Amazon Prime dark patterns: the $2.5 billion settlement and how to claim your refund

Updated: December 2025

For years, Amazon made it easy to sign up for Prime—and nearly impossible to leave. Buttons were designed to confuse. Cancellation required navigating a labyrinth the company internally called "Iliad," named after Homer's epic poem about the decade-long Trojan War. Internal documents showed employees describing the practice as "a bit of a shady world" and calling unwanted subscriptions "an unspoken cancer."

In September 2025, Amazon agreed to pay $2.5 billion to settle Federal Trade Commission charges that it enrolled millions of consumers in Prime without their consent and deliberately sabotaged their attempts to cancel. The settlement includes $1.5 billion in refunds to approximately 35 million affected customers—consumers who signed up through deceptive checkout flows or tried but failed to escape the subscription.

This is the largest civil penalty ever obtained by the FTC in a case involving dark patterns. And if you were a Prime member between June 2019 and June 2025, you may be entitled to a refund of up to $51.

This guide explains what Amazon did, how the FTC proved it, your legal rights, how to claim your refund, and what this settlement means for the future of subscription services.

What Amazon did

The enrollment trap

When you shopped on Amazon without a Prime membership, the company didn't just offer Prime as an option. It made buying without Prime confusing, frustrating, and sometimes nearly impossible.

The FTC's complaint documented several specific tactics:

The "misdirection" design: Amazon used a technique it internally called "misdirection." To complete a purchase without joining Prime, customers had to find a small blue text link buried on the page. But a large, prominent yellow button—Amazon's signature call-to-action color—said "Get FREE Two-Day Shipping." Clicking that button enrolled you in Prime, whether you intended to or not.

The checkout ambush: During checkout, Amazon presented Prime enrollment screens designed to look like a required step in completing your purchase. Many customers clicked through thinking they were simply finishing their order. Instead, they had unknowingly agreed to a $139/year subscription with automatic renewal.

The Prime Video trap: When customers tried to watch content on Prime Video, Amazon presented enrollment screens that obscured the fact that clicking "Watch Now" would enroll them in a paid subscription. Customers thought they were accessing content they'd already paid for or that was free—not signing up for recurring charges.

The universal Prime decision page: Amazon tested and deployed multiple checkout flow designs specifically optimized to maximize Prime enrollment, regardless of whether customers actually wanted or understood what they were agreeing to.

The evidence of intent

What made the FTC's case devastating wasn't just that Amazon's design confused customers. It was that Amazon knew it—and did it anyway.

Internal Amazon documents produced during the litigation revealed:

"Subscription driving is a bit of a shady world": Amazon employees discussed the ethics of their enrollment tactics in internal communications. One described the subscription-driving practices as operating in "a bit of a shady world."

"An unspoken cancer": Another internal communication referred to unwanted subscriptions as "an unspoken cancer" affecting the company.

35 million non-consensual enrollments: By Amazon's own internal estimates, more than 35 million Prime subscriptions over a seven-year period were "non-consensual"—meaning customers did not actually intend to sign up.

A company newsletter acknowledgment: An internal Amazon newsletter stated: "The issue of accidental Prime sign-ups is well documented" and acknowledged that Prime customers "sign[] up accidentally and/or [don't] see auto-renewal terms."

Revenue calculations per obstacle: At trial, FTC attorneys presented evidence that Amazon had calculated the exact revenue benefit achieved by adding each new obstacle to the cancellation process. The company knew that every additional click, every additional screen, every additional "are you sure?" prompt meant more customers would give up and keep paying.

Executive rejection of improvements: The FTC's amended complaint charged that senior executives were informed about non-consensual enrollment problems by other employees—in emails, meetings, and presentations—and encouraged to make changes. They chose not to act. Instead, they "slowed, avoided, and even reversed user experience changes that they knew would reduce nonconsensual enrollment because those changes would also negatively affect Amazon's bottom line."

The Iliad cancellation flow

If signing up for Prime was a trap, getting out was an odyssey.

Amazon named its cancellation process "Iliad"—a reference to Homer's 15,693-line epic poem about the Trojan War, a conflict that lasted ten years. The name was apt.

The FTC documented what it called "Prime's Four-Page, Six-Click, Fifteen-Option Iliad Flow." To cancel Prime, a customer had to:

• •Find the cancellation option. Amazon buried cancellation deep in account settings, making it difficult to locate in the first place.

• •Navigate four separate pages. Each page presented new information, new offers, and new opportunities to abandon the cancellation attempt.

• •Click through six separate confirmation steps. At each step, Amazon presented reasons not to cancel, warnings about what you'd lose, and offers for discounted membership.

• •Reject fifteen different options to keep some form of Prime membership, pause your membership, or otherwise avoid actually canceling.

Diversionary tactics at every turn: The Iliad Flow didn't just ask "are you sure?" It actively tried to change your mind. Amazon would:

• •Remind you of Prime benefits you'd lose
• •Show you how much you'd supposedly saved with Prime
• •Offer discounted rates to keep your membership
• •Suggest pausing instead of canceling
• •Warn about losing access to Prime Video content
• •Highlight upcoming deals you'd miss

Each diversion was another opportunity for the customer to give up. And Amazon's data showed that many did.

