"No commitment." Shutterstock printed those words on its image-pack purchase page in clean type, above a bright "Buy now" button. In May 2026, the FTC made the company pay $35 million for what that button actually sold. Shutterstock built a billing system that turned one-time buyers into subscribers without a second consent step.

Most operators who have bought stock photos, templates, or design assets by the pack have seen some version of this language. "No commitment." "Best for a one-time project." It sounds like a clean trade. You pay, you get your files, you move on. The evidence says otherwise.

The FTC complaint, filed in federal court in New York, laid out how Shutterstock sold image packs under "one-time project" language while a subscription ran beneath the surface.

Here is how the billing worked. When a buyer downloads the last image in a pack, the pack refills on its own. The card on file gets charged again. The auto-refill setting is on by default. The buyer did not click "renew." The buyer did not check a box. Using the last file in a pack the buyer already paid for was enough. The system treated that action as consent to buy more.

There is a name for this in federal law. The FTC calls it a "negative option feature." It means the seller treats a buyer's silence, or failure to take action to cancel, as agreement to keep paying. The purchase page said "no commitment." The billing structure said the opposite. "No commitment" did not fail people. It failed the system they were trying to run.

The flaw is not that terms exist in small print. The flaw is that one action does two jobs. You download a file you already paid for. That download triggers a new charge. No consent step sits between the two. Only one of those jobs is visible on the screen.

The terms that mattered most were not placed where a buyer would read them first. Some sat behind links that no one was required to click before the sale went through. The billing details came after the card number was already entered. The page was built to move a buyer past the terms, not through them.

Once inside, leaving costs real money. The FTC complaint said Shutterstock charged a cancellation fee equal to 50% of the remaining contract value. On a $199-per-month annual plan with six months left, that math comes to $597 to walk away. The company also built a cancellation flow that stretched across as many as eight screens before a buyer could finish the process.

In mid-2024, the company raised its cancellation fee and applied the new rate to buyers who had signed up under the old terms. No notice. No new consent. The trap got worse after entry.

Internal records cited in the FTC complaint tell the rest of the story. A Shutterstock Operations Senior Manager wrote in a group chat that "many of our customers don't realize what they have signed up for." The cancellation fee was, in that same exchange, called a "constant source of confusion" for buyers. The company knew the fee kept people locked in. It used that fact as a retention tool.

Then came the line that closes the gap between suspicion and proof. When the FTC filed a separate case against Adobe in 2024 for the same billing structure, Shutterstock employees flagged it on Slack. One worried the company would "be next." A Senior Product Manager replied: "hopefully we can get away with it."

That is not a marketing problem. It is a system built to profit from the distance between what the page says and what the billing does. The Adobe case proves the pattern is not limited to one company. Two of the largest digital vendors in the market, hit by the same federal agency, for the same mechanism, inside two years.

The label on a purchase page is not the billing structure. The only defense is a three-part test run before you enter a card number. Once that is clear, three moves follow from it.

Before you buy, search the purchase page for "renew," "refill," or "auto." Read the gray text below the buy button and above the submit field. If the product refills based on your usage rather than a date you set, it is a subscription wearing a different label. This is the step most operators skip, because the page is designed to feel like a simple, one-time purchase.

Look for "early termination," "cancellation fee," or "remaining balance." These terms often sit inside a linked document, not on the purchase screen itself. If the fee is a share of a contract term you did not know you were entering, write down the number before you buy. A vendor that hides the exit cost has told you something about its model.

Search the vendor's help center for "how to cancel." Count the steps. If the path runs through chat, then email, then a retention screen, or through more than three pages, the exit friction is part of the product design. The harder it is to leave, the more the vendor depends on you staying past the point of value.

If any of these three are missing from the purchase screen, the product is a subscription. The label does not change the billing.

Running this test across a current vendor stack does something the label never did:

At the end of a full vendor review, ask three things.

→ Which vendor's renewal trigger was hardest to find on the purchase page?

→ Which tool looked like a one-time cost but carried a recurring charge underneath?

→ Which exit path took more than three steps to finish?

That is the difference between a label that sounds right and a billing structure that proves itself.

Shutterstock's purchase page still shows a bright button. The text below it is still gray. Thirty-five million dollars changed the settlement ledger, not how these products are built across the market. "No commitment" means nothing until the billing confirms it.