Adobe paying a $75 million penalty for how it handled subscription cancellations looks, at first glance, like a US‑only legal story. It isn’t. It’s a warning shot for every software company that has quietly turned friction into a business model – and for users who have accepted that “Cancel” will always mean clicking through a maze.
In this piece, we’ll look at what Adobe actually agreed to, why regulators cared so much about cancellation flows, how this fits into a broader crackdown on “dark patterns,” and what it means for creative professionals and SaaS vendors in Europe and beyond.
The news in brief
According to Ars Technica, Adobe has settled a US Department of Justice lawsuit filed in 2024 over the way it handled cancellations for its Creative Cloud subscriptions. The DOJ accused Adobe of violating the US Restore Online Shoppers’ Confidence Act (ROSCA) by obscuring hefty early‑termination fees and making it unreasonably hard for customers to cancel.
For many customers on annual plans, cancelling meant paying 50% of the remaining contract value – a cost often buried in fine print or behind links during sign‑up. The government also took issue with complex phone menus and online flows that allegedly discouraged cancellations.
Under the settlement, Adobe will pay $75 million to the US government and has committed to providing an additional $75 million worth of free services to affected customers, though it has not yet detailed who qualifies or what exactly they will receive. Adobe denies any wrongdoing and says it already changed its sales funnel in recent years to make fees clearer. The settlement allows Adobe to avoid a full trial.
Why this matters
The money itself is almost a rounding error. Adobe reported more than $7 billion in net profit last year, as Ars Technica notes. A $75 million check is not existential; it’s a line item. The real impact is reputational and regulatory.
First, this case puts a legal spotlight on something users have long complained about but companies treated as “good UX optimization”: using design to keep people from leaving. When your revenue depends on recurring subscriptions, reducing churn is gold. Making cancellation confusing or costly is the most direct – and least honest – way to do it.
Second, this is a reminder that the battle over subscriptions has shifted from “Is SaaS acceptable?” to “Can SaaS be trusted?” Adobe pioneered the idea of turning core creative tools into a utility‑like monthly expense, especially for designers, agencies, and freelancers. For many, that was tolerable precisely because they believed they could adjust or cancel when needed. If that exit is revealed to be booby‑trapped, the whole value proposition looks different.
Third, it emboldens regulators. ROSCA is not a new law; it has simply not been enforced aggressively in software. The DOJ choosing a flagship, highly profitable, and relatively well‑regarded player like Adobe sends a clear message: even industry leaders are fair game when it comes to dark patterns.
Finally, it pressures other SaaS vendors. If you’re running any subscription product with:
- hidden early‑termination fees,
- cancellation only via phone,
- confusing downgrade paths,
you now have a concrete, high‑profile example of what can trigger enforcement. Expect legal and product teams across the industry to quietly review their flows this quarter.
The bigger picture
Adobe’s settlement is not an isolated event; it fits neatly into a global turn against manipulative subscription design.
In the US, the Federal Trade Commission has already gone after telecom and subscription services that make cancellation unreasonably hard. The case against Amazon over its allegedly confusing Prime cancellation flow – internally nicknamed “Project Iliad,” after the famously long epic – highlighted how much effort some companies invest in making leaving painful.
Adobe’s situation is subtler but similar in spirit: the allegation is not that the fees were illegal per se, but that they were strategically hidden and paired with friction to suppress cancellations. That’s textbook “dark pattern” territory.
The timing also matters. We’re more than a decade into the great SaaS shift. Users have now had enough time to realize they’re effectively renting software at ever‑rising prices. In creative industries, there’s growing resentment at being locked into a single vendor for tools that were once one‑off purchases – especially when those vendors post record profits while freelancers struggle with inconsistent income.
At the same time, generative AI is introducing new forms of lock‑in. Adobe is weaving Firefly and Sensei AI features deep into Creative Cloud. Once your workflows, assets, and even styles depend on proprietary AI tools, switching costs go up again – even if the subscription itself is technically “cancelable.”
Regulators are starting to see all of this as part of a pattern: large platforms using design, contract structure, and data to create economic dependency. The Adobe case focuses on cancellation fees, but the subtext is broader: the era of “growth at all costs, design the funnel later” is ending.
The European angle
Even though this case is US‑based, European users and companies should pay close attention – and not just because many of them rely heavily on Adobe tools.
The EU has spent the past few years explicitly targeting the kind of practices at issue here. Under the Digital Services Act (DSA), very large platforms are banned from using misleading interface design – a broad attack on dark patterns. Existing consumer protection rules also require that subscription terms, including prices and renewal conditions, be clear and easily accessible.
Several Member States have gone further. Germany, for example, introduced the so‑called “Kündigungsbutton” in 2022, forcing businesses to provide an easy online cancellation button for many recurring contracts. That is exactly the sort of friction‑removal the DOJ is now demanding in the US.
For European regulators, Adobe is already a known quantity. The company abandoned its planned acquisition of Figma after intense scrutiny from EU and UK competition authorities, which argued the deal could harm innovation in design tools. The settlement in the US only strengthens the narrative of a powerful incumbent that occasionally needs firm guardrails.
For EU SaaS startups, there is an opportunity here: build subscription models that feel genuinely fair. Clear monthly pricing, pro‑rated refunds, one‑click cancellation, and no opaque “gotchas” can become a selling point, not a cost center – especially in privacy‑ and consumer‑sensitive markets like Germany and the Nordics.
Looking ahead
In practical terms, Adobe will likely tweak – not transform – its business. Expect more prominent disclosures around early‑termination fees, a smoother self‑serve cancellation flow, and a detailed remediation program for affected US customers.
The larger questions lie elsewhere:
- Will regulators move beyond fees to scrutinize broader forms of lock‑in? That could include proprietary formats, cloud‑only features, and AI models that make exporting work difficult.
- Will the EU or UK launch their own investigations? Now that the DOJ has framed Adobe’s practices as a consumer‑protection concern, it’s easier for other regulators to piggyback on the same logic.
- Will this spark collective legal action? If Adobe customers in other jurisdictions can show similar patterns of hidden fees or obstructive flows, class‑action style cases become more likely.
From an industry perspective, the smart SaaS vendors will treat this as a free compliance audit. If your product manager can’t explain your cancellation flow in one slide and your lawyer can’t summarize your early‑termination terms in one paragraph, that’s a risk.
Timeline‑wise, Adobe’s payments and remediation will play out over the next year or two. Regulatory ripples – new guidance, local enforcement, copycat lawsuits – will likely unfold over a longer horizon, especially in Europe, where procedures move slowly but decisively.
The bottom line
Adobe’s $75 million settlement is not going to change its balance sheet, but it should change how the industry thinks about subscriptions. The message from regulators is clear: dark patterns are no longer just a UX sin; they’re a legal liability.
For users, the question is whether we continue to accept lock‑in as the price of convenience – or start rewarding tools and vendors that make leaving as simple as joining. In an economy built on recurring revenue, the real power move might be choosing products that let you walk away.