Calculated abandonment rates: Internal documents revealed that Amazon tracked exactly how many customers abandoned cancellation at each step of the Iliad Flow. The company knew that adding friction caused customers to give up—and it added friction deliberately.

The FTC's legal case

The Restore Online Shoppers' Confidence Act (ROSCA)

The FTC's primary legal theory was that Amazon violated the Restore Online Shoppers' Confidence Act (15 U.S.C. § 8403), a federal law that governs negative option marketing—business practices where silence or inaction is treated as acceptance of an offer.

ROSCA requires that before charging consumers for goods or services through negative option features, sellers must:

• •Clearly and conspicuously disclose all material terms of the transaction before obtaining billing information
• •Obtain the consumer's express informed consent before making the charge
• •Provide simple mechanisms for consumers to stop recurring charges

The FTC alleged Amazon violated all three requirements:

Disclosure failures: Amazon's checkout flows did not clearly disclose that clicking certain buttons would enroll customers in automatically-renewing subscriptions. The Prime enrollment was buried, obscured, or presented in ways that reasonable consumers would not notice or understand.

Consent failures: Because Amazon's disclosures were inadequate, customers could not provide "express informed consent." The 35 million non-consensual enrollments Amazon's own documents acknowledged were direct evidence of this failure.

Cancellation failures: The Iliad Flow was the opposite of a "simple mechanism" to stop recurring charges. It was deliberately designed to be complex, confusing, and discouraging.

The FTC Act Section 5

The FTC also charged Amazon with violating Section 5 of the FTC Act (15 U.S.C. § 45), which prohibits "unfair or deceptive acts or practices in or affecting commerce."

Deception: Amazon's checkout designs were deceptive because they created a false impression—that customers were simply completing a purchase when they were actually enrolling in a subscription.

Unfairness: Amazon's practices were unfair because they caused substantial injury to consumers (unwanted recurring charges) that consumers could not reasonably avoid (because the enrollment was non-consensual) and that was not outweighed by countervailing benefits.

Individual executive liability

In September 2023, the FTC took the unusual step of adding two senior Amazon executives as individual defendants:

Neil Lindsay: Senior Vice President of Amazon Stores, who oversaw Prime's growth strategy

Jamil Ghani: Vice President of Amazon Prime, directly responsible for Prime enrollment and retention

The FTC alleged these executives "played key roles in Prime's allegedly deceptive sign-up and cancellation tactics" and "personally participated in, had authority to control, or had knowledge of the violative conduct."

This was significant. The FTC was sending a message: executives who knowingly implement or maintain dark patterns can face personal liability, not just corporate consequences.

Litigation timeline

June 21, 2023: FTC files original complaint against Amazon in U.S. District Court for the Western District of Washington (Case No. 2:23-cv-00932)

September 20, 2023: FTC amends complaint to add Neil Lindsay and Jamil Ghani as individual defendants

May 16, 2024: Judge grants FTC's motion to proceed to trial, rejecting Amazon's motion to dismiss. Judge John H. Chun rules: "The FTC has plausibly alleged that Amazon's sign-up flows are designed so that consumers cannot easily find the option to buy an item without also signing up for Prime."

September 17, 2025: Trial begins in Seattle

September 25, 2025: Amazon agrees to $2.5 billion settlement before trial concludes

The $2.5 billion settlement

Settlement terms

On September 25, 2025, Amazon agreed to settle the FTC's charges for $2.5 billion—the largest settlement in FTC history for a case involving dark patterns. The settlement includes:

$1 billion civil penalty: Paid directly to the federal government. This is the largest civil penalty ever obtained in a case involving an FTC rule violation.

$1.5 billion consumer redress: Set aside for refunds to affected consumers. This is the second-largest restitution amount ever recovered by the FTC.

Injunctive relief: Amazon must change its practices going forward.

Required business changes

Under the settlement, Amazon must:

Eliminate deceptive enrollment buttons: Amazon can no longer use buttons that say "No, I don't want Free Shipping" or similar phrasing that makes declining Prime seem like declining a benefit rather than declining a subscription.

Provide clear opt-out options: Customers must have a clear, conspicuous option to complete purchases without enrolling in Prime. The decline option must be as prominent as the enrollment option.

Disclose all material terms: Before any enrollment, Amazon must clearly disclose that Prime involves automatic recurring charges, the amount of those charges, and how to cancel.

Simplify cancellation: Amazon must provide a straightforward cancellation process—no more Iliad Flow. Cancellation must be "as easy to find and use as the method consumers used to sign up."

Third-party monitoring: Amazon must retain an independent third-party supervisor to monitor compliance with the settlement terms.

No admission of wrongdoing

As is typical in settlements, Amazon did not admit any wrongdoing. The company stated that it had "already instituted many of the changes laid out by the FTC" and that it "categorically denies" the allegations.

