In June 2025, the Central Consumer Protection Authority (CCPA) gave e-commerce platforms a three-month ultimatum to conduct self-audit and steer clear of dark patterns. Earlier, CCPA had issued notices to IndiGo Airlines and BookMyShow under Consumer Protection Act, 2019 for alleged deceptive design practices.
Here’s what this means for the 800 million Indians navigating our digital economy daily.
When Design Becomes Deception
Let me paint a picture you’ll recognize. You’re booking that Goa flight, excited about your weekend getaway. The website screams “Only 2 seats left!”. You rush through booking, only to discover a ₹500 “convenience fee” and ₹200 insurance premium mysteriously added to your cart.
Familiar? You’ve just encountered what regulators call “dark patterns”, deliberate design tricks that manipulate users into actions they never intended.
Surveys by consumer advocacy group LocalCircles reveal that 77% of consumers surveyed reported facing “Forced Action” on OTT platforms, where they were required to share unnecessary personal details to access content
Finally, Guidelines With Some Teeth
Building on their 2023 guidelines, the CCPA’s June 2025 advisory classifies dark patterns as “unfair trade practices” under the Consumer Protection Act, 2019, giving them legal enforcement power.
For instance, BookMyShow had to remove their automatic service charge additions. IndiGo was forced to eliminate those guilt-inducing insurance purchase buttons.
What are dark patterns? And, why do we need to care?
The 13 Faces of Digital Manipulation
Dark patterns are “manipulative user interface (UI) design elements used by websites and apps to trick users into taking actions they didn’t intend”.
The CCPA has identified 13 specific dark pattern types as illegal. I’m breaking them down in categories that make sense:
Financial Trickery:
- Drip Pricing: Hiding the real price until checkout (those surprise airline fees)
- Basket Sneaking: Adding items you never selected
- SaaS Billing: Making subscription cancellation unnecessarily complex
Psychological Pressure:
- False Urgency: Fabricating scarcity to rush decisions
- Confirm Shaming: Guilt-tripping users (“No thanks, I don’t want to save money”)
- Nagging: Endless pop-ups and persistent requests
Information Warfare:
- Interface Interference: Hiding important details while highlighting misleading ones
- Bait and Switch: Promising one thing, delivering another
- Disguised Ads: Blurring the line between content and advertisements
- Trick Wording: Using confusing language to mislead
Forced Compliance:
- Forced Action: Requiring unrelated actions to access services
- Subscription Trap: Making cancellation a maze of confusion
- Rogue Malware: Tricking users into downloading harmful software
I’m sure most of you have experienced many of the above patterns. Did you consider how easy it is to subscribe to an OTT as opposed to opting out? Did you notice how auto-renewal is the default, and it takes herculean efforts to cancel that?
But this helps formalize what we’ve always known but couldn’t put in words.
Where Persuasion Ends and Manipulation Begins
Not all influence is manipulation.
I remember what my marketing professor used to say: “Marketing cannot create demand. It can only help customers identify unmet demand”.
For instance, copywriting is the skill to write in a way that persuades the reader to buy our products. A copy that clearly identifies the customer’s pain point, and offers a solution in a compelling language is bound to resonate with them. A copy that starts with a customer story is better-placed to convince than a fact-sheet without any narrative.
Robert Cialdini’s work (especially, Influence) contains wisdom that feels illegal to possess. In fact, Charlie Munger is quoted as saying, “The way to get rich is to get a lot of knowledge that other people don’t have. And one of the great things that a person can do is learn some psychology. I think Cialdini’s book, Influence, is one of the greatest books ever written.”
But there’s a difference between ethical persuasion and dark patterns. Legitimate influence respects user autonomy while providing genuine value. Dark patterns eliminate or impair choice through deception.
Consider these two approaches to showing product popularity:
Ethical:
- “This item has 4.5 stars from 1,200 verified buyers”
- A financial advisor gifts a book on investing wisdom to his potential clients. This employs ‘reciprocity’ for business, which is legitimate.
Dark Pattern:
- “Only 1 product left” (when the number is fabricated).
- Consider the wording when a customer opts out of default travel insurance, “No, I will take the risk”.
One builds trust through transparency. The other employs psychological triggers and deception.
The key distinction? Intent and honesty.
Why This Matters: Real Impact for Real People
The Government of India launched tools like the Jagriti App that have already enabled over 2 million consumers to report violations directly.
For average users, the changes promise:
Immediate Relief:
- No more surprise fees at checkout
- Easier subscription cancellations
- Honest availability information
- Clear distinction between ads and content
Long-term Benefits:
- Restored faith in digital platforms
- Better-informed purchasing decisions
- Protection from psychological manipulation
- A marketplace competing on value, not tricks
The Business Reality Check
Before you dismiss this as anti-business sentiment, consider this: India’s digital economy is projected to hit $1 trillion by 2027. Consumer trust is an economical necessity.
Companies embracing transparency early will likely gain competitive advantages. Those resisting have a tough road to navigate in an increasingly aware market (besides regulatory penalties). The three-month self-audit deadline is a great opportunity for companies to not just comply, but fuel competitive differentiation.
But let’s be realistic. Changing deeply embedded business practices takes time. Some companies will test the boundaries. Others will find creative ways around regulations.
The real test is whether enforcement remains consistent and penalties remain meaningful six months from now.
The Bigger Picture
This regulatory push represents more than consumer protection. It’s about defining what kind of digital economy India wants to build.
Do we want innovation that serves users or exploits them? Technology that enhances choice or eliminates it?
Whether this regulatory moment becomes a lasting transformation or another well-intentioned initiative that fades away remains to be seen. But given the increasing customer awareness, I’m cautiously optimistic.
What’s your experience with dark patterns? Have you noticed changes in how platforms present choices since these guidelines? Share your thoughts in the comments.
Musings by Madhav 
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