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FTC's Historic $2.5B Settlement Forces Amazon to Rethink Customer Experience

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The landmark case shows deceptive design isn’t just bad CX — it now carries billion-dollar consequences.

The Gist

  • Historic settlement. The FTC secured a record $2.5 billion settlement with Amazon over deceptive Prime subscription practices.
  • Dark patterns banned. Amazon must eliminate manipulative design tactics and simplify sign-up and cancellation flows.
  • Consumer restitution. Billions will go back to customers who were unknowingly enrolled or faced hurdles canceling Prime.
  • Long road from complaint to case closure. We first covered the FTC’s complaint in 2023 — the settlement closes a multiyear battle over Amazon’s customer experience practices.

Table of Contents

Update: Sept. 25, 2025: FTC Reaches Historic $2.5B Settlement With Amazon

The Federal Trade Commission announced Sept. 25 it has secured a landmark $2.5 billion settlement with Amazon, concluding its multiyear investigation and litigation over Prime subscription practices. The agreement is among the largest ever reached with a technology company and represents a decisive outcome in the FTC’s campaign against so-called “dark patterns.”

According to the FTC, Amazon will pay billions in restitution to consumers who were unknowingly enrolled in Prime or who encountered repeated obstacles when attempting to cancel their memberships. In addition to the financial penalties, the settlement compels Amazon to:

  • Redesign its Prime sign-up flow. Clear, upfront disclosures will now be required before a consumer is enrolled in a recurring subscription.
  • Simplify cancellation. The company must provide a straightforward cancellation process that does not include multiple deterrent screens or confusing redirects.
  • Independent compliance monitoring. Amazon is subject to ongoing oversight to ensure adherence to the settlement terms and prevent backsliding into manipulative design practices.

FTC Chair Lina M. Khan called the agreement “a landmark win for consumers,” saying the settlement “restores fairness to digital markets and ensures Amazon can no longer frustrate or mislead users into paying for services they didn’t intend to buy.” The Commission emphasized that this outcome also sets a precedent for how regulators will evaluate deceptive interface design across the tech sector.

The size of the penalty and the breadth of the compliance measures speak to how seriously regulators are treating subscription-related consumer harm. Analysts noted that the $2.5 billion sum rivals settlements previously reserved for antitrust or privacy violations, signaling a shift in enforcement priorities toward customer experience and digital fairness.

The Genesis of the FTC-Amazon Customer Experience Shakedown

Editor's note: Back in 2023, we first reported on the FTC’s initial complaint against Amazon that laid out these allegations in detail. That original coverage continues below.

Say it ain't so. Amazon getting called out for poor customer experience? 

It is so. And it's not some lone Twitter rant, either. It's the US federal government.

The Federal Trade Commission filed a complaint yesterday against Amazon for its "years-long effort to enroll consumers into its Prime program without their consent while knowingly making it difficult for consumers to cancel their subscriptions to Prime." Amazon knowingly duped millions of consumers into unknowingly enrolling in Amazon Prime and used "manipulative, coercive, or deceptive user-interface designs known as 'dark patterns' to trick consumers into enrolling in automatically-renewing Prime subscriptions."

Doesn't sound Amazon-ey. The company's been hailed for its superior customer experience, with analysts and customer experience leaders often citing the ecommerce provider as the standard-bearer of customer experience excellence.

'Amazon Tricked and Trapped People'

Not in the eyes of the FTC, which dinged Amazon for failing at two hallmark elements of a customer experience program: customer acquisition and customer service. Considering the praise Amazon gets in these departments for being super easy and flexible, the FTC revelations should be a shocker to the CX industry.

The FTC claims Amazon's goal with the Prime cancellation process was not to stop customers from doing so. You can't fault companies for offering incentives to stay around as customers when they want to leave. That's a pretty common tactic. ("You sure you want to go?") However, the FTC cites Amazon's actions as trickery.

“Amazon tricked and trapped people into recurring subscriptions without their consent, not only frustrating users but also costing them significant money,” FTC Chair Lina M. Khan said in a statement. “These manipulative tactics harm consumers and law-abiding businesses alike. The FTC will continue to vigorously protect Americans from 'dark patterns' and other unfair or deceptive practices in digital markets.”

Because Amazon used so-called “dark patterns” to cause consumers to enroll in Prime without their consent, this violated the FTC Act and the Restore Online Shoppers’ Confidence Act, according to the FTC.

Learning Opportunities

Related Article: How Amazon Prime Created a Bad Customer Experience for Everyone Else

FTC Breaks Down Amazon Prime's Poor CX

According to the FTC, here's how Amazon delivered deceptive practices around Amazon Prime:

  • Tough to make purchase without subscription. Amazon offered numerous ways to subscribe to Amazon Prime for $14.99 per month during its online checkout process. However, it was difficult for consumers to purchase items on Amazon without subscribing to Prime. In some cases, the button presented to consumers to complete their transaction did not clearly state that in choosing that option they were also agreeing to join Prime for a recurring subscription, according to the FTC.
  • Hard to cancel subscription. Amazon aimed to deter consumers from successfully unsubscribing from Prime. It included multiple steps to actually accomplish the task of canceling, according to the FTC complaint. Amazon made it difficult for consumers to locate the cancellation flow, then were redirected to multiple pages that presented several offers to continue the subscription at a discounted price, to simply turn off the auto-renew feature or to decide not to cancel. Only after clicking through these pages could consumers finally cancel the service, according to the FTC.
  • No actions until FTC intervention. Amazon's executives failed to take any meaningful steps to address the issues until they were aware of the FTC investigation, and it attempted to delay and hinder the FTC's investigation in multiple instances, according to the FTC complaint, filed in the U.S. District Court for the Western District of Washington.

Amazon: We'll Prove Ourselves in Court

In a statement, Amazon disputed the claims by the FTC and called the FTC's complaint announcement this week premature.

"The truth is that customers love Prime, and by design we make it clear and simple for customers to both sign up for or cancel their Prime membership," an Amazon spokesperson said. "We also find it concerning that the FTC announced this lawsuit without notice to us, in the midst of our discussions with FTC staff members to ensure they understand the facts, context, and legal issues, and before we were able to have a dialog with the Commissioners themselves before they filed a lawsuit. While the absence of that normal course engagement is extremely disappointing, we look forward to proving our case in court."

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About the Author
Dom Nicastro

Dom Nicastro is editor-in-chief of CMSWire and an award-winning journalist with a passion for technology, customer experience and marketing. With more than 20 years of experience, he has written for various publications, like the Gloucester Daily Times and Boston Magazine. He has a proven track record of delivering high-quality, informative, and engaging content to his readers. Dom works tirelessly to stay up-to-date with the latest trends in the industry to provide readers with accurate, trustworthy information to help them make informed decisions. Connect with Dom Nicastro:

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