Shutterstock pays $35M to FTC

Shutterstock agreed on May 13 to pay $35 million to settle Federal Trade Commission allegations that it used unlawful subscription and cancellation practices on its digital content platform, according to the agency and the company. The FTC said the New York-based company charged some users without informed consent, failed to clearly disclose auto-renewals and cancellation fees, and made subscriptions hard to cancel. Shutterstock disclosed the matter in an 8-K filing with the Securities and Exchange Commission, saying it had received a civil investigative demand in August 2024 and entered settlement discussions with the FTC in January 2026. ### Which conduct did the FTC say crossed the line? The FTC said Shutterstock’s conduct dated back to at least 2020 and centered on how it marketed and enrolled users into recurring plans. The agency said the company offered annual paid-up-front, annual paid-monthly and on-demand content plans, but did not adequately disclose key terms for some of those products. (ftc.gov) The complaint, as described by the FTC, said Shutterstock marketed on-demand packs as suited for a “one-time project” and with “no commitment,” while failing to adequately disclose that the packs automatically renewed when the last download was used and, until early 2024, also automatically renewed after one year. The FTC also said the company’s desktop enrollment flow for annual paid-monthly plans often did not clearly disclose that those plans renewed at the end of each year and could carry an early cancellation fee. (ftc.gov) ### What did the company say in its own filing? Shutterstock said in its SEC filing that the FTC’s complaint alleged violations of Section 5 of the FTC Act and the Restore Online Shoppers’ Confidence Act, or ROSCA. The company said it cooperated throughout the investigation and reached an agreement in principle with the agency on the same day the complaint was filed in federal court. (ftc.gov) The 8-K said the settlement requires Shutterstock to pay $35 million to the FTC and to provide additional disclosure and implement changes to its subscription enrollment and cancellation practices. The filing did not admit liability in the excerpt surfaced by the SEC search result, but it confirmed the payment amount and the operational changes tied to the agreement. (sec.gov) ### What does the order require beyond the money? The FTC said the stipulated order requires Shutterstock to stop misrepresenting subscription terms and to obtain consumers’ express informed consent before charging them. The agency also said the company must make cancellation simple and must clearly disclose material terms tied to recurring charges. (sec.gov) Christopher Mufarrige, director of the FTC’s Bureau of Consumer Protection, said subscription tools can benefit both companies and consumers, but only when firms clearly disclose material terms, secure informed consent before charging consumers, and make cancellation “a straightforward and simple process.” That statement tied the Shutterstock case to the agency’s broader focus on negative-option and recurring-payment practices. (ftc.gov) ### How does this fit with the FTC’s broader subscription push? The FTC’s October 2024 announcement of its final “click-to-cancel” rule said the rule applies broadly to negative-option programs, including automatic renewals and free-trial offers, and requires clear disclosure, express informed consent and a cancellation method that is at least as easy as sign-up. A separate FTC explainer said online sign-ups should allow online cancellation and that violators can face redress and civil penalties. (ftc.gov) The FTC’s rule page also shows the Negative Option Rule was published in the Federal Register on November 15, 2024. In 2026, the agency separately said it was seeking public comment on whether to amend the current rule, indicating the subscription rulemaking process is still active even as the agency pursues case-by-case enforcement. ### Why does this matter for product and engineering teams? (ftc.gov) The FTC’s allegations focused on specific product choices: enrollment pages, renewal disclosures, billing consent and cancellation flow design. The agency’s own description of the case shows that recurring-revenue compliance is being judged not only by contract language, but by what users see at the moment they sign up, what they are told before a charge, and how many steps it takes to leave. (ftc.gov) The practical lesson from the order is procedural, not rhetorical: companies need records showing what terms were disclosed, where consent was obtained and how cancellation works in production. Shutterstock’s settlement and the FTC’s rule materials both point to the same enforcement questions — disclosure, informed consent and ease of cancellation. May 13, 2026 is the next concrete marker in the case file: the FTC complaint and the proposed stipulated order were both filed that day in the U.S. (ftc.gov) District Court for the Southern District of New York. Shutterstock’s 8-K says the company agreed to the payment and to changes in its enrollment and cancellation practices as the matter moves through court approval. (ftc.gov) (sec.gov)