The settlement amount and specific remedies remain subject to final approval. The FTC has not yet disclosed whether Shutterstock admitted wrongdoing or detailed the full scope of affected customers.
This settlement lands as the FTC intensifies enforcement against subscription dark patterns. The agency sued Adobe over similar practices in 2024, and internal Shutterstock communications reportedly show employees worried the company's own tactics might face identical scrutiny. The $35 million penalty signals that subscription businesses cannot rely on friction-laden cancellation processes or buried billing terms. Attorneys advising companies with recurring billing models should audit their disclosure practices, consent mechanisms, and cancellation workflows now—the FTC is clearly willing to pursue seven-figure settlements in this space.