many users have reported that Perplexity has recently introduced usage limits to its Pro plan. In an interaction with support, a Perplexity representative (“AGENT”) stated:
“This changed recently. While we can’t share exact figures, your current plan has usage limits. These billing limits may change over time and are essential to maintain the speed and reliability of the platform for everyone.”
An "anonymous" user notes that the product page for the Pro plan (https://www.perplexity.ai/pro previously advertised the service as “unlimited,” and that no prior notice was provided before these limits were implemented.
If confirmed, this situation raises serious concerns regarding transparency, deceptive marketing, unilateral modification of contractual terms, and the management of subscription relationships across several major jurisdictions.
2. Potential violations of EU law
2.1 Directive (EU) 2019/770 on digital content and digital services
Directive 2019/770 requires traders providing digital content or digital services to inform consumers clearly and comprehensibly about all relevant features and conditions of use before the contract is concluded. Usage limits are a substantial aspect of the service and therefore must be communicated in advance.
Where a change to the main characteristics of the service or the conditions of performance occurs during an ongoing contractual relationship, consumers must be informed in advance on a durable medium and, where the change has a negative impact on the consumer, they must be clearly informed of their right to terminate the contract without penalties.
By refusing to disclose “exact numbers” for usage limits and introducing such limits only after consumers subscribed to a service advertised as “unlimited,” Perplexity appears not to comply with the transparency and pre-contract information obligations set out in this directive.
2.2 Directive 2005/29/EC on unfair commercial practices
Under Directive 2005/29/EC, a commercial practice is considered unfair if it is misleading or aggressive and if it is likely to cause the average consumer to take a transactional decision they would not otherwise have taken.
Promoting a subscription as “unlimited” while effectively imposing undisclosed limits—or limits not disclosed in detail—may constitute a misleading practice by omission or by providing misleading information about the main characteristics of the service. The refusal to communicate the exact limits (“we can’t share exact numbers”) may aggravate this situation, as it prevents consumers from assessing the service’s real value.
2.3 Italian Consumer Code and AGCM enforcement
In Italy, the Consumer Code provides that unilateral changes to contractual conditions must be communicated with adequate notice (often interpreted as at least 30 days) and that consumers must be informed of their right to withdraw without penalties when such changes are detrimental.
Moreover, the lack of clear and complete information about substantial limitations may be considered an unfair commercial practice, regardless of a generic acceptance of terms and conditions. The Italian Competition Authority (AGCM) has the power to impose significant administrative fines—up to several million euros—in cases of misleading advertising and unfair commercial practices.
Introducing hidden or unspecified limits to a service previously described as “unlimited,” without notice and without clear information on withdrawal rights, appears inconsistent with these principles.
3. Potential violations of US law
3.1 ROSCA (Restore Online Shoppers’ Confidence Act)
ROSCA requires online sellers to clearly and conspicuously disclose all material terms of a transaction before obtaining consumers’ billing information, particularly in the context of recurring charges and subscription products.
Usage limits that materially affect the value, performance, or usability of a subscription are “material terms.” Failing to disclose them clearly and specifically, or refusing to share “exact numbers,” could be inconsistent with ROSCA’s clear-and-conspicuous disclosure requirement.
3.2 FTC Act — Unfair or deceptive acts or practices
The US Federal Trade Commission (FTC) has repeatedly emphasized that:
Advertising services as “unlimited” while imposing undisclosed or restrictive limits is likely to be considered deceptive.
Changing the main terms of a service (e.g., introducing limits to an “unlimited” plan) without adequate notice and an easy, accessible option to cancel may constitute an unfair or deceptive practice.
The FTC has previously taken enforcement actions against companies that marketed “unlimited” data plans or services and then restricted usage in ways not clearly communicated at the time of purchase.
3.3 Negative option and subscription principles
Under FTC negative option and subscription principles, companies that change key elements of a subscription—such as price, scope, or usage conditions—are generally expected to:
Provide clear and timely notice, typically within a period ranging from 7 to 30 days before the changes take effect.
