Getty Images is acquiring Shutterstock. This means the two largest stock content platforms in the world — relied upon by millions of independent creators — will come under the control of a single company.
The UK Competition and Markets Authority (CMA) has already launched an in-depth Phase 2 investigation and is accepting submissions from all interested parties until 19 April 2026. This is a rare opportunity where the voice of an individual contributor genuinely matters: the CMA is legally required to consider all submissions received.
What happens after the merger if contributors stay silent:
Your submission will carry weight if you:
You can be based in any country — the CMA accepts international third-party submissions.
Email: gettyimages.shutterstock@cma.gov.uk
Subject line:
Third Party Submission — ME/2252/25 — Getty Images / Shutterstock — [Your Name]Deadline: 19 April 2026 (the sooner, the better)
Format: A standard email with a PDF attachment, or the submission text in the body of the email. No special forms are required.
Confidentiality: If you do not want your personal details or financial figures published on the CMA's public case page, add the following sentence at the top of your submission:
"I request that my personal contact details and specific financial figures be treated as confidential and not published on the public case page."
Your letter does not need to be long. Even a short personal account of one page carries weight. What matters is specificity — concrete facts from your own experience.
1. Who you are Your name, country, how long you have been a contributor, which platforms, approximate portfolio size.
2. What you have personally experienced Specific facts: royalty cuts (when, from what rate to what rate), terms changed without consultation, your content used for AI training without consent, difficulties enforcing your copyright.
3. Why the merger makes this worse Even if there is currently some ability to switch between platforms — after the merger that option will be gone entirely.
4. What you are asking the CMA to do Block the merger, or impose conditions: a minimum royalty floor, opt-in consent for AI training use, a ban on account suspension as a tool to suppress IP enforcement.
Attach whatever you have readily available:
You do not need to attach everything — one or two documents that support the key fact in your letter is sufficient. You can offer to provide further documentation upon request.
Yours sincerely,
[Your Name]
[Professional Content Creator / Photographer / Videographer / Illustrator]
[Platform] contributor since [year]
Email: [your email]
Country of residence: [your country]
Supporting documentation available on request.https://www.gov.uk/cma-cases/getty-images-slash-shutterstock-merger-inquiry
Copy this prompt in full and paste it into Claude, ChatGPT, or another AI assistant. Fill in the details in square brackets with your own information.
Help me write a formal third-party submission to the UK Competition and Markets
Authority (CMA) in case ME/2252/25 — the investigation into the proposed merger
of Getty Images and Shutterstock. Deadline: 19 April 2026.
Submission email: gettyimages.shutterstock@cma.gov.uk
Background on the case:
- The CMA found a realistic prospect of SLC (substantial lessening of competition)
in both the editorial and stock content markets in its Phase 1 decision
(October 2025)
- The case is now at Phase 2 (in-depth investigation), with a statutory deadline
of 19 April 2026
- The US DOJ gave unconditional clearance on 23 February 2026 — the companies
are publicly pressuring the CMA to reach the same conclusion
- The Phase 1 decision did NOT examine contributors as a distinct economic sector
(upstream contributor market) — this is the key gap that needs to be addressed
My details:
- Name: [your name]
- Country: [your country]
- Platforms I contribute to: [Shutterstock / Getty Images / iStock / Pond5 / other]
- Contributor since: [year of registration]
- Approximate earnings: [amount or range, if you are willing to disclose]
- Portfolio size: [number of assets]
- Personal experience: [describe what happened — royalty cuts, account suspension,
content used for AI training without consent, difficulties enforcing copyright]
Key arguments to include (use those applicable to my situation):
1. MONOPSONY: After the merger, contributors will have no alternative platforms
of comparable scale. Shutterstock has already acquired TurboSquid (2021),
Pond5 (2022), and Envato (2024). Getty controls iStock, Unsplash, and others.
Combined: over 1 billion assets and 2.5 million contributors under single control.
2. ROYALTY COMPRESSION: In May 2020, Shutterstock cut royalties by approximately
74% without consulting contributors, simultaneously introducing a Yearly Rank
Reset. This is a textbook indicator of monopsony power.
3. AI TRAINING DATA: Shutterstock entered into agreements with OpenAI and LG AI
Research to use contributor content for AI model training without direct
compensation. Adobe pays contributors an annual Firefly bonus for the same
purpose — proving an alternative model exists. After the merger: the world's
largest legally cleared AI training dataset under single control.
4. IP RIGHTS SUPPRESSION: Shutterstock Submitter Terms of Service (Version 9,
Section 9b) require the company's prior written consent before a contributor
can take action against a licensee alleged to have misused their content.
This may constitute an abuse of dominant position under Chapter II of the
Competition Act 1998.
5. DOJ CLEARANCE is not applicable to the CMA's analysis: the DOJ did not
examine the contributor market or AI training datasets. The CMA has independent
jurisdiction under the Enterprise Act 2002.
Letter structure:
1. Introduction — who I am, years in the industry, scale of activity
2. Why Phase 1 did not examine the upstream contributor market
3. Evidence of monopsony power (with my personal data)
4. Suppression of IP rights (if applicable to my situation)
5. AI training datasets as a separate product market
6. Why DOJ clearance is not a precedent for the CMA
7. Specific remedies requested from the CMA
8. Conclusion
9. List of documents (attached and available on request)
Tone: formal legal English. The letter must address the specific findings of the
Phase 1 decision — not merely express dissatisfaction. All factual claims must
be supported by references to public sources (Shutterstock/Getty press releases,
SEC filings, official blogs).
Please include a references section at the end with numbered citations
linking each factual claim to its source.
Signature at the end:
[Name]
[Professional Content Creator / job title]
[Platform] contributor since [year]
Email: [email]
Country of residence: [country]This guide was prepared on the basis of a real submission to the CMA in case ME/2252/25.
Deadline: 19 April 2026 | Email: gettyimages.shutterstock@cma.gov.uk