However, the settlement terms—and the $2.5 billion price tag—speak for themselves.

How to claim your refund

Who is eligible

You may be eligible for a refund if you meet all of the following criteria:

• •You are a U.S. Amazon Prime customer

• •You signed up for Prime between June 23, 2019 and June 23, 2025 through one of the "challenged enrollment flows":
• •The universal Prime decision page
• •The shipping selection page
• •Single page checkout
• •The Prime Video enrollment flow

• •You used no more than three Amazon Prime benefits in any 12-month period (indicating you may not have intended to have Prime)

You may also be eligible if you attempted but were unable to cancel your Prime subscription during that period.

Refund amounts

Eligible consumers can receive up to $51 per affected subscription period. The exact amount depends on:

• •How long you were enrolled
• •How many benefits you used
• •Whether you attempted to cancel
• •The total number of claims filed

The $1.5 billion fund will be distributed among all eligible claimants. If claims exceed the fund, individual payments will be reduced proportionally.

Automatic refunds (Wave 1)

Many eligible consumers will receive automatic refunds without needing to file a claim. Amazon is required to identify affected customers using its own records.

Timeline: Amazon will send notification emails between November 12, 2025 and December 24, 2025.

Payment method: You can receive your refund via PayPal or Venmo. If you prefer a check, simply do not respond to the email—Amazon will mail a check to your default shipping address on file.

Deadline to accept digital payment: 15 days from receiving notification

Deadline to cash check: 60 days from receipt

Filing a claim (Wave 2)

If you don't receive an automatic refund but believe you're eligible, you can file a claim:

Claims open: December 24, 2025

Notification period: December 24, 2025 through January 23, 2026 (notices sent to potentially eligible consumers)

Claims administrator contact: Beginning January 23, 2026

Claims deadline: July 23, 2026

How to file: Visit SubscriptionMembershipSettlement.com (the official settlement website) or wait for contact from the court-appointed claims administrator.

Avoiding scams

The FTC has warned that scammers are already trying to exploit this settlement:

The FTC will NOT contact you about refunds. If you receive a call from someone claiming to be from the FTC about Amazon refunds, it's a scam.

Amazon will NOT ask for payment. No one from Amazon will ever ask you for money to receive a refund. If someone asks for payment, money transfer, or gift cards to "process" your refund, it's a scam.

Use only official channels: The official settlement website is SubscriptionMembershipSettlement.com. The official FTC information page is ftc.gov/enforcement/refunds/amazon-refunds.

Do not click suspicious links: Scammers may send emails that look like they're from Amazon or the FTC. When in doubt, navigate directly to official websites rather than clicking email links.

The trial: what came out in court

Opening arguments (September 17, 2025)

When the trial began in Seattle federal court, FTC attorneys laid out a case built on Amazon's own words.

Lead FTC counsel presented internal documents showing that Amazon executives had been warned repeatedly about non-consensual enrollments. Employees had raised concerns. Product managers had proposed simpler flows. But leadership rejected these changes because they would reduce subscription revenue.

"Amazon built a trap," the FTC argued in opening statements. "They made it easy to fall in, and they made it almost impossible to climb out. And they did it knowing exactly what they were doing."

Amazon's defense focused on two arguments: first, that customers received value from Prime and that high retention rates reflected satisfaction, not manipulation; second, that the company had already made improvements before the lawsuit was filed.

Key evidence presented

The conversion rate documents: FTC attorneys introduced documents showing Amazon tracked "conversion rates" for each Prime enrollment flow. The company knew exactly which button designs, which color schemes, and which placement choices led to more enrollments—and optimized for maximum enrollment regardless of customer intent.

The cancellation abandonment data: Amazon tracked how many customers abandoned the cancellation process at each step. Documents showed that adding a single additional page to the cancellation flow increased abandonment by measurable percentages. Amazon used this data not to simplify cancellation, but to add more obstacles.

Executive email chains: Email threads showed senior executives discussing concerns raised by employees about "accidental" enrollments. In multiple instances, executives acknowledged the problem but declined to act because fixes would "impact the business."

Customer service transcripts: The FTC introduced customer service chat logs and call recordings showing customers struggling to cancel, being transferred between departments, and receiving conflicting information about how to stop their subscriptions.

A/B testing results: Amazon's own A/B tests showed that simpler, clearer checkout flows resulted in fewer Prime enrollments. The company chose the confusing designs precisely because they produced more enrollments.

Amazon's defense

Amazon's legal team argued that:

Prime delivers value: The company emphasized that Prime members receive free shipping, video streaming, music, and other benefits worth more than the $139 annual fee. High retention rates, Amazon argued, reflected genuine customer satisfaction.

Improvements were already made: Amazon pointed to changes it had made to enrollment and cancellation flows before the trial, arguing that any past issues had been addressed.

No intent to deceive: Amazon denied that its designs were intended to trick customers, characterizing them as standard e-commerce practices used across the industry.

Regulatory overreach: Amazon argued that the FTC was attempting to regulate user interface design in ways Congress never intended.