Include clear explanations of the consumer’s right to cancel and provide an easy method to cancel.
Implementing new usage limits without prior notice and without clear, intuitive cancellation information is inconsistent with these principles.
4. Applicable Japanese laws
4.1 Consumer Contract Act (Japan)
Japan’s Consumer Contract Act aims to ensure consumer contracts are transparent and fair. It covers, among other things:
Situations where a business misrepresents important matters or intentionally (or through gross negligence) omits to disclose disadvantageous facts relating to important matters, causing the consumer to be mistaken at the time of contract formation.
Contract clauses that unreasonably disadvantage the consumer may be declared invalid.
If a service is advertised as “unlimited” but is in fact subject to undisclosed limits, or limits introduced later without clear communication, this may be considered a false statement or a failure to disclose disadvantageous facts regarding an important contractual element.
4.2 Act on Specified Commercial Transactions (SCTA – 特定商取引法)
The SCTA covers, among other areas, online and subscription-based transactions. Key obligations include:
Clear identification of the operator and the commercial nature of the solicitation.
Prohibition of unfair solicitation, including false or misleading explanations about prices, payment terms, and other material conditions.
Advertising rules requiring the presentation of important information and prohibiting false or exaggerated claims.
An obligation to provide the consumer, at the time the contract is concluded, with a written document (or an electromagnetic equivalent) describing the key terms.
Recent reforms (2022–2023) strengthened rules against deceptive subscription practices, including:
Stronger controls against “subscription traps,” where a service appears to be a one-time purchase but is actually a recurring subscription.
Prohibitions on unduly obstructing or complicating cancellations.
Clarification of civil rules on consumers’ right to rescind, particularly in cases of misleading or insufficient information.
A service advertised as “unlimited” and later subject to undisclosed limits, combined with a lack of clear and simple cancellation pathways, squarely fits the concerns these reforms were designed to address.
4.3 Act against Unjustifiable Premiums and Misleading Representations
The Act against Unjustifiable Premiums and Misleading Representations prohibits misleading representations that could induce customers to behave in a way that interferes with fair competition. It:
Prohibits false or grossly exaggerated claims regarding the quality, quantity, or other key attributes of goods and services.
Authorizes the Japan Fair Trade Commission (JFTC) to intervene and order the cessation of misleading representations.
Promoting a plan as “unlimited” while imposing undisclosed or non-transparent usage limits may be interpreted as a misleading representation under this law.
5. Consolidated assessment of the Perplexity case
Based on the reported information, the conduct at issue may present multiple overlapping compliance problems:
No prior notice
The company appears to have introduced usage limits “recently” without notice, contrary to expectations of advance communication under EU directives, US FTC negative option principles, and Japanese consumer protection standards.
Unspecified and non-transparent limits
The explicit refusal to disclose “exact numbers” for the limits conflicts with transparency obligations in all three jurisdictions, where usage limits constitute material contract terms and must be disclosed clearly and comprehensibly.
Lack of clear cancellation rights
There is no indication that users were explicitly informed of their right to cancel free of charge when the new limits were introduced, nor that they were clearly guided through a simple cancellation procedure. This is particularly sensitive under ROSCA, FTC negative option principles, EU consumer law, and Japan’s SCTA framework.
Potentially misleading “unlimited” advertising
Advertising the Pro plan as “unlimited” while it now imposes undisclosed or variable limits is likely to be considered misleading or unfair in the EU, the United States, and Japan. Past enforcement practice (including FTC actions and AGCM decisions) shows that regulators treat “unlimited” claims with particular scrutiny.
Unilateral and variable limits “over time”
Reserving the right to change limits “over time” without specifying clear criteria, thresholds, or notice obligations can be seen as an unfair contract term or an unfair commercial practice—especially when consumers bear all the risk and have not had a meaningful opportunity to reassess or withdraw from the contract.