It seems like a good rule, and I am eager to see what NYC’s enforcement is going to look like. I have historically been disappointed (as a life-long resident) by the discontinuity between the city’s eagerness to legislate and its recalcitrance around enforcement, particularly when public interest in any given topic fades.
(Compare the city’s historic problems around preventing illegal de-stabilization of rental units, inability to prevent the NYPD from parking on sidewalks, and so forth.)
> A person making an automatic renewal or continuous service offer to a consumer must 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 that the consumer used to provide consent and that is through the same medium that the consumer used to provide consent
So if a startup lets someone sign up using Stripe, for example, does this mean that they need to have a way to unsubscribe that is as easy as Stripe? Lots of companies have a way to unsubscribe electronically, but it requires logging in to your account, going into settings, saying you want to unsub, and possibly declining various offers to stay.
Surely at some point a company could cross the line of "a simple cancellation mechanism that is as easy to use as the mechanism the consumer used to provide consent". But where is the line exactly? Surely you don't have to have a big red cancel button on every page of your platform, but at the same time surely it can't be hidden 8 levels down in the settings.
Some examples would be helpful to let businesses and consumers know what is acceptable and what is not acceptable.
There's a funny thing when people don't like something where they can intentionally misunderstand it or impart artificial complexity onto it painting a picture like the rule is hard to comply with. I suppose to variation of a straw man argument. I honestly don't think this is one is hard to understand at all. If you can sign up through the web you should be able to cancel through the web. If you can sign up through the phone you should be able to cancel through the phone. Companies knowingly an intentionally make it harder to cancel than to sign up for obvious reasons that have nothing to do with doing right by the consumer. This is a very good law and it should be adopted everywhere.
Maybe those people who’ve spent so much time A/B testing where to put the signup buttons can use those skills to figure out where to put the cancel buttons so that they are as easy to find.
Worse. We are going to see signup flows that are initially simple but take the user through several steps to do it but not in a way to make them abandon the process.
> ...and possibly declining various offers to stay
Unless there were several efforts to get you to think twice before subscribing, clearly trying to get you to think twice before unsubscribing is not as easy to use.
I suspect that something as simple as 2-3 emails prior to renewal, each with a one-click (no auth needed) clear, unobscured "unsubscribe" button would be sufficient.
I don’t think anyone will have trouble figuring out a good way to comply with this. It’s not clear exactly where the line is, so just don’t go near it. Make it easy to cancel, job done. If a company wants to push the boundaries by making it as difficult to cancel as the rule allows, they’re running the risk of being on the wrong side of the line and suffering the consequences, and that’s their choice.
The only reason any company would have trouble complying with this rule is if they want to abuse customers to keep them from canceling when they want to cancel. The amount of sympathy I have towards such companies requires advanced scientific notation to quantify.
In my country the rule is "unsubscribe the same way you subscribed". So no bullshit with having to write a literal physical letter through the mail (yes really this happened) or having to call a callcenter in India and having to explain why you want to your stop subscription.
One abstract idea is to convert every digital event into a hook. The hook then goes into a local LLM that has a rule to figure out what to do with it. I use DDG or mozilla email aliases as much as I can. All my emails go to a local email client and for the non-spam classified mails I have a few rules(**) I am toying with right now:
1. If non-money sub, categorize its content and create a P1 watch event and a set of follow up actions.
2. If its a money/trial sub, create a P0 watch event and its own set of followup actions.
All watch events are queued for me by priority where i ask on the weekend: "Tell me P0 events", it then asks me what action. The ergonomic factor here is I the human can tune this valve on the information hose. There is also a dashboard for P0 notifications and an android push notification that notifies me of P0 events, but they aren't "consumed" until i decide. There are tons of places this can be useful: make progress on non-work related todos, systematic investment, writing year-end reviews.
None of this is rocket science.
**Local service webhooks are the key: Every web-hook has some kind of decision maker in it - an LLM + deterministic logic.
To avoid the overhead, we could simply adopt pro-consumer practices across the board? Easier than segmenting users and deciding which cancellation mechanisms are available to them based on region.