The settlement

Eight days into what was expected to be a three-week trial, Amazon agreed to settle. Legal observers noted that the timing—after the FTC had presented its most damaging evidence but before Amazon had fully presented its defense—suggested the company wanted to avoid further revelations.

Neither side commented on what specific evidence or testimony may have prompted the settlement decision.

Consumer impact: real stories

The accidental enrollments

The FTC's complaint and subsequent court filings included accounts from affected consumers:

Sarah, Texas: "I was buying a birthday present for my daughter. I clicked what I thought was the 'complete purchase' button. Three months later, I realized I'd been paying $14.99/month for Prime. I never wanted it, never used it."

Michael, Ohio: "I tried to watch a movie on Prime Video that I thought was included. It enrolled me in Prime. I didn't realize it until I saw the charge on my credit card statement."

Jennifer, California: "I tried to cancel Prime three separate times. Each time, I thought I had canceled, but the charges kept coming. The process was so confusing I couldn't tell if I'd actually completed the cancellation."

The cancellation nightmare

Consumer complaints filed with the FTC and state attorneys general documented the Iliad Flow experience:

Multiple failed attempts: Many consumers reported attempting to cancel multiple times, believing they had successfully unsubscribed, only to find charges continuing on their statements.

Phone runaround: Customers who called Amazon's customer service to cancel reported being transferred between departments, placed on extended holds, and given conflicting information.

Retention pressure: Customers described aggressive retention tactics, including repeated offers, guilt-based messaging ("Are you sure you want to lose free shipping?"), and unclear buttons that seemed to confirm cancellation but actually selected retention offers.

Post-cancellation charges: Some customers reported continuing to be charged even after receiving confirmation that their membership was canceled.

The financial toll

For the 35 million consumers affected, the financial impact was real:

Monthly charges: Prime costs $14.99/month or $139/year. A consumer enrolled without consent for even one year lost $139 to a subscription they never wanted.

Opportunity cost: Money spent on unwanted Prime subscriptions was money that couldn't be spent on other needs—groceries, utilities, savings.

Credit impact: Some consumers who disputed charges or had cards declined due to unexpected Prime charges faced complications with their credit.

Time wasted: The hours spent trying to navigate cancellation flows, calling customer service, and disputing charges represented real costs in time and frustration.

What are dark patterns?

Definition

Dark patterns are user interface designs that manipulate users into taking actions they didn't intend to take or wouldn't choose if they fully understood what was happening.

The term was coined by UX designer Harry Brignull in 2010. California law defines dark patterns as "a user interface designed or manipulated with the substantial effect of subverting or impairing user autonomy, decision-making, or choice."

Common types of dark patterns

Roach motel: Easy to get into, hard to get out of. Amazon's Iliad cancellation flow is a textbook example.

Trick questions: Using confusing language or double negatives so users select the opposite of what they intend. "Uncheck this box if you prefer not to receive no marketing communications."

Misdirection: Using visual design to draw attention toward one option and away from another. Amazon's prominent "Get FREE Two-Day Shipping" button versus the small text link to decline Prime.

Hidden costs: Revealing additional fees only at the final step of checkout, after the user has already invested time in the transaction.

Forced continuity: Silently charging a user's credit card after a free trial ends without adequate notice.

Confirmshaming: Using guilt or shame to manipulate users. "No thanks, I don't want to save money."

Bait and switch: Advertising one thing but delivering another, or making it difficult to get the advertised option.

Disguised ads: Advertisements designed to look like content or navigation elements.

Privacy zuckering: Using confusing privacy settings to get users to share more data than they intended.

Why dark patterns work

Dark patterns exploit well-documented cognitive biases:

Default bias: People tend to accept default options rather than actively changing them. Dark patterns exploit this by pre-selecting options that benefit the company.

Cognitive load: When people are tired, rushed, or overwhelmed, they make worse decisions. Dark patterns add complexity and confusion to exploit this vulnerability.

Loss aversion: People feel losses more strongly than equivalent gains. Dark patterns use loss-framing ("You'll lose access to...") to discourage cancellation.

Sunk cost fallacy: People are reluctant to abandon something they've already invested in. Multi-step cancellation flows exploit this by making users invest more with each step.

Authority bias: People tend to trust official-looking interfaces. Dark patterns use professional design to create false legitimacy.

The legal landscape

Federal law

FTC Act Section 5: The Federal Trade Commission's primary authority to combat dark patterns comes from Section 5 of the FTC Act, which prohibits "unfair or deceptive acts or practices." The FTC has increasingly treated dark patterns as deceptive practices subject to enforcement.

ROSCA: The Restore Online Shoppers' Confidence Act specifically governs negative option marketing (automatic renewals, free trials that convert to paid subscriptions, etc.). ROSCA requires clear disclosure, express consent, and simple cancellation mechanisms.

