On September 25, 2025, the U.S. Federal Trade Commission reached a historic $2.5 billion settlement with Amazon.com, Inc. to settle allegations that the company used deceptive methods that caused millions of consumers to enroll in Prime subscriptions without their consent and then intentionally made it difficult to cancel those subscriptions. Two Amazon executives – Vice President Neil Lindsay and Vice President Jamil Ghani – were also charged by the FTC with knowingly misleading consumers to enroll in Prime subscriptions, in violation of the FTC Act and the Restore Online Shopper’s Confidence Act (“ROSCA”). The settlement requires Amazon to end their unlawful enrollment and cancellation practices, pay a $1 billion civil penalty, and pay $1.5 billion in refunds back to consumers who were harmed by the deceptive practices. The stipulated settlement order is pending approval by a judge in the U.S. District Court for the Western District of Washington, and Amazon has neither admitted or denied the allegations. According to the FTC, the $1 billion civil penalty is the largest ever imposed in case involving an FTC rule violation, and the $1.5 billion consumer redress is the second-highest restitution award ever obtained by FTC action. The settlement is also significant because it is only the third ROSCA case in which the FTC has obtained a civil penalty.
According to the amended complaint, which was filed on September 20, 2023, Amazon and its leadership duped approximately 35 million consumers into unknowingly enrolling in Amazon Prime, an automatically-renewing subscription service. The FTC alleged that “Nonconsensual Enrollment” was a well-known practice at Amazon, according to internal documents that frequently referred to “accidental” signups. The company is accused of using “manipulative, coercive, or deceptive user-interface designs known as ‘dark patterns’” to mislead or trick users into enrolling in Prime subscriptions. Despite having knowledge of the problem and receiving requests from employees to fix it, Amazon executives, including Lindsay and Ghani, allegedly avoided making changes to the deceptive enrollment practice and purposefully complicated the cancellations process because the change would negatively affect the company’s bottom line. According to the complaint, the cancellation process, which Amazon named “Iliad,” in reference to Homer’s epic about the long and arduous Trojan War, was designed to be “labyrinthine” in nature in order to thwart consumers’ efforts to cancel Prime subscriptions.
In addition to the payment of monetary penalties, Amazon is required to cease their unlawful enrollment and cancellation practices for Prime and is prohibited from making material misrepresentations regarding Prime or selling Prime subscriptions without obtaining consumers’ express informed consent. Amazon must also make several changes to its Prime enrollment and cancellation processes, including the creation a clear option or button for customers to decline Prime subscriptions; clear and conspicuous disclosures regarding all material terms for enrolling in and cancelling a Prime subscription; and the creation of an easy cancellation process for Prime that is similar to the method used to enroll subscribers. Amazon is also required to hire court-appointed claims supervisor to monitor the consumer fund distribution process.
FTC Press Release | Stipulated Order | Amended Complaint