Amazon is set to face a pivotal moment in its corporate history as it prepares to enter a Federal Trade Commission (FTC) trial on September 22, 2025, over accusations of deceptive practices tied to its Prime membership program. The company, which reported a staggering $12.2 billion in subscription revenue in the last quarter, stands accused of using so-called "dark patterns"—user interface tricks designed to manipulate consumers—both to enroll customers in automatically renewing Prime memberships and to make it difficult for them to cancel. The legal showdown, which follows years of regulatory scrutiny, could reshape not only Amazon’s business practices but also the broader digital subscription economy.
The FTC’s case against Amazon began formally on June 21, 2023, when the agency filed suit alleging that the tech giant had for years used "manipulative, coercive, or deceptive user-interface designs known as dark patterns to trick consumers into enrolling in automatically-renewing Prime subscriptions." According to Reuters, the commission further accused Amazon of intentionally complicating the cancellation process, making it so difficult that the company itself referred to the process internally as "Iliad"—a nod to its epic length and complexity. FTC Chair Lina Khan, a noted critic of big tech, described the company’s conduct bluntly: "Amazon tricked and trapped people into recurring subscriptions without their consent, not only frustrating users but also costing them significant money. 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."
The allegations have been bolstered by a recent pre-trial ruling. On September 18, 2025, U.S. District Judge John Chinin found that Amazon violated the Restore Online Shoppers' Confidence Act (ROSCA) by collecting Prime subscribers' billing information before fully disclosing the service's terms. As Reuters reported, Judge Chinin’s decision not only prevents Amazon from arguing that ROSCA does not apply to Prime memberships but also opens the door for two Amazon executives to be held personally liable if violations are proven at trial. Chris Mufarrige, head of the FTC's bureau of consumer protection, stated, "Today's decision confirms that Amazon defrauded American consumers by failing to disclose all the terms of Prime before collecting consumers' payment information. The Trump-Vance FTC intends to make them whole."
The road to trial has been anything but smooth. The date has been pushed several times—from February 2025 to June, and now to September—amid accusations from the FTC that Amazon was dragging its feet during the discovery process. The stakes have only grown higher as the trial approaches, with the judge’s recent ruling strengthening the FTC’s hand and increasing the likelihood of significant penalties or mandated changes to Amazon’s business practices.
At the heart of the case is the concept of "dark patterns." Coined in 2010, the term refers to user interface designs that intentionally steer, mislead, or coerce users into taking actions they might not otherwise choose—such as signing up for a subscription or sharing personal data. The FTC has made clear its intent to crack down on such tactics. Its 2022 report, "Bringing Dark Patterns to Light," and a recent amendment to the Negative Option Rule—which now requires that cancellation mechanisms be "at least as easy to use" as enrollment—highlight a growing regulatory intolerance for these manipulative designs.
Amazon’s defense has been to deny all accusations, insisting that its Prime practices are both lawful and consumer-friendly. The company argues that a strong FTC victory could ultimately harm consumers by reducing product choices, raising prices, and slowing deliveries, as well as limiting options for small businesses on its platform. Still, the potential consequences for Amazon are significant: hefty financial penalties, mandated customer refunds, and a forced overhaul of its Prime sign-up and cancellation flows. Investors are watching closely, wary of the potential for reputational damage and fluctuations in Amazon’s stock price as the trial unfolds.
The implications of this legal battle stretch far beyond Amazon. Should the FTC prevail, consumers stand to gain the most: clearer disclosures during the Prime sign-up process, easier cancellation, and the possibility of restitution for past deceptive enrollments. The FTC, for its part, would see its authority in regulating digital markets and combating dark patterns significantly enhanced, setting a crucial precedent for how antitrust and consumer protection laws are applied to subscription models in the digital age.
The ripple effects could also reach Amazon’s competitors and the broader subscription industry. E-commerce rivals like Walmart, eBay, and Shopify may benefit if the lawsuit curbs Amazon’s alleged anti-competitive tactics, potentially leveling the playing field and fostering greater innovation. Meanwhile, other companies that rely on dark patterns to retain subscribers will likely face heightened scrutiny and may be compelled to redesign their interfaces to be more transparent and user-friendly.
This case is part of a larger, global movement to rein in the power of big tech and protect consumers from digital manipulation. The FTC’s actions echo similar efforts abroad, such as the European Union’s Digital Services Act—which explicitly bans dark patterns—and the General Data Protection Regulation (GDPR), which emphasizes informed consent and transparency. Previous enforcement actions, including the FTC’s fines against Epic Games for deceptive in-game purchases and lawsuits against Google over location data, demonstrate a growing consensus that these practices are harmful and require intervention.
For Amazon, the short-term outlook is challenging. The company faces intense public and regulatory scrutiny, and the recent judicial finding that it violated consumer protection law puts it on the defensive. Internally, Amazon may be forced to review and potentially revise its subscription-related user interfaces, perhaps making minor changes before the trial’s conclusion in an effort to demonstrate good faith. In the longer term, a decisive FTC victory could force Amazon to fundamentally alter its Prime subscription model, shifting from aggressive retention tactics to a more transparent, value-driven approach. The possibility of executives being held personally liable for violations adds a new layer of accountability, not just for Amazon but for the tech industry at large.
As the trial begins, the industry will be watching closely. The outcome will likely set new standards for transparency and user autonomy in digital subscription services, compelling businesses to prioritize informed consent and easy cancellation over retention at any cost. For consumers, the prospect of a more ethical, user-friendly digital marketplace is within reach. For Amazon and its peers, the trial is a clarion call to adapt or face the consequences of a new era of digital accountability. The coming weeks will reveal whether Amazon can weather this storm—or if the FTC’s case will mark a turning point in the battle against dark patterns and deceptive digital practices.
