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Unredacted FTC complaint alleges Amazon ad prices up to 250% over auction

The FTC's updated complaint puts numbers on what the August filing left blacked out, including alleged increases of up to 250% on major shopping days. With Black Friday on November 27, here's what it says and what to check in your own event-day data.

By Founder, Lead Brand Strategist

The short answer

On November 5, 2026, the Federal Trade Commission and 22 states filed an updated, less-redacted complaint in their lawsuit over Amazon's ad auctions. It alleges Amazon raised advertising prices by as much as 50% over auction results on ordinary days and by as much as 250% on days like Prime Day and Black Friday, and that surcharges added $87 million in worldwide revenue in the 2022 holiday season. Amazon has denied the case's claims. Nothing has been proven in court.

On November 5, 2026, the Federal Trade Commission and 22 states filed an updated complaint in their lawsuit over Amazon's search advertising auctions, with many of the details that were blacked out in August now public.

The new version alleges that Amazon raised ad prices "by as much as 50% above auction results on ordinary days" and "by as much as 250% on major shopping days like Prime Day or Black Friday." Those are allegations. Amazon has denied the case's claims, and no court has ruled.

We covered the original suit, filed August 31, 2026, in our explainer on the FTC's Amazon ad auction lawsuit. This piece is about what's new, and why the timing matters with Black Friday falling on November 27, 2026.

What the unredacted complaint adds

The FTC's release describes newly unredacted details of the alleged scheme, and the FTC's case page lists the updated complaint as a November 5, 2026 filing. The August version described Amazon replacing a second-price auction result with a higher "soft reserve" price, but left the size of the alleged increases blacked out. The new filing fills in numbers, dates and internal messages.

As described in the FTC's release, the complaint alleges:

  • Ordinary days: prices allegedly raised by as much as 50% above auction results.
  • Major shopping days: allegedly by as much as 250% on days like Prime Day or Black Friday.
  • 2021 holiday season: the complaint says advertisers' average cost per click rose 20%, with some advertisers seeing increases above 200%.
  • 2022 holiday season: the complaint says Amazon raised its surcharges to increase its revenue by $87 million worldwide.
  • Prime Day 2023: the complaint says one large food and beverage advertiser was subjected to price increases of more than 100%, which the complaint says Amazon internally acknowledged was "destroying campaign performance."
  • 2023 planning: the complaint says Amazon executives discussed the need to find an additional $40 million in revenue to meet corporate financial targets. It quotes an email from the head of Amazon Ads, who isn't named in the release, saying: "I'd like to pull out all of the stops (without doing unnatural acts) to close our gaps to plan."

The release also describes an advertiser asking whether "something has changed with respect to the second price auction process." The FTC says an Amazon account manager replied: "This year the marketplace is even more crowded than any year previous, and we are seeing the spike in CPCs." The FTC alleges that answer misled the advertiser.

We read the FTC's press release and its case page, which lists the updated complaint as a November 5, 2026 filing. We couldn't download the complaint PDF itself as of November 6, 2026, so the figures above are as the FTC's release states them.

The case so far

  1. Holiday 2021

    Average CPC up 20%, as alleged

    The updated complaint says some advertisers saw increases above 200%.

  2. Holiday 2022

    $87 million added, as alleged

    The complaint says raised surcharges increased Amazon's worldwide revenue by that amount.

  3. Prime Day 2023

    One advertiser above 100%, as alleged

    A large food and beverage advertiser, not named in the release.

  4. Aug 31, 2026

    FTC and 22 states sue

    Original complaint filed in the Western District of Washington with key figures redacted. Amazon responds the same day.

  5. Nov 5, 2026

    Updated complaint unredacts details

    The FTC publishes the new figures and internal messages.

  6. Nov 27, 2026

    Black Friday

    The first major shopping day since the new figures became public.

The alleged increases, side by side

The figures in the release measure different things, so they aren't one series. Read them as the scale the complaint alleges, not as a trend.

As alleged in the FTC's updated complaint

Alleged ad price increases on Amazon

Figures from the FTC's November 5, 2026 press release. Allegations, not findings.

  • Average CPC, 2021 holiday season20%
  • Maximum above auction result, ordinary days50%
  • One advertiser, Prime Day 2023 (more than)100%
  • Maximum above auction result, major shopping days250%
Alleged ad price increases on Amazon
ItemValue
Average CPC, 2021 holiday season20%
Maximum above auction result, ordinary days50%
One advertiser, Prime Day 2023 (more than)100%
Maximum above auction result, major shopping days250%
Each bar is a separate allegation: an average across advertisers for one season, two 'as much as' ceilings, and one advertiser on one day. The complaint doesn't present them as comparable measures, and Amazon disputes the case.

