On May 13, 2026, the Federal Trade Commission (FTC) filed and simultaneously settled with Shutterstock, Inc. (Shutterstock), an online library of stock photos and videos, for $35 million over allegations regarding its subscription and cancellation practices. The FTC alleged that Shutterstock used deceptive “negative option” features in connection with its annual paid‑monthly subscription plans and on‑demand “packs,” charged consumers without their informed consent, and made it difficult for consumers to cancel. Under a stipulated order for permanent injunction, monetary judgment, and other relief, Shutterstock agreed to pay $35 million in consumer redress and make some changes to how it markets, obtains consent for, and cancels subscription offerings.

Key Allegations in the FTC’s Complaint

The FTC’s complaint asserted violations of the FTC Act and the Restore Online Shoppers’ Confidence Act (ROSCA), focusing on both how Shutterstock enrolled consumers and how it handled cancellations.

Alleged Misrepresentations and Omissions

The FTC alleges that Shutterstock misled consumers by (1) marketing “annual, paid monthly” plans as simple monthly subscriptions while hiding that they automatically renewed each year and carried substantial cancellation fees, (2) promoting on‑demand “packs” as one‑time, “no commitment” purchases even though they automatically renewed — both when the last download was used and, until early 2024, one year after purchase — , and (3) converting free trials into paid annual plans, often billed monthly, without clearly disclosing when and how consumers would be charged or the full terms of the subscription.

Charging Without Express Informed Consent

The FTC claims that Shutterstock charged consumers for recurring subscriptions without first obtaining their express informed consent to all material terms, including that charges would recur (and at what frequency); the duration of the commitment; the existence, timing, and amount of cancellation fees; and the conditions under which packs or subscriptions would automatically renew. This alleged conduct forms part of the FTC’s ROSCA claim that Shutterstock sold goods and services over the internet through negative option features without first clearly disclosing material terms and obtaining consumers’ express informed consent.

Obstacles to Cancellation

The complaint also alleges that Shutterstock violated ROSCA by failing to provide simple mechanisms for consumers to stop recurring charges. The FTC contends that these obstacles violated ROSCA’s requirement that negative option plans offer a “simple mechanism” for cancellation.

The Stipulated Order and Monetary Relief

To resolve the FTC’s allegations, Shutterstock agreed to a stipulated order for permanent injunction, monetary judgment, and other relief, filed the same day as the complaint. In addition to monetary relief, Shutterstock also agreed to injunctive and compliance obligations. Among other things, Shutterstock agreed it will not misrepresent any material terms of its subscription offerings, including whether a product or plan is a one‑time purchase or ongoing subscription, the existence and nature of automatic renewal, and the presence, amount, and timing of any cancellation fees.

Why It Matters

The Shutterstock settlement underscores several key themes for companies that rely on subscription and “negative option” models:

• Enforcement efforts remain active;
• “One‑time” and “no commitment” claims are high‑risk when plans involve automatic renewal;
• Fine print and multistep purchase flows are unlikely to cure alleged deficient disclosures;
• Cancellation must be as easy as enrollment, and dark patterns that frustrate cancellation are likely to draw regulatory scrutiny; and
• State and federal enforcers are coordinated on negative option practices, signaling sustained multijurisdictional interest in subscription marketing, auto‑renewal, and cancellation design.