NY: Coalition Letter in Support to Cancel A.3928A/S.5615

March 21, 2025
Honorable Kathy Hochul
Governor of New York State

RE: Support for A.3928A/S.5615 – Click to Cancel Act

Dear Governor Hochul,

On behalf of the undersigned organizations, we write to express our strong support for A.3928A/S.5615, which provides a modernized, balanced, and consumer-friendly approach to subscription renewal and cancellation processes. This legislation ensures consumers receive clear and timely information about their subscriptions while avoiding unnecessary, redundant, and frustrating processes for businesses and consumers that could create barriers and confusion to canceling services. We believe A.3928A/S.5615 is the right legislative vehicle for addressing subscription renewal and cancellation reforms this year, as it strengthens consumer protections while maintaining necessary business flexibility.

A.3928A/S.5615 improves consumer experiences while preventing confusion and unnecessary steps:

● Simplifies the cancellation process by avoiding excessive, multi-step consent requirements that could frustrate consumers, particularly through unnecessary pop-ups that contribute to consent fatigue.

● Provides consumers with important cancellation-related information, including how to retain access to saved content or adjust subscription preferences, while still giving them the flexibility to choose cancellation options that work best for them.

● Ensures timely price increase notifications through a straightforward and effective process that avoids duplicative and unnecessary notifications that may confuse or overwhelm consumers.

● Avoids establishing unnecessary burdens on businesses, by providing flexibility for businesses and consumers to communicate by modern methods, as opposed to prescriptive, out-of-date, requirements (such as mandated 1-800 numbers, cancellation via billboards, or by traditional mail).

By contrast, the provisions included in the Executive Budget proposal (TED Part W) introduce complex requirements that could ultimately frustrate consumers rather than empower them. Specifically, these provisions mandate multiple, redundant notifications, separate consent pop-ups, and restrictions that prevent businesses from providing consumers with useful information about their accounts, such as content retention options or alternative pricing structures. If adopted, it is likely that hundreds of thousands of New Yorkers could end up having the subscriptions they value cancelled for them, cutting off their access to the goods and services they want, as they multi-layered affirmative consent regime would overly complicate the subscription management process and place another tremendous burden on New Yorker residents.

By supporting A.3928A/S.5615, New York can establish clear, effective subscription renewal and cancellation policies that protect consumers while maintaining business flexibility and avoiding unnecessary hurdles. We urge you and the Legislature to adopt this bill’s approach as the best path forward for modernizing New York’s consumer protection laws in a way that benefits both consumers and businesses.

Thank you for your time and consideration. We look forward to working together to ensure fair and effective consumer protection policies in New York State.

Sincerely,

The Business Council of New York State
Tech:NYC
Buffalo Niagara Partnership
Capital Region Chamber
Business Council of Westchester
Greater Rochester Chamber
Centerstate CEO
Long Island Association
Internet Coalition
American Fintech Council
Partnership for New York City

CC:
‍Majority Leader Andrea Stewart-Cousins
NYS Senate Speaker Carl Heastie
NYS Assembly

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