Last month, New York passed its 2025-2026 omnibus budget bill. Contained within the Transportation, Economic Development and Environmental Conservation bill are unique consumer protection provisions, including those related to automatic renewals, online return policies, and algorithmic pricing disclosures, as well as AI companions. Given the method in which they were enacted, many of these provisions threaten to take online marketers by surprise.
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.
New law takes effect just prior to the holidays
On December 10, 2023, a new law takes effect in New York that will mandate a grace period that will allow consumers three months to use up their credit card rewards points prior to a change in their loyalty program. New York General Business Law § 520-e was enacted in 2021 with a delayed effective date. The new law provides that before a credit card rewards program can be modified, cancelled or terminated, the consumer must be provided with at least 90 days’ notice of the forthcoming change and therefore an equally long window of opportunity to “redeem, exchange, or otherwise use” the previously accumulated points. The notice must go out no later than 45 days after the change has been decided upon by the credit card issuer.
The client alert addresses how New York has now joined other states with some of the most burdensome automatic renewal laws, enacting a sweeping law that regulates automatic renewal disclosures and cancellation procedures.
Proposed legislation recently introduced in the New York Senate would impose new limitations on discount buying clubs.
Effective November 12, 2012, sweeping new telemarketing legislation is now in effect in New York.