The Government of India has issued an advisory directing all e-commerce platforms to conduct self-audits for deceptive design practices known as “dark patterns,” which mislead or manipulate consumers and constitute unfair trade practices under the Consumer Protection Act, 2019.
Dark patterns refer to user interface designs and choice structures that compel or trick consumers into decisions not in their best interest. These include drip pricing, disguised advertisements, bait-and-switch offers, false urgency, confirm shaming, basket sneaking, forced actions, subscription traps, interface interference, trick wording, SaaS billing exploits, rogue malware triggers and persistent nagging. Such practices are defined as “unfair trade practices” under Sub-section 47 of Section 2 of the Act.
The Central Consumer Protection Authority (CCPA), empowered under Section 18 of the Act, issued the “Guidelines for Prevention and Regulation of Dark Patterns, 2023” on November 30, 2023, identifying 13 distinct dark patterns prevalent across e-commerce platforms.
To operationalize the regulatory approach, the Department of Consumer Affairs held a meeting on May 28, 2025, chaired by the Minister of Consumer Affairs, Food & Public Distribution and New and Renewable Energy, engaging major e-commerce platforms, industry associations, voluntary consumer organizations and National Law Universities. The focus was on eliminating deceptive practices and strengthening consumer trust in digital marketplaces.
Following this deliberation, on June 5, 2025, the CCPA issued a formal advisory under the Consumer Protection Act, 2019, mandating that all e-commerce platforms undertake self-audits within three months to detect and remove dark patterns. Post-audit, platforms must submit a self-declaration confirming compliance and non-indulgence in any form of dark pattern design or manipulation.
To aid enforcement and knowledge sharing, a Joint Working Group was constituted through an office memorandum dated June 5, 2025, with representation from relevant Ministries, National Law Universities and Voluntary Consumer Organizations. The group is tasked with identifying dark patterns and coordinating efforts to build a transparent, ethical and consumer-centric digital environment.
These actions mark a decisive push by the government to create an equitable digital marketplace by promoting responsible design choices and holding platforms accountable for manipulative practices. The initiative seeks to align commercial innovation with consumer rights, ensuring fair play in India’s rapidly expanding e-commerce sector.
