On May 13, 2026, the Federal Trade Commission (“FTC”) announced that Shutterstock, Inc. had agreed to a $35 million settlement resolving allegations that the company engaged in unfair and deceptive subscription practices. The FTC asserted claims under Section 5 of the FTC Act and the Restore Online Shoppers’ Confidence Act (“ROSCA”), alleging that Shutterstock charged consumers who did not understand they were enrolling in a subscription, failed to adequately disclose material subscription terms, and made cancellation unnecessarily difficult. The complaint did not seek civil penalties, and the final settlement requires only consumer redress.
According to the FTC’s complaint, Shutterstock operates one of the world’s largest online libraries of stock photos, graphics, videos, and music clips. Since at least 2020, the company has primarily distributed its content through subscription plans that allow users to download and use a set number of assets. The FTC’s allegations focus on whether Shutterstock adequately disclosed the material terms of these subscription offerings, including the automatically renewing nature of certain products. In particular, the complaint highlighted the following alleged practices:
- Misleading marketing of “on-demand packs.” Shutterstock offered annual subscription plans, as well as “on-demand packs” that included the right to download a limited number of assets. The FTC alleged that Shutterstock marketed its “on‑demand packs” as involving “no commitment” and suitable for “one‑time projects,” while failing to clearly convey that the packs would automatically replenish—and result in additional charges—once users exhausted the included credits. The complaint also alleged that included credits expired after one year and, for a period of time, Shutterstock renewed expired packs without adequately disclosing that it would do so.
- Inadequate and unclear disclosure of key material terms. The complaint alleged that statements such as “Your pack will automatically refill when all licenses are used” did not adequately convey that a refill would trigger a new charge, particularly where such language appeared in gray text below the call‑to‑action button and contradicted more prominent “one-time project” marketing language. The FTC further alleged that the final enrollment screen did not clearly disclose key terms, including that packs would refill or expire, that Shutterstock would charge the consumer’s payment method if a refill were triggered, the amount of any such charge, or how consumers could avoid it. The complaint also alleged that Shutterstock failed to adequately disclose that consumers who chose to pay for annual subscriptions on a monthly basis would be charged a cancellation fee if they cancelled before the end of the annual term.
- Burdensome cancellation process. According to the FTC, for a period of time, some consumers were not permitted to cancel online. Those consumers who could cancel online were required to navigate multiple pages, prompts, and retention screens to cancel. When consumers tried to contact customer support to cancel, they were met with incorrect phone numbers, long wait times, repeated follow‑up communications to confirm their intent to cancel, and requirements to start over if they did not promptly pay the cancellation fee.
- Internal awareness of consumer confusion. The complaint cites internal company discussions reflecting alleged consumer confusion and frustration with the subscription experience and acknowledging limitations in Shutterstock’s disclosures.
Under the stipulated order, Shutterstock will pay $35 million for consumer redress and is subject to injunctive provisions governing its subscription practices. The order requires Shutterstock to clearly disclose all material terms, obtain consumers’ express, informed consent before imposing charges, and provide simple, streamlined cancellation mechanisms that reflect some of the requirements of the now-vacated Negative Option Rule. The matter underscores the FTC’s continued focus on negative option enforcement alongside its announcement that it is launching a new Negative Option Rulemaking.
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