FTC Negative Option Rule: The FTC has proposed strengthening its Negative Option Rule to address dark patterns more directly. The proposed updates would require:

• •Clear disclosure of all material terms before obtaining billing information
• •Express informed consent documented by the seller
• •Simple cancellation mechanisms (at least as easy as signing up)

Status of Click-to-Cancel Rule: The FTC's "Click to Cancel" rule, which would have required businesses to make cancellation as easy as signup, was struck down by courts in July 2025. However, the Amazon settlement demonstrates that the FTC can still pursue dark patterns under existing authority.

State laws

Several states have enacted laws specifically addressing dark patterns:

California (CCPA/CPRA): California law defines dark patterns and provides that "agreement obtained through use of dark patterns does not constitute consent." The California Privacy Protection Agency (CPPA) actively enforces against dark patterns, with penalties of $2,500 per violation or $7,500 for intentional violations.

Colorado (CPA): The Colorado Privacy Act voids consent obtained through dark patterns and defines them as interfaces "designed or manipulated with the substantial effect of subverting or impairing user autonomy, decision-making, or choice."

Connecticut (CTDPA): Connecticut's data privacy law includes similar dark pattern prohibitions.

Texas: While Texas lacks comprehensive privacy legislation, the state attorney general has actively pursued dark patterns under consumer protection authority. Texas secured a $9.5 million settlement with Booking Holdings over deceptive "junk fee" practices.

Other states: Minnesota, Montana, and several other states have incorporated dark pattern prohibitions into their privacy laws.

Enforcement trends

The Amazon settlement reflects a broader enforcement trend:

FTC priorities: The FTC has made dark patterns an enforcement priority. Recent actions include:

• •Fortnite maker Epic Games ($520 million, 2022)
• •ABCMouse operator Age of Learning ($10 million, 2020)
• •Credit Karma ($3 million, 2024)
• •Vonage ($100 million, 2022)

State attorney general actions: State AGs have increasingly pursued dark patterns:

• •California: Honda (2025) for consent management dark patterns
• •Texas: Booking Holdings ($9.5 million) for hotel fee disclosure
• •New York/Illinois: Jimmy John's for subscription practices
• •Multiple states: Investigations of major subscription services

Private litigation: While most state dark pattern laws lack private rights of action, consumers can pursue claims under state consumer protection laws (UDAP statutes) that do allow private suits.

Other dark pattern settlements and cases

Epic Games / Fortnite ($520 million, 2022)

The FTC charged that Epic Games, maker of the popular video game Fortnite, used dark patterns to trick players—including children—into making unintended purchases.

The practices: Epic used confusing button layouts and ambiguous dialog boxes that led players to make purchases they didn't mean to make. The game's interface was designed so that a single accidental button press could charge the player's account.

The settlement: Epic paid $245 million in refunds to affected players plus a $275 million penalty—at the time, the largest penalty ever in a video game case.

Vonage ($100 million, 2022)

The FTC charged that Vonage, a telecommunications company, made it extremely difficult for customers to cancel their phone service.

The practices: Customers trying to cancel faced a gauntlet of retention tactics. They were required to call during limited hours, wait on hold for extended periods, navigate multiple departments, and endure high-pressure retention scripts. Even after completing this process, many customers found they were still being charged.

The settlement: Vonage agreed to pay $100 million in refunds and civil penalties and to implement a simple cancellation process.

ABCMouse / Age of Learning ($10 million, 2020)

The FTC charged that ABCMouse, a children's educational website, used dark patterns to trap parents in subscriptions.

The practices: ABCMouse made cancellation difficult by burying the cancellation option, requiring multi-step processes, and using retention tactics designed to frustrate users into giving up.

The settlement: Age of Learning paid $10 million and agreed to provide simple cancellation mechanisms.

Credit Karma ($3 million, 2024)

The FTC charged that Credit Karma, a personal finance company, used dark patterns in marketing credit card offers.

The practices: Credit Karma's interface made it appear that users were "pre-approved" for credit cards when they weren't. Users who clicked through were actually applying for cards they might be rejected for—potentially damaging their credit scores.

The settlement: Credit Karma paid $3 million and agreed to change its marketing practices.

Protecting yourself from dark patterns

Before signing up

Read before clicking: Don't click prominent buttons without reading what they actually do. Dark patterns exploit users who click first and read later.

Look for the "no thanks" option: Before accepting any offer, look for the option to decline. If it's hard to find, that's a red flag.

Check for pre-selected boxes: Look for checkboxes that have been pre-selected on your behalf. Uncheck anything you didn't actively choose.

Review the full price: Before completing any transaction, find the total price including all fees, taxes, and recurring charges.

Screenshot terms: If you're signing up for a trial or subscription, screenshot the terms, prices, and cancellation policy. You may need this evidence later.

During free trials

Set a calendar reminder: Mark your calendar for 2-3 days before any free trial expires. This gives you time to cancel if you don't want to continue.

Use virtual card numbers: Some credit cards and services (like Privacy.com) let you create virtual card numbers with spending limits. Use a card with a low limit for free trials so charges can't exceed that amount.

Understand the conversion terms: Know exactly what you'll be charged when the trial ends and when that charge will occur.

When trying to cancel

Document everything: Take screenshots of each step in the cancellation process. This evidence may be valuable if you need to dispute charges or file a complaint.

