last day to dispute a renewal charge.
- To stop a debit or bank payment you can't cancel, contact your bank at least 3 business days before the next charge.
Sources
- California Business and Professions Code §17602 (as amended by AB 2863)
- California Business and Professions Code §17603
- California Business and Professions Code §17605
- New York State Assembly: A.3008-C (2025), Part W amending GBL §527-a
- NYC Department of Consumer and Worker Protection: Click to Cancel rule (PDF)
- Minnesota Statutes §325G.57
- Minnesota Statutes §325G.59
- Minnesota Statutes §325G.61
- Minnesota Statutes §325G.62
- Minnesota Session Laws 2024, chapter 114
- Code of Virginia §59.1-207.45
- Code of Virginia §59.1-207.46
- Colorado Revised Statutes §6-1-732 (FindLaw consolidated copy)
- Colorado General Assembly: HB21-1239, enrolled act (PDF)
- Colorado General Assembly: SB25-145, enrolled act (PDF)
- Colorado General Assembly: SB25-145 bill history
- Illinois Automatic Contract Renewal Act, 815 ILCS 601/10
- 15 U.S.C. §8403 (ROSCA)
- FTC: Advance notice on the Negative Option Rule (March 2026)
- CFPB: Regulation Z, 12 CFR 1026.13 (billing error resolution)
- CFPB: Regulation E, 12 CFR 1005.11 (error resolution)
- CFPB: Regulation E, 12 CFR 1005.10 (preauthorized transfers)
- CFPB: How do I stop automatic payments from my bank account?
- Apple Support: Cancel a subscription from Apple
- Apple Media Services Terms and Conditions
- Apple Support: Request a refund for apps or content
- Google Play Help: Cancel, pause, or change a subscription