Amazon’s $2.5 billion settlement with the Federal Trade Commission over Amazon Prime enrollment and cancellation practices is entering its second remediation stage: a consumer claims process for eligible Prime subscribers who did not receive an automatic refund.

The FTC’s Amazon refunds page states that Amazon will begin a claims process in 2026 for eligible Prime customers who did not receive an automatic refund during the November–December 2025 distribution window, and that the FTC will update its page when the claims process starts.

Separately, the settlement administrator’s website—referenced in consumer guidance around the refund program—posts a claims timeline stating the claims window opens January 5, 2026, that eligible consumers should receive notice by January 23, 2026, and that consumers will have 180 days to submit a claim form. The administrator also states Amazon will have 30 days to review each claim once received.

What this settlement is

On September 25, 2025, the FTC announced a settlement alleging Amazon violated the Restore Online Shoppers’ Confidence Act (ROSCA) in connection with Prime by (among other things) failing to clearly disclose material terms before collecting billing information, failing to obtain “express informed consent,” and failing to provide “simple mechanisms” to cancel. Amazon settled without admitting liability.

The settlement totals $2.5 billion, including a $1 billion civil penalty and $1.5 billion for consumer refunds.

Two refund tracks: automatic vs. claim-based

The FTC has described the refund program as staged. The FTC says Amazon issued automatic refunds between Nov. 12 and Dec. 24, 2025, with refunds of Prime subscription fees up to $51.

The settlement administrator describes two consumer payment groups:

Automatic Payment Group
Consumers meeting eligibility criteria did not need to take action, with payments distributed during the Nov.–Dec. 2025 window.

Claims Process Payment Group (Phase 2)
The administrator’s criteria describe a claims process for eligible consumers who did not receive an automatic payment, tied to benefit-usage thresholds and an attestation connected to enrollment and/or cancellation experience.

Operational note: As of publication, the administrator’s “File Claim” page still displayed messaging that the claim filing process has not yet opened and instructs consumers to check back, suggesting a staged rollout or a delayed activation.

Who may be eligible to file a claim (administrator criteria)

Per the settlement administrator’s eligibility description, the claims group includes:

• Prime sign-up between June 23, 2019 and June 23, 2025

• Prime benefit usage of more than three but less than ten benefits in a 12-month period during that window.

• And an attestation that the consumer either unintentionally enrolled through a challenged enrollment flow or attempted to cancel through the online cancellation flow but was unable to do so.

INSIDER TAKE

For subscription operators, this is less about Amazon and more about the enforcement standard now being operationalized in public. The FTC’s case and remediation mechanics function as a blueprint for how regulators evaluate modern subscription funnels: what is disclosed, when consent is captured, and whether cancellation is straightforward in practice.

• Treat the order and remediation criteria as a pattern library. Map signup and cancellation paths to “clear and conspicuous” disclosure timing, consent capture, and “simple cancellation” expectations.

• Do not assume the “save offer” is the risk—assume interruption is. If retention offers sit in the cancel path, ensure users can still complete cancellation cleanly and immediately.

• Expect eligibility logic to become an audit artifact. Benefit-use thresholds and flow-based criteria show how telemetry can surface later in remediation design and enforcement narratives.

• Align CS and Trust teams on refund/claims escalation and scams. The FTC has warned that refund programs attract fraud attempts; prepare scripts and escalation routes to reduce friction and reputational blowback.