Be persistent: If the cancellation process is difficult, that's probably intentional. Don't give up.

Check for chat cancellation: Some companies that make phone cancellation difficult allow easier cancellation through chat or email.

Check your statements: After canceling, monitor your credit card statements to ensure charges actually stop. Companies sometimes continue charging after cancellation.

Dispute unauthorized charges: If you continue to be charged after canceling, dispute the charges with your credit card company. Under the Fair Credit Billing Act, you have 60 days from the statement date to dispute charges.

Reporting dark patterns

FTC: Report dark patterns to the FTC at reportfraud.ftc.gov. FTC complaints help identify patterns of abuse and build enforcement cases.

State attorney general: Report to your state attorney general's consumer protection division. Find yours at naag.org.

California residents: Report to the California Privacy Protection Agency (CPPA) at cppa.ca.gov if the dark pattern involves your personal data.

Better Business Bureau: File a complaint at bbb.org. BBB complaints can pressure companies to change practices.

What this means for the future

Precedent for enforcement

The Amazon settlement establishes several important precedents:

Record penalties: The $2.5 billion settlement demonstrates that dark patterns can result in massive financial consequences. Companies can no longer treat dark pattern enforcement as a cost of doing business.

Executive liability: By naming individual executives as defendants, the FTC signaled that personal liability is on the table. Executives who knowingly approve dark patterns may face personal consequences, not just corporate ones.

Internal documents matter: Amazon's internal communications—"shady world," "unspoken cancer," calculations of revenue per cancellation obstacle—proved devastating. Companies should assume that internal discussions about manipulative practices will eventually become public.

"As easy to cancel as to sign up": The settlement's requirement that cancellation be as easy as signup may become the de facto standard for subscription services, even without the FTC's Click-to-Cancel rule.

Industry response

The settlement is already affecting how companies approach subscription design:

Proactive changes: Many subscription companies are reviewing and simplifying their cancellation processes before facing enforcement action.

Legal department involvement: Legal teams are increasingly involved in user interface design decisions, particularly around subscription enrollment and cancellation.

Documentation practices: Companies are being more careful about internal communications that could be used as evidence of intentional manipulation.

Consumer awareness

The Amazon case has increased public awareness of dark patterns:

Media coverage: The settlement received extensive media attention, educating consumers about manipulative design practices.

Regulatory attention: The case has increased pressure on regulators to address dark patterns more aggressively.

Design ethics: The UX design community continues to debate the ethics of persuasive design versus manipulative design.

Frequently asked questions

Am I eligible for a refund?

You may be eligible if you were enrolled in Prime between June 23, 2019 and June 23, 2025 through one of the challenged enrollment flows (checkout pages, Prime Video enrollment, shipping selection pages) and you used few Prime benefits—indicating you may not have intended to subscribe. You may also be eligible if you tried but failed to cancel during this period.

How much will I receive?

Eligible consumers can receive up to $51. The exact amount depends on how long you were enrolled, how the fund is distributed among all claimants, and other factors. If you were enrolled for a short period or the fund is oversubscribed, you may receive less.

Do I need to do anything to get my refund?

Many consumers will receive automatic refunds. Amazon is required to identify affected customers using its records and will send emails between November 12, 2025 and December 24, 2025. If you don't receive an automatic notification, you can file a claim starting December 24, 2025.

How will I receive my refund?

You can choose PayPal or Venmo for electronic payment. If you don't respond to the electronic payment offer within 15 days, Amazon will mail a check to your address on file. Cash checks within 60 days.

What if I'm still a Prime member and want to stay?

This settlement is about past deceptive practices, not about whether Prime itself is valuable. If you're a current Prime member who intentionally signed up and wants to keep your membership, you don't need to do anything. The settlement compensates people who were enrolled without proper consent or who couldn't cancel when they tried.

What if I canceled Prime years ago?

You may still be eligible if you were enrolled through a challenged flow during the settlement period (June 2019 - June 2025), even if you later successfully canceled. The harm was the period during which you paid for a subscription you didn't consent to.

Will I need to provide proof?

For automatic refunds, no proof is required—Amazon has records of your enrollment and usage. If you file a claim in Wave 2, you may need to provide basic information about your Amazon account.

Is this a scam?

No, this is a legitimate FTC settlement. However, scammers are trying to exploit it. Remember: the FTC will NOT call you about refunds, and no one from Amazon will ask you to pay money to receive a refund. Only use official websites (SubscriptionMembershipSettlement.com and ftc.gov).

What about Amazon's other lawsuit?

Amazon faces a separate FTC lawsuit (filed 2023) alleging monopolistic practices in online retail. That case is scheduled for trial in 2027 and is unrelated to the Prime dark patterns settlement. Any outcomes in that case would be separate from this refund process.

Can I still sue Amazon separately?

The settlement releases claims related to the specific dark pattern practices covered by the FTC case. If you have claims based on different conduct, or if you opted out of the settlement, you may have other legal options. Consult an attorney if you believe you have claims beyond what the settlement covers.