What Amazon says

Amazon's August 31 response calls the lawsuit "misguided" and says: "In no scenario does an advertiser pay more than their bid." It describes the soft reserve as "a real-time minimum value" meant to reflect what a placement is worth and says average cost per click "remained flat when adjusted for inflation" from 2019 through 2024.

Search Engine Journal reported that the FTC's November 5 release didn't include a new Amazon response to the unredacted details.

There's no conflict between "up to 250% above the auction result" and "never more than the bid," and that's worth understanding. If the second-price result was low and your bid was high, a price well above the auction result can still sit at or under your bid. Both statements can be true at once. Which one describes your campaigns is something your own reports can show.

Our read: your bid is the ceiling, so set it like one

We said this when the suit was filed and the new figures make it sharper. Whatever the court decides, the working assumption on Amazon should be that your bid is close to your price, especially on the biggest days. Many of the complaint's most specific allegations are about peak periods: holiday seasons and Prime Day.

That's the habit to break before Black Friday on November 27 and Cyber Monday on November 30. A lot of event-day playbooks raise bids sharply on the theory that the auction will only charge what it takes to win. If the complaint is even partly right about how pricing behaved on those days in 2021 to 2023, an inflated bid is the number you should expect to pay, not a safety margin.

None of this is legal advice. If you think you were affected, talk to your own counsel. We're not lawyers, and the case is at an early stage. What we can do is help you read your own data. It's the check we run in every retail media audit and part of how we manage Amazon advertising.

What to check before Black Friday

Event-day bid check

  • Pull Sponsored Products and Sponsored Brands targeting reports for Prime Day 2026 and Black Friday through Cyber Monday 2025, with clicks, spend and bids.
  • Divide cost per click by bid for each target on those days and on a normal week. Ratios near 1.0 mean you paid close to your bid.
  • Compare event-day ratios with normal-day ratios. A big jump tells you your peak bids were setting your price.
  • Set event-day bid ceilings from what a click is worth at your conversion rate and margin, not as a multiple of your everyday bid.
  • Cap budgets by hour or by day on Black Friday and Cyber Monday so a high-CPC morning can't spend the whole day.
  • Save the exports so you can compare 2026 event-day ratios with 2025.

Common questions

What did the FTC's November 5, 2026 filing in the Amazon ad case reveal?

It's an updated version of the complaint with details that were redacted in August. It alleges Amazon raised ad prices by as much as 50% above auction results on ordinary days and as much as 250% on major shopping days, that average cost per click rose 20% in the 2021 holiday season, and that surcharges added $87 million in worldwide revenue in the 2022 holiday season. These are allegations, not findings.

Has Amazon responded to the FTC's ad auction allegations?

Amazon responded to the original suit on August 31, 2026, calling it misguided and saying that in no scenario does an advertiser pay more than its bid. Search Engine Journal reported that the FTC's November 5 release didn't include a new Amazon response to the unredacted details.

Does the FTC case change how Amazon ads are priced today?

No ruling has been made, so nothing in the case changes the auction you're buying in. The new filing's figures concern the period from 2021 to 2023 and focus on peak shopping days, which is why we'd check your own event-day cost per click against bids before Black Friday.

Sources

Everything above is drawn from these documents. Where a figure is ours, the text says so. Spotted an error? Our corrections policy says how we fix it.

  1. 01
    New Details Emerge in Amazon Ads Auction-Rigging Case

    Federal Trade Commission

  2. 02
    Amazon (timeline item) - November 5, 2026

    Federal Trade Commission

  3. 03
    FTC, States Sue Amazon Over Secret Ad Surcharge Scheme

    Federal Trade Commission

  4. 04
  5. 05
    FTC Unseals Details In Amazon Ads Auction Surcharge Suit

    Search Engine Journal

Josh Grillo, founder, lead brand strategist at Sell Through

Josh Grillo

Founder, Lead Brand Strategist

Josh founded Sell Through after twelve-plus years running beauty, supplement and pet brands on Amazon and the marketplaces around it. He leads strategy on every account and is the editor responsible for everything published here.

More about JoshHow we source and correct

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