FTC settlement requires Shutterstock to pay $35M and change subscription cancellation practices
Shutterstock must rebuild subscription disclosure, consent and cancellation controls under the FTC settlement order
Change
On May 12, 2026, the US Federal Trade Commission announced a proposed federal court order requiring Shutterstock Inc. to pay $35 million and change its subscription billing and cancellation practices for negative option features.
Why it matters
The proposed order turns the FTC’s billing and cancellation allegations into concrete controls for Shutterstock: material-term disclosure before billing, express informed consent before charging, and simple cancellation mechanisms. The case also signals how the FTC is applying negative-option enforcement to subscription checkout and cancellation flows, especially where renewal or early-cancellation terms are not made clear before payment.
Implications
- — Shutterstock subscription product teams must clearly and conspicuously disclose renewal terms and cancellation-fee timing and amounts before billing — failure would breach the proposed order’s material-term disclosure requirement once approved.
- — Shutterstock checkout and payments teams must obtain consumers’ express informed consent before charging for subscriptions or content packs with negative option features — charging without that consent would breach the proposed order’s consent requirement once approved.
- — Shutterstock account, customer-support and cancellation-flow teams must maintain simple cancellation mechanisms for negative option features — forcing consumers through harder cancellation paths would breach the proposed order’s cancellation requirement once approved.
- — Digital subscription businesses using auto-renewal, usage-triggered renewal or annual paid-monthly plans should review checkout disclosures and cancellation paths against the FTC’s allegations — similar gaps can create enforcement exposure even where the order directly binds only Shutterstock.
Who is affected
- — Shutterstock subscription product teams
- — Shutterstock checkout and payments teams
- — Shutterstock customer-support and cancellation-flow teams
- — Digital subscription businesses using negative option billing
What to watch
- — Court approval: the stipulated final order has force of law only when approved and signed by the District Court judge.
- — Consumer relief payment: Shutterstock must pay $35 million under the proposed order.