Advertising Law Blog

Equinox Group, LLC, the operator of Equinox and SoulCycle fitness clubs, recently entered into a settlement agreement with the New York Attorney General’s Office (“OAG”). Under the  settlement terms contained in the Assurance of Discontinuance, Equinox agreed to pay $600,000 and overhaul its subscription and cancellation practices. The deal was announced in May 2025, following the OAG’s investigation into Equinox’s automatic renewal terms and cancellation processes. While the monetary penalty is notable, it is the prospective reforms that are more consequential for ongoing industry compliance.

The OAG launched its investigation after receiving numerous consumer complaints alleging that Equinox made it difficult or impossible to cancel memberships. Many consumers were enrolled in automatically renewing contracts without sufficient notice of the cancellation requirements. In some cases, they were required to visit the gym locations to terminate memberships or were subjected to lengthy and unresponsive customer service processes.

According to the OAG, these practices violated New York General Business Law § 527-a, which governs automatic renewal offers, as well as the federal Restore Online Shoppers’ Confidence Act (often referred to as "ROSCA"). Both laws require businesses to present automatic renewal terms clearly and conspicuously, obtain affirmative consent and provide straightforward cancellation mechanisms.

As part of the settlement, the $600,000 that Equinox must pay includes civil penalties and restitution. Eligible consumers may receive up to $100 if they were affected by the company’s cancellation practices between February 2021 and May 2025, with those submitting formal complaints potentially receiving up to $250.

But the most forward-looking component of the settlement is the extensive compliance framework Equinox must now implement:

• Equinox must present automatic renewal terms in a clear and conspicuous manner before the subscription agreement is fulfilled. This includes disclosure of the cancellation policy, all recurring charges, length of the renewal term and any minimum purchase obligations.
• The company is required to obtain affirmative consent to the agreement that contains the automatic renewal terms before issuing any charges.
• Equinox must provide an easy-to-use mechanism for cancellation. For online enrollments, consumers must be able to terminate the automatic renewal exclusively online.
• It must also provide a confirmation that includes the automatic renewal or continuous service offer terms, cancellation policy, and information regarding how to cancel, in a manner capable of being retained by the consumer.

TAKEAWAY: The Equinox case is the latest in a series of enforcement actions signaling the importance of consumers' newly expanded rights of cancellation. Subscription-based businesses should beware: what might have once been viewed as aggressive customer retention strategy is now a regulatory liability. Companies should focus not only on the legality of automatic renewal enrollment but also on the user experience of cancellation. Future enforcement will likely hinge as much on design and accessibility of the consumer-facing process as on contractual language. With regulatory scrutiny increasing, particularly in New York and California, transparent enrollment and easy exits are becoming legal necessities.