How to check if you were affected

Step 1: Review your Amazon account history

Log into your Amazon account and navigate to:

• •Account & Lists → Your Prime Membership → View membership history

Look for:

• •When you first enrolled in Prime
• •Whether you enrolled during a purchase checkout
• •Any periods where you attempted to cancel

Step 2: Check your email records

Search your email for messages from Amazon containing:

• •"Welcome to Prime"
• •"Prime membership"
• •"Prime cancellation"

Note the dates of these emails and whether you recall intentionally signing up.

Step 3: Review your credit card and bank statements

Look for Amazon charges that include:

• •"PRIME" or "AMZN PRIME"
• •Recurring charges you didn't recognize
• •Charges that continued after you thought you'd canceled

Step 4: Document your experience

If you believe you were enrolled without consent or couldn't cancel:

• •Write down what happened
• •Note approximate dates
• •Save any emails or screenshots
• •Keep credit card statements showing charges

This documentation may be helpful if you need to file a claim in Wave 2.

Step 5: Watch for notification

Amazon will email affected customers between November 12, 2025 and December 24, 2025. Make sure Amazon has your current email address and check your spam folder.

The bigger picture: subscription economy abuse

Amazon is not alone

While the Amazon settlement is the largest, it's part of a pattern across the subscription economy:

Gym memberships: Planet Fitness, LA Fitness, and other gym chains have faced lawsuits over difficult cancellation processes. Some gyms require in-person cancellation, certified letters, or impose waiting periods—all designed to keep you paying.

Streaming services: Multiple streaming services have faced complaints about confusing cancellation flows, with some burying the cancel button multiple screens deep.

News subscriptions: The New York Times, Washington Post, and other publications have faced criticism for making digital subscription cancellation far more difficult than signup.

Software subscriptions: Adobe, Microsoft, and other software companies have been criticized for auto-renewal practices and cancellation friction.

Meal kits: HelloFresh, Blue Apron, and similar services have faced lawsuits over enrollment and cancellation practices. HelloFresh settled with the FTC for $7.5 million in 2024.

The business model problem

The subscription economy creates perverse incentives:

Customer acquisition cost: Companies spend heavily to acquire customers—sometimes more than a year's worth of subscription revenue. This creates pressure to retain customers by any means.

Churn metrics: Subscription businesses live and die by "churn"—the percentage of customers who cancel. Reducing churn, even through manipulation, directly improves company valuation.

Dark pattern ROI: Companies can calculate exactly how much revenue each obstacle to cancellation produces. When the math favors manipulation, some companies choose manipulation.

Investor pressure: Publicly traded subscription companies face pressure to show subscriber growth. This can incentivize acquisition tactics that prioritize quantity over consent.

Regulatory response

The Amazon settlement reflects broader regulatory momentum against subscription abuse:

FTC focus: The FTC has made subscription practices an enforcement priority, with multiple cases in recent years.

State legislation: California, Colorado, and other states have enacted laws specifically addressing automatic renewal and cancellation practices.

International action: The European Union's Digital Services Act and consumer protection authorities in the UK, Australia, and other countries are increasingly targeting dark patterns.

Industry self-regulation: Some companies are voluntarily improving cancellation processes to avoid regulatory action—though critics argue these improvements are often insufficient.

Timeline: how we got here

Understanding the full history of the Amazon Prime case shows how long it took to hold a major corporation accountable for deceptive practices.

2005: Amazon launches Prime with annual subscription and two-day shipping.

2010: UX designer Harry Brignull coins the term "dark patterns" to describe manipulative interface design.

2015: Consumer complaints about Prime enrollment and cancellation difficulties begin appearing in significant numbers on social media and consumer complaint sites.

2018: Norwegian Consumer Council publishes influential report on dark patterns, increasing international awareness.

2019 (June 23): Beginning of the settlement class period. Prime enrollment and cancellation practices during this time form the basis of the FTC case.

2021: FTC begins investigation of Amazon Prime practices after receiving consumer complaints.

2022: FTC issues Civil Investigative Demands (subpoenas) to Amazon, seeking documents about enrollment and cancellation practices.

2023 (January): FTC files enforcement actions against other companies using dark patterns, signaling increased focus on the issue.

2023 (June 21): FTC files complaint against Amazon in U.S. District Court for the Western District of Washington, alleging violations of ROSCA and the FTC Act.

2023 (September 20): FTC amends complaint to add individual executives Neil Lindsay and Jamil Ghani as defendants.

2024 (May 16): Judge John H. Chun denies Amazon's motion to dismiss, allowing the case to proceed to trial. Court rules FTC "plausibly alleged" deceptive practices.

2024 (December): FTC finalizes "junk fees" rule banning hidden fees in hotels and event tickets, reflecting broader agency focus on consumer manipulation.

2025 (June 23): End of the settlement class period.

2025 (July): FTC's Click-to-Cancel rule struck down by courts, but agency continues enforcement under existing authority.

2025 (September 17): Trial begins in Seattle federal court.

