Subscription Enrollment Consent Register

PROBLEM: The FTC sued Amazon in June 2023 alleging it enrolled millions of consumers in Prime without informed consent and made cancellation unreasonably difficult through its "Iliad" flow; on 25 September 2025 Amazon agreed to pay $2.5 billion — a $1 billion civil penalty plus up to $1.5 billion in refunds to about 35 million consumers — to settle the case (FTC v. Amazon, W.D. Wash. No. 2:23-cv-00932). Amazon did not admit wrongdoing. Enrollment and cancellation records were at the centre of the dispute, yet consumers had no single auditable record of what they consented to.

SOLUTION: An IBM Cloud Ideas compliance improvement that maintains a subscription-enrollment consent register: each enrollment, consent screen, renewal and cancellation attempt is logged with its timestamp and the terms shown, so a regulator or customer can reconstruct exactly what was agreed and when cancellation was attempted.

EVIDENCE BASIS: DOCUMENTED — FTC v. Amazon, filed Jun 2023; settlement 25 Sep 2025: Amazon $2.5B ($1B penalty + up to $1.5B refunds to ~35M consumers) over Prime enrollment without informed consent and a difficult cancellation flow.