Shutterstock's subscription dark patterns hid auto-renewal — $35M FTC settlement

Shutterstock Inc., the New York-based online stock photo, video, and music licensing platform, became one of the best-known brand names in digital media by offering millions of creators a simple way to license professional content. Its subscription plans — annual paid monthly (APM), annual paid upfront (APU), month-to-month, and on-demand content packs — were marketed as straightforward, with 'no commitment' guarantees on certain products.

What consumers saw on the checkout screen was not the full picture. According to the FTC, Shutterstock systematically failed to disclose that annual plans auto-renewed at the end of each term, that cancelling before expiry carried a fee, and that on-demand packs would automatically refill when the last download was used. These terms were buried in fine print rendered in a small gray font, tucked behind hyperlinks that users never had to open, or placed below brightly coloured 'Buy now' buttons — after the consumer had already entered billing information.

Cancellation was deliberately difficult. Until 2024, subscribers could not cancel early online at all — they had to phone, email, or use web chat, all of which the FTC described as 'a complicated and time-consuming process.' Internal practices also included free trials that silently converted into annually recurring subscriptions without clear notice. The FTC brought charges under both Section 5 of the FTC Act and the Restore Online Shoppers' Confidence Act (ROSCA), which specifically requires clear disclosure, express informed consent, and simple cancellation for negative option features.

On May 13, 2026, Shutterstock agreed to pay $35 million to settle the allegations. The proposed order, entered by the U.S. District Court for the Southern District of New York the next day, permanently prohibits Shutterstock from misrepresenting any material terms of its subscription offerings and requires clear disclosure of all material terms before collecting billing information, express informed consent before charging, and a cancellation mechanism that is 'at least as easy to use' as the sign-up flow.