FTC vs Uber: A Case Study in Dark Patterns and Regulatory Risk

On April 21, 2025, the U.S. Federal Trade Commission (FTC) filed a lawsuit against Uber Technologies Inc., alleging deceptive practices related to its Uber One subscription service. The FTC claims Uber enrolled consumers without explicit consent and made cancellation processes unduly burdensome, violating both the FTC Act and the Restore Online Shoppers’ Confidence Act (ROSCA).

Key Allegations:

• Misleading Savings Claims: Uber advertised potential savings of $25/month through Uber One, yet failed to disclose the $9.99/month or $96/year subscription fee that significantly offset this benefit.

• Complex Cancellation Process: According to the FTC, users had to complete up to 32 actions across 23 screens to cancel, especially difficult within 48 hours of billing.

• Unauthorised Charges: Some users were billed without having signed up, with charges appearing even for those without active Uber accounts or before free trials expired.

Uber’s Response:

Uber disputes the allegations, stating that its processes comply with legal standards and are now streamlined. The company claims most users can cancel in-app within 20 seconds and that prior 48-hour contact rules no longer apply.

My Outlook – Regulatory Reckoning and Investor Caution

This case isn’t just a skirmish between a regulator and a tech firm—it’s emblematic of a wider regulatory recalibration in the US and likely soon in the UK. The FTC, under Andrew Ferguson’s leadership, is clearly pursuing an aggressive agenda against Big Tech, and this action against Uber is a bellwether.

From an investor’s perspective, the headline risk is just the surface. Beneath it lies a structural vulnerability: Uber’s monetisation strategy increasingly relies on subscription-based revenue (Uber One reportedly grew 60% YoY in 2024). If trust erodes in this revenue stream, or if regulators globally begin to clamp down on similar practices, we could see meaningful revenue contraction or margin compression due to compliance costs and fines.

In a UK context, where the CMA is already active in digital markets oversight, Uber’s £4.99/month Uber One offer may soon come under scrutiny—particularly if any of the UX ‘dark patterns’ identified in the US also appear in the UK app.

In my view, this case is a red flag for any investor assessing business models predicated on frictional retention—especially when regulatory tides are turning. It reinforces the importance of governance, compliance robustness, and ethical UX design as key non-financial indicators in investment due diligence.