Introduction
Unfamiliar with the term “dark patterns” or unaware of the recent measures taken by the Central Consumer Protection Authority (CCPA)? In a bid to promote clarity, honesty, and fairness in user interactions, the CCPA has issued strict directives to ensure that digital platforms operate in a transparent and consumer-centric manner.
In this article, we break down the key highlights of the latest advisory issued by the CCPA, which calls on all e-commerce platforms to take steps to eliminate dark practices. Whether it’s a pre-ticked checkbox, a misleading button label, or a confusing navigation path, no part of the user interface should be designed in a way that causes users to take actions they did not intend. These steps mark a significant push toward a more ethical and trustworthy digital economy.
Ever found yourself subscribed to newsletters or articles you never signed up for? or billed for services or charges you didn’t knowingly agree to? or perhaps have felt pressured by prompts like “Hurry Up! Sale ending soon” or “Order Now! Somebody from Delhi just purchased the same product”, that’s a dark pattern, a deceptive design technique crafted to trick you into doing things you didn’t intend.
While the term “dark patterns” may seem unfamiliar at first glance, the reality is that almost every internet user has encountered this digital trap at some point. Simply put, dark patterns are manipulative design practices that companies employ to nudge, or in many cases, coerce users into taking actions they never consciously intended, often to the benefit of the business behind the interface.
The Central Consumer Protection Authority (CCPA) on 5th June, 2025 vide its notification being CCPA-1/1/2023-CCPA, to ensure compliance with Rule 4(9) of the Consumer Protection (E-Commerce) Rules, 2020 which states that every e-commerce entity shall only record the consent of a consumer for the purchase of any good or service offered on its platform where such consent is expressed through an explicit and affirmative action, and no such entity shall record such consent automatically, including in the form of pre-ticked checkboxes, has directed the following:
- All e-commerce platforms are advised to take necessary steps to ensure that their platforms do not engage in such deceptive and unfair trade practice which are in the nature of dark patterns.
- Conduct self-audits within three months to identify and eliminate dark patterns, deceptive design practices that mislead consumers into unintended actions to create a fair, ethical and consumer-centric digital ecosystem.
- E-commerce platforms, based on their self-audit reports are also encouraged to provide self-declarations affirming that they do not engage in such practices.
What are Dark Patterns?
The Guidelines for Prevention and Regulation of Dark Patterns, 2023 (“Guidelines”), clearly prohibit any platforms offering goods and services, advertisers and sellers from deploying dark patterns, which is defined as “any practices or deceptive design patterns using UI/UX (user interface/user experience) interactions on any platform; designed to mislead or trick users to do something they originally did not intend or want to do; by subverting or impairing the consumer autonomy, decision making or choice; amounting to misleading advertisement or unfair trade practice or violation of consumer rights.”
The Guidelines have identified the following dark patterns as specified dark patterns. Let’s understand it with some real-life examples.
- False Urgency – “Hurry Up! Only 2 more left”
- Basket Sneaking – Pre-Checked tick boxes, Auto-adding items, payments to charity/donation etc. at the time of checkout from a platform.
- Confirm Shaming – “Yes, I want to stay informed or No, I prefer to remain ignorant”, “Yes, I want to learn how to grow my business or No, I’m not interested in improving”
- Forced Action – “Signup to download the free eBook”
- Subscription Trap – Easy sign up but complicated cancellation
- Interface Interference – A pop-up shows only the “Yes” button clearly, while the “No” button is a small ‘X’ hidden in a corner.
- Bait and switch – A portal that advertises a “free resume download,” but after registration and providing details, users are told to pay to download.
- Drip pricing – A flight booking website initially shows ₹3,000, but adds baggage fees, taxes, and convenience charges only at the payment page.
- Disguised advertisement – Fake system notification that is actually an ad leading to a sponsored app download.
- Nagging – A pop-up asking you to enable notifications appears every time you open an app, even after declining.
The measures undertaken by the CCPA serves a crucial role in protecting consumers and users from being misled, deceived, or manipulated into actions they did not originally intend or consent to. By implementing such safeguards, e-commerce platforms are not only being held accountable for deliberate manipulative practices but are also being reminded that ethical and transparent user interface (UI) and user experience (UX) design is essential. These regulations emphasize that all user interactions must be designed to ensure clarity, honesty, and fairness. E-commerce platforms are thereby expected to review the dark patters in their UI/UX and ensure that no aspect of the interface, whether a pre-ticked checkbox, misleading button label, or confusing navigation, can result in unintended user behavior.
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