Alternatively, let people cancel easily everywhere. If you think it’s worth the extra revenue to geofence easy cancellations, then—well, you do you, but you are making a business judgment that the additional development cost is justified. This is different from VAT/sales tax etc., where it is in fact impossible to comply everywhere without discriminating by jurisdiction.
It’s an easy rule to comply with and nothing stops you from complying with it everywhere.
We will see a patchwork regime, where companies make it easy to cancel if you’re in NYC or another jurisdiction with similar rules, but difficult otherwise. When you see this, you must remember that the easiest thing would have been to make it easy for everyone to cancel regardless of location. That would be perfectly legal and it would be the cheapest option to build. If a company didn’t do that it’s because they made a deliberate choice to spend more money just so they could continue screwing some people over.
You can't seriously think this makes you sound like a sympathetic party, right? "Oh no, we have to maintain two codepaths now: the pro-social one for places with functional governments, and the slimy anti-consumer fuck-you one for everywhere else. Won't anyone think of our plight?"
> While I think this is a good idea, we already have so many different regions to comply with, now we're adding cities....
Lina Khan's FTC passed a rule to make click-to-cancel nationwide in 2024.
It was killed on procedural grounds by the highly conservative Eighth Circuit Court of Appeals.
The take-away from how it was killed boils down to "we (companies) know that we'd lose more than $100 million dollars if people could reasonably unsubscribe rather than deal with our dark patterns".
The old FTC would have been able to fix the procedural problem, but then Trump took office and gutted the FTC and destroyed all the good work it was doing.
Since the federal government is failing us, I support local governments doing the right thing. If enough do, companies will eventually be forced into compliance nationally because it won't be worth the complexity to have hundreds of regional carve-outs.
It seems like a good rule, and I am eager to see what NYC’s enforcement is going to look like. I have historically been disappointed (as a life-long resident) by the discontinuity between the city’s eagerness to legislate and its recalcitrance around enforcement, particularly when public interest in any given topic fades.
(Compare the city’s historic problems around preventing illegal de-stabilization of rental units, inability to prevent the NYPD from parking on sidewalks, and so forth.)
NYPD parking on sidewalks is more of a "who watches the watchmen" problem unfortunately.
> A person making an automatic renewal or continuous service offer to a consumer must 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 that the consumer used to provide consent and that is through the same medium that the consumer used to provide consent
So if a startup lets someone sign up using Stripe, for example, does this mean that they need to have a way to unsubscribe that is as easy as Stripe? Lots of companies have a way to unsubscribe electronically, but it requires logging in to your account, going into settings, saying you want to unsub, and possibly declining various offers to stay.
Surely at some point a company could cross the line of "a simple cancellation mechanism that is as easy to use as the mechanism the consumer used to provide consent". But where is the line exactly? Surely you don't have to have a big red cancel button on every page of your platform, but at the same time surely it can't be hidden 8 levels down in the settings.
Some examples would be helpful to let businesses and consumers know what is acceptable and what is not acceptable.
There's a funny thing when people don't like something where they can intentionally misunderstand it or impart artificial complexity onto it painting a picture like the rule is hard to comply with. I suppose to variation of a straw man argument. I honestly don't think this is one is hard to understand at all. If you can sign up through the web you should be able to cancel through the web. If you can sign up through the phone you should be able to cancel through the phone. Companies knowingly an intentionally make it harder to cancel than to sign up for obvious reasons that have nothing to do with doing right by the consumer. This is a very good law and it should be adopted everywhere.
And if you didn't have to click through a bunch of offers to subscribe, you shouldn't have to to cancel.
“It is difficult to get a man to understand something, when his salary depends on his not understanding it.”
― Upton Sinclair
Maybe those people who’ve spent so much time A/B testing where to put the signup buttons can use those skills to figure out where to put the cancel buttons so that they are as easy to find.
Worse. We are going to see signup flows that are initially simple but take the user through several steps to do it but not in a way to make them abandon the process.
I think the point of the law is - the same medium. If you signed up online, you should be able to cancel subscription also online.
> ...and possibly declining various offers to stay
Unless there were several efforts to get you to think twice before subscribing, clearly trying to get you to think twice before unsubscribing is not as easy to use.
I suspect that something as simple as 2-3 emails prior to renewal, each with a one-click (no auth needed) clear, unobscured "unsubscribe" button would be sufficient.
