FTC Cracks Down on Amazon's "Dark Patterns" in Major Subscription Settlement

On September 25, 2025, the Federal Trade Commission announced a landmark $2.5 billion settlement with Amazon, marking the largest case of its kind in subscription commerce and consumer protection law.

The FTC had accused Amazon of enrolling millions of consumers into its Prime program without their express consent and of making cancellation deliberately difficult through confusing interface design and obstructive flows. Internal documents reportedly showed that Amazon employees themselves described these practices as “shady” and akin to an “unspoken cancer” within the company.

The settlement imposes a $1 billion civil penalty along with $1.5 billion in consumer redress, funds that will be distributed to roughly 35 million affected consumers. In addition to financial penalties, Amazon is now required to reform its subscription practices by providing a clear opt-out button for Prime enrollment, prominently disclosing all material terms such as cost and renewal conditions, and ensuring cancellation is as simple as enrollment.

An independent monitor will oversee compliance to ensure the remedies are properly enforced. Legally, the FTC grounded its case not only in Section 5 of the FTC Act, which prohibits unfair or deceptive acts in commerce, but also in the Restore Online Shoppers’ Confidence Act (ROSCA), which governs negative option marketing and requires express consent and easy cancellation.

The case highlights how user interface design often dismissed as mere product choice can rise to the level of a deceptive practice under law, especially when it exploits consumer inertia or misleads users into recurring payments.

The settlement sends a strong warning to all subscription-based businesses that “dark patterns” and cancellation traps will not only draw regulatory scrutiny but may also result in billion-dollar penalties.

Beyond immediate consumer redress, the case will shape industry standards, embolden regulators to take on other subscription models, and potentially inspire legislative tightening of rules governing auto-renewals and digital commerce.

While Amazon may still seek to limit the scope of injunctive obligations or challenge aspects of implementation, this moment underscores the growing convergence of consumer rights, digital design ethics, and regulatory enforcement in the modern subscription economy.