India’s Ministry of Consumer Affairs has launched an enforcement campaign against dark patterns in digital commerce. Eleven companies, including Zepto, Rapido, Uber, and Ola, have received formal notices for violating interface design guidelines that undermine consumer autonomy. The ministry is enforcing the Guidelines for Prevention and Regulation of Dark Patterns, published in 2023, and has mandated annual internal audits for companies operating online platforms. These audits must identify deceptive practices in user interfaces and document efforts to remove or redesign them.
Dark patterns are design tactics that push users toward actions they would not otherwise take. This includes hidden fees, opt-outs disguised as confirmations, and subscriptions that are easy to start but difficult to cancel. The most common implementation occurs during checkout, in data-sharing prompts, or within misleading default settings. The intent behind these patterns is to increase revenue or data capture without the user’s informed consent.
On May 28, Union Minister for Consumer Affairs Pralhad Joshi convened over 50 companies and industry associations in New Delhi. Participants included Amazon, Flipkart, Apple, Google, Meta, Swiggy, Zomato, MakeMyTrip, NASSCOM, and FICCI. The ministry emphasized the need for all stakeholders to comply with design regulations that preserve user clarity and voluntary choice. Most attendees agreed to the framework in principle and committed to reviewing their platforms for violations.
Anonymously sourced complaints recently submitted to the Reserve Bank of India illustrate how these patterns work in practice. The apps Kuku FM and Stage allegedly used low-priced trials to lure users into automatic subscription billing without prominent disclosure. Once the user agreed to the trial, the system defaulted to premium monthly plans without requiring further confirmation. This scenario exemplifies a pattern known as forced continuity. Once initiated, the billing continues until the user actively identifies and disables it.
Regulators globally are moving to suppress similar techniques. The European Union enforces its Digital Services Act, and the United States Federal Trade Commission issues guidance to combat deceptive interfaces. India’s new enforcement approach is notable because it does not rely on passive compliance or long legal proceedings. Instead, companies must submit verified audit results and actively prove the removal of manipulative features.
Dark patterns fall into several defined categories. Each one functions by exploiting attention limits, misdirecting user focus, or overwhelming the decision space with misleading signals.
- Confirmshaming uses guilt to pressure user consent. Phrases like “No thanks, I prefer paying full price” are attached to opt-outs.
- Forced continuity continues billing after a trial without a user-triggered opt-in.
- Sneak into basket adds items to the cart by default.
- Privacy zuckering tricks users into sharing more data than they realize.
- Bait and switch changes the result of a user’s input after the fact.
- Roach motel makes account creation simple but cancellation difficult.
- Trick questions obscure consent choices through misleading phrasing.
- Disguised ads imitate interface elements to draw attention away from advertising disclosure.
Most e-commerce platforms use at least one of these mechanisms. These patterns are rarely accidental. They are designed through behavioral analytics to optimize outcomes for the platform, often at the expense of user clarity.
India’s regulatory shift redefines platform responsibility. Companies must now prove compliance not only through policy but through verifiable redesign. Internal audits must examine workflows, labeling systems, click-through paths, and billing logic. Annual reporting will track both violations and corrections. These reports must be delivered to the Department of Consumer Affairs and may become public under transparency obligations.
This enforcement is not limited to large companies. Any digital platform operating in India is subject to the same obligations. Startups and small developers must also ensure that their user interfaces are not coercive, misleading, or structurally deceptive.
Critics argue that the regulation may slow down digital commerce by reducing optimization techniques that increase conversions. However, advocates maintain that conversion should not be pursued at the cost of clarity or consent. Respect for user agency is considered a fundamental consumer right.
By requiring annual audits, removing regional exemptions, and treating interface design as a compliance issue rather than a stylistic choice, the Indian government signals a significant policy shift. Interfaces are no longer considered neutral delivery mechanisms. They are now recognized as powerful tools that can exploit cognitive vulnerabilities. The state’s role, under this view, is to prevent the abuse of that power.
This development is part of a wider global trend. California’s recent expansion of its privacy laws and the European Commission’s investigations into social media platform designs reflect growing momentum to enforce design ethics. India’s execution model is faster and more centralized. It sets a regulatory precedent that other countries may study and replicate.
Platforms that fail to comply face regulatory penalties, including public listing as non-compliant, legal fines, and in extreme cases, platform bans or service takedowns. At present, the focus remains on compliance through audit and redesign rather than punishment. This phase may not last. Non-compliance could accelerate more aggressive enforcement.
Interface regulation is no longer a theoretical debate. It is now embedded in law, procedure, and public expectation. India’s directive transforms how digital commerce must operate. It does not ban persuasion. It bans deception.
Works Cited
“Govt issues notices to 11 firms including Zepto, Uber for using dark patterns to sway consumers.” The Times of India, May 28, 2025.
“Dark patterns on e-commerce sites under fire: Govt mandates annual audits to combat dark patterns.” Business Today, May 29, 2025.
“India Asks eCommerce Platforms to Remove ‘Dark Patterns’ That Deceive Customers.” PYMNTS, May 28, 2025.
“Dark Patterns: Centre Asks Online Platforms to Ensure Compliance.” Outlook Money, June 3, 2025.