Dark Patterns Guidelines in India: What Marketplace Sellers and D2C Sites Must Avoid

India's Guidelines for Prevention and Regulation of Dark Patterns, 2023 identify 13 types of deceptive interface design, and from 1 January 2027 every e-commerce entity must comply with them, run a yearly self-audit and display a certificate of compliance. The Central Consumer Protection Authority already asked platforms in June 2025 to self-audit and remove dark patterns. This is general information, not legal advice; confirm specifics with a lawyer.

What is a dark pattern in Indian law?

A dark pattern is an interface design that pushes a shopper into a choice they would not otherwise make. The 2023 Guidelines cover 13 types of it, according to the taxguru report on the CCPA advisory. That report does not list the 13, and none of the other sources we opened do either. The official text sits on the Department of Consumer Affairs website, which our tools could not open. We therefore do not name the 13 here. Download the Guidelines and read the list and the examples before you build a checklist from this page.

Do the guidelines bind me as a seller or only the platform?

The new obligation is written for e-commerce entities, not for sellers as such. Two things follow.

• On a marketplace, the platform carries the audit and the certificate. You carry the content you upload and the prices you set, and the platform will push its own risk back to you through listing rules. Rule 6(5) separately obliges sellers to give the platform product and transaction details.
• On your own D2C site, you are likely the e-commerce entity. Then the audit and certificate are yours. See our guide to the annual dark-pattern audit and certificate for what is and is not confirmed about the process.

Which dark patterns do sellers meet most often?

The rules we could verify do not use seller-friendly labels, so here is the practical mapping. The left column is the behaviour; the middle column is the verified rule that already addresses it; the right is what to check.

Behaviours such as false stock counters, countdown timers or hidden subscription renewals are not in the verified rows above because we could not confirm how the Guidelines treat them. They are exactly what the full text should be checked against.

How should I handle prices and discounts?

This is where sellers are most exposed. The prior-price rule means a "price cut" is measured against the lowest price at which the item was offered in the 30 days before the announcement.

For example, if you sold a ₹1,499 item at ₹1,199 for two weeks last month and then show "₹1,499 now ₹999", the comparison point under the rule is ₹1,199, the lowest price in the 30 days, not ₹1,499. Whether the marketplace or the seller applies the calculation depends on the platform; the rule text we saw puts the display duty on the entity. Keep your own price log so you can answer a query.

If you run festive deals, look at what the platform's tool shows as the original price, and keep your MRP, listed price and promotional price consistent with each other. Our festive discount calculator can help you test discount depth before you commit.

What about consent, data and the DPDP Act?

The E-Commerce amendment says marketplace entities may not use consumer information for specified purposes without express and affirmative consent. The release does not list the purposes. A separate data-protection regime also applies to the personal data your D2C store collects; see the DPDP Rules guide for e-commerce brands.

What does a quick self-check look like?

1. Open your D2C store in an incognito window on a phone and walk from product page to payment.
2. Note every box, banner, timer, badge and pop-up. Ask whether a shopper could be misled by it.
3. Untick every default checkbox.
4. Compare each "was" price with your last 30 days of prices.
5. Check that ads and sponsored placements are labelled.
6. Check that cancelling, returning or unsubscribing is not harder than buying. This is an audit question to test, not a rule we could confirm from the sources we opened.
7. Screenshot, date and file the result.

What should a D2C founder change first?

Start with the three things the verified rules touch directly: default checkboxes, "was" prices and unlabelled promotions. They are cheap to fix and easy to explain to a regulator. Next, give one person ownership of the Guidelines and a calendar slot every quarter, so the yearly audit is a review of work already done and not a scramble in December. Finally, keep screenshots of each checkout version you ship. If a complaint arrives through the National Consumer Helpline, which every e-commerce entity must now join, you can show what the customer actually saw on that date.

What happens if I get it wrong?

We could not confirm penalty amounts for dark patterns from the sources we opened. The PIB release names none, and a law-firm summary says contraventions from 1 January 2027 attract the applicable provisions of the Consumer Protection Act, 2019. The CCPA is the regulator that issued the 2025 advisory. For a marketplace seller the more immediate risk is commercial: the platform can delist or restrict listings that break its policies.

FAQ

How many dark patterns do the 2023 guidelines list? The Guidelines for Prevention and Regulation of Dark Patterns, 2023 cover 13 types. We could not open the official text to list them, so read the Guidelines on the Department of Consumer Affairs website for the names and examples.

Are the dark patterns guidelines mandatory? Yes for e-commerce entities from 1 January 2027, when the amended E-Commerce Rules require compliance with the Guidelines, a yearly self-audit and a displayed certificate. Before that, the CCPA advisory asked platforms to self-audit.

Is a pre-ticked checkbox allowed at checkout? No. The CCPA advisory cites Rule 4(9) of the E-Commerce Rules: purchase consent must be recorded through an explicit, affirmative action, not automatically through pre-ticked checkboxes.

Can I show a fake original price to make a discount look bigger? Not under the new price-reduction rule. From 1 January 2027, where a price cut is announced, the reduced price and the prior price must both be shown, and the prior price is the lowest price in the preceding 30 days.

Do I need to put the certificate on my Amazon storefront? No. The certificate is for the e-commerce entity, so on a marketplace it is the platform's job. If you run your own site, you likely need your own.

Does this apply to quick commerce sellers? The release covers e-commerce entities generally, and one news report says that includes quick commerce platforms. A brand selling through Blinkit or Zepto gives data to the platform and does not issue the certificate.

Next step: audit your own screens

Start with price claims and checkout defaults, then fix listing content. Blooprint, a Bengaluru e-commerce agency, works on catalogue content and promotions across marketplaces; our catalogue and listing optimisation service is the closest fit.