Adobe is moving to settle the federal case over its subscription enrollment and cancellation practices. On March 13, 2026, the U.S. Department of Justice said it filed a proposed stipulated order that, if entered by the court, would resolve claims against Adobe and two executives under the Restore Online Shoppers’ Confidence Act, or ROSCA. The proposed package totals $150 million, including $75 million in civil penalties and $75 million in free services for customers.

The case began in June 2024, when the Federal Trade Commission alleged that Adobe steered consumers into its “annual paid monthly” plan without adequately disclosing that canceling during the first year could trigger a substantial early termination fee. The FTC said Adobe emphasized the monthly price during sign-up while obscuring the annual commitment and the termination fee, which it alleged was 50% of the remaining monthly payments during the first year.

The government also alleged that Adobe made cancellation unnecessarily difficult. In the complaint, regulators described a process marked by repeated prompts, retention offers, warnings, surveys, password reentry, transfers, long wait times, and, in some cases, dropped calls or chats.

Under the proposed order, Adobe would have to clearly disclose any early termination fee and how it is calculated before enrolling a customer in a subscription. The Justice Department also said that for free trials lasting longer than seven days, Adobe would have to notify consumers before converting them into a paid subscription that includes an early termination fee. The proposed order also requires Adobe to provide simple ways to cancel.

Adobe said it disagrees with the government’s claims and denies wrongdoing. In its statement, the company said it has made its sign-up and cancellation processes more streamlined and transparent in recent years, and that it agreed to provide $75 million worth of services for qualifying customers along with a $75 million payment to the Department of Justice. Adobe also said it plans to proactively contact affected customers once the appropriate court filings are made and accepted.

ROSCA is the statute underlying the case. As DOJ summarized it, the law generally requires companies offering online subscriptions to clearly disclose material terms and provide simple ways for subscribers to stop recurring charges.

INSIDER TAKE

For subscription operators, this case is another reminder that subscription UX is now firmly part of the compliance conversation. Disclosure design, plan naming, conversion reminders, and cancellation flow architecture are no longer just retention or billing choices. They are legal and reputational ones too.

That is what makes Adobe worth watching beyond the headline settlement number. The government’s theory was not simply that a fee existed. It was that the way the plan was presented, the way consent was captured, and the way cancellation friction showed up in practice created a consumer protection problem.

The practical lesson is not “add more legal copy.” It is to make sure material terms appear where customers actually see them, before enrollment, in language that matches the plan being sold. If the monthly price is emphasized but the annual commitment or cancellation cost is not, that gap can become the story regulators tell about the business.

The cancellation piece matters just as much. Regulators are continuing to look at whether a customer can actually get out of a subscription without unnecessary friction, not just whether a cancellation path technically exists somewhere in the system. For operators, that makes cancellation design a compliance workflow as much as a save workflow.

Adobe is also a reminder that existing law remains plenty active even while broader rulemaking fights continue. Subscription businesses do not need to wait for a new federal rule to understand the direction of travel. Clear disclosure, informed consent, and straightforward cancellation are already live enforcement expectations.