2025 (September 25): Amazon agrees to $2.5 billion settlement—$1 billion penalty plus $1.5 billion consumer refunds.

2025 (November 12): Amazon begins sending automatic refund notifications to affected consumers.

2025 (December 24): Deadline for Wave 1 automatic refund notifications; Wave 2 claims process opens.

2026 (January 23): Claims administrator begins contacting consumers for Wave 2.

2026 (July 23): Deadline for filing Wave 2 claims.

What happens next

For Amazon

The settlement requires Amazon to fundamentally change how it handles Prime enrollment and cancellation. The company must:

• •Redesign checkout flows to provide clear, equally prominent options to buy with or without Prime
• •Eliminate manipulative button text like "No, I don't want Free Shipping"
• •Create a straightforward cancellation process without multiple pages of retention offers
• •Submit to third-party compliance monitoring

Amazon has stated it had already begun implementing some changes before the settlement. The company will need to demonstrate ongoing compliance to avoid further enforcement action.

For the subscription industry

The Amazon settlement sends a clear message to other subscription businesses: dark patterns carry real financial risk. Companies that continue using manipulative enrollment and cancellation practices face potential enforcement action with massive penalties.

Industry observers expect:

• •More companies to proactively simplify cancellation processes
• •Increased legal department oversight of user interface design
• •More careful documentation of design decisions
• •Greater attention to consumer consent in enrollment flows

For consumers

The settlement provides immediate financial relief to affected consumers and should result in improved practices going forward. However, vigilance remains necessary:

• •Other companies continue to use dark patterns
• •Enforcement resources are limited
• •New manipulative techniques continue to emerge
• •Consumer awareness is the first line of defense

For regulators

The Amazon case demonstrates that the FTC can achieve significant results even without new rulemaking authority. The settlement may encourage continued enforcement action against other dark pattern practitioners.

However, questions remain about regulatory capacity:

• •FTC resources are limited relative to the scope of dark pattern use
• •Recent political changes have affected agency staffing and priorities
• •Courts have constrained some FTC rulemaking authority
• •State-level enforcement varies significantly

The long-term trajectory of dark pattern enforcement will depend on continued regulatory attention, congressional action, and ongoing public pressure for accountability.

Resources

Official settlement information

• •Settlement website: SubscriptionMembershipSettlement.com
• •FTC refund information: ftc.gov/enforcement/refunds/amazon-refunds
• •FTC case documents: ftc.gov/legal-library/browse/cases-proceedings/2123050-amazoncom-inc-rosca-ftc-v

Government agencies

• •FTC complaints: reportfraud.ftc.gov
• •State attorneys general: naag.org
• •California Privacy Protection Agency: cppa.ca.gov
• •Consumer Financial Protection Bureau: consumerfinance.gov

Consumer advocacy

• •Consumer Reports: consumerreports.org
• •Electronic Frontier Foundation: eff.org
• •Public Citizen: citizen.org
• •U.S. PIRG: pirg.org

Dark pattern resources

• •Dark Patterns Tip Line: darkpatternstipline.org
• •Deceptive Design: deceptive.design (Harry Brignull's original dark patterns documentation)
• •Consumer Action: consumer-action.org

Legal help

• •National Consumer Law Center: nclc.org
• •Your state bar association: lawyer referral services
• •Legal aid: lsc.gov

Key takeaways

The Amazon Prime dark patterns case represents a watershed moment in consumer protection. Here are the essential points to remember:

For affected consumers:

• •Check your eligibility—you may be entitled to up to $51 if you were enrolled in Prime between June 2019 and June 2025 through challenged flows
• •Watch for automatic refund notifications from Amazon between November 12 and December 24, 2025
• •If you don't receive automatic notification, file a claim starting December 24, 2025
• •Use only official websites (SubscriptionMembershipSettlement.com) and be alert for scams
• •Choose PayPal/Venmo for faster payment or wait for a mailed check

For understanding your rights:

• •Companies cannot use manipulative design to enroll you in subscriptions without your informed consent
• •Cancellation must be reasonably simple—not an odyssey through multiple pages of retention offers
• •You can report dark patterns to the FTC at reportfraud.ftc.gov
• •State laws in California, Colorado, and elsewhere provide additional protections
• •Internal company knowledge of deceptive practices strengthens legal cases

For protecting yourself going forward:

• •Read before clicking—especially buttons during checkout
• •Look for pre-selected boxes and hidden text links
• •Set calendar reminders before free trials expire
• •Document terms and cancellation processes with screenshots
• •Monitor credit card statements for unexpected recurring charges
• •Dispute unauthorized charges within 60 days

The $2.5 billion settlement proves that even the largest companies face consequences for manipulative design. But individual vigilance remains the first line of defense against the subscription traps that pervade the modern economy.

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This guide provides general information about the Amazon Prime FTC settlement and dark patterns. It does not constitute legal advice. Settlement terms, claim deadlines, and eligibility requirements may change. Visit the official settlement website at SubscriptionMembershipSettlement.com for current information.

Sources: FTC, NPR, Fortune, Fast Company, National Law Review

Last updated: December 2025