I don’t think anyone will have trouble figuring out a good way to comply with this. It’s not clear exactly where the line is, so just don’t go near it. Make it easy to cancel, job done. If a company wants to push the boundaries by making it as difficult to cancel as the rule allows, they’re running the risk of being on the wrong side of the line and suffering the consequences, and that’s their choice.
The only reason any company would have trouble complying with this rule is if they want to abuse customers to keep them from canceling when they want to cancel. The amount of sympathy I have towards such companies requires advanced scientific notation to quantify.
In my country the rule is "unsubscribe the same way you subscribed". So no bullshit with having to write a literal physical letter through the mail (yes really this happened) or having to call a callcenter in India and having to explain why you want to your stop subscription.
One abstract idea is to convert every digital event into a hook. The hook then goes into a local LLM that has a rule to figure out what to do with it. I use DDG or mozilla email aliases as much as I can. All my emails go to a local email client and for the non-spam classified mails I have a few rules(**) I am toying with right now:
1. If non-money sub, categorize its content and create a P1 watch event and a set of follow up actions.
2. If its a money/trial sub, create a P0 watch event and its own set of followup actions.
All watch events are queued for me by priority where i ask on the weekend: "Tell me P0 events", it then asks me what action. The ergonomic factor here is I the human can tune this valve on the information hose. There is also a dashboard for P0 notifications and an android push notification that notifies me of P0 events, but they aren't "consumed" until i decide. There are tons of places this can be useful: make progress on non-work related todos, systematic investment, writing year-end reviews.
None of this is rocket science.
**Local service webhooks are the key: Every web-hook has some kind of decision maker in it - an LLM + deterministic logic.
While I think this is a good idea, we already have so many different regions to comply with, now we're adding cities....
To avoid the overhead, we could simply adopt pro-consumer practices across the board? Easier than segmenting users and deciding which cancellation mechanisms are available to them based on region.
Nothing from stopping them from making it this easy to cancel for everyone. We all see cookie banners due to the EU's rules.
As far as added complexity goes, a rule for a city the size of NYC doesn’t seem like that far of a bridge to cross.
Alternatively, let people cancel easily everywhere. If you think it’s worth the extra revenue to geofence easy cancellations, then—well, you do you, but you are making a business judgment that the additional development cost is justified. This is different from VAT/sales tax etc., where it is in fact impossible to comply everywhere without discriminating by jurisdiction.
It’s an easy rule to comply with and nothing stops you from complying with it everywhere.
We will see a patchwork regime, where companies make it easy to cancel if you’re in NYC or another jurisdiction with similar rules, but difficult otherwise. When you see this, you must remember that the easiest thing would have been to make it easy for everyone to cancel regardless of location. That would be perfectly legal and it would be the cheapest option to build. If a company didn’t do that it’s because they made a deliberate choice to spend more money just so they could continue screwing some people over.
its hard being a dick
You can't seriously think this makes you sound like a sympathetic party, right? "Oh no, we have to maintain two codepaths now: the pro-social one for places with functional governments, and the slimy anti-consumer fuck-you one for everywhere else. Won't anyone think of our plight?"
> While I think this is a good idea, we already have so many different regions to comply with, now we're adding cities....
Lina Khan's FTC passed a rule to make click-to-cancel nationwide in 2024.
It was killed on procedural grounds by the highly conservative Eighth Circuit Court of Appeals.
The take-away from how it was killed boils down to "we (companies) know that we'd lose more than $100 million dollars if people could reasonably unsubscribe rather than deal with our dark patterns".
The old FTC would have been able to fix the procedural problem, but then Trump took office and gutted the FTC and destroyed all the good work it was doing.
Since the federal government is failing us, I support local governments doing the right thing. If enough do, companies will eventually be forced into compliance nationally because it won't be worth the complexity to have hundreds of regional carve-outs.
New York Times in shambles over this one
You can only submit my snail mail or Fax.
So close yet so far
There's a big blue button on the homepage that says "File a complaint" - I presume that goes through the web.
Previous discussion on the announcement:
New York City to ban deceptive subscription practices
https://news.ycombinator.com/item?id=48863464
When are NY and California going to secede and join the EU?