Indian compliance ยท Glossary

What is Dark patterns?

Dark patterns are deceptive interface designs that trick users into choices they did not intend; India regulates them under the Guidelines for Prevention and Regulation of Dark Patterns, 2023, which name 13 types.

A dark pattern is a design that tricks a user into doing something they did not intend, such as buying an add-on or giving consent. In India, the Guidelines for Prevention and Regulation of Dark Patterns, 2023 cover 13 types, and the Central Consumer Protection Authority (CCPA) enforces them. As of November 2026, platforms also face annual self-audit duties.

What the rules and advisory say

  • The CCPA issued an advisory on 5 June 2025 asking all e-commerce platforms to run self-audits within three months, and encouraged self-declarations based on them.
  • Rule 4(9) of the Consumer Protection (E-Commerce) Rules, 2020 requires consent through an explicit, affirmative action, so pre-ticked checkboxes are not allowed.
  • The 2026 amendment to Rule 4 requires entities to follow the 2023 guidelines, carry out a yearly self-audit and display a certificate prominently; the Legal500 summary says it comes into force on 1 January 2027.

We could not open the 2023 guidelines text itself, so this entry does not list the 13 types. Read the original on the Department of Consumer Affairs site.

What it means for a seller

The audit duty falls on platforms, but a seller's listing can still look like a trick: fake urgency, hidden charges or misleading claims. Our guides on dark patterns guidelines for sellers and the annual audit certificate go further. Also see account health rating and listing quality score.

Examples of what counts

The one concrete example in the advisory coverage is a pre-ticked checkbox, which breaks the explicit-consent rule. Other practices people commonly describe as dark patterns include fake countdown timers and charges that appear only at checkout. We have not checked those against the guidelines' own list, so use the official text before treating a specific practice as covered.

What is still unclear

Whether marketplaces will pass audit duties down to sellers in their policies, and how the CCPA will treat seller-written listing copy, is not confirmed in the pages we opened. Watch your marketplace's policy updates.

How to keep your listings clean

Show the full price including GST, avoid countdown claims that are not real, do not pre-select add-ons or extras, and make cancellation or return terms easy to find. These are sensible practice drawn from the consent rule above, not a legal checklist, and they do not replace reading the guidelines.

Blooprint, a Bengaluru e-commerce agency, reviews catalogues for claims and content issues through catalogue and listing optimisation. This is general information, not legal advice; confirm with a lawyer.

Frequently asked questions

What are dark patterns in simple words?

Interface tricks that push a shopper into something they did not mean to do. Wikipedia describes them as designs crafted to trick users (source: https://en.wikipedia.org/wiki/Dark_pattern).

Do sellers have to do a self-audit?

The CCPA advisory of 5 June 2025 is addressed to e-commerce platforms, not to individual sellers (source: https://taxguru.in/corporate-law/ccpa-mandates-e-commerce-self-audits-dark-patterns.html). Check your marketplace's seller terms for what it asks of you.

Are pre-ticked checkboxes allowed?

No. Rule 4(9) of the E-Commerce Rules, 2020 requires explicit, affirmative consent, and pre-ticked boxes are not permitted (source: https://taxguru.in/corporate-law/ccpa-mandates-e-commerce-self-audits-dark-patterns.html).

When do the 2026 amendments start?

The Legal500 summary of the 2026 e-commerce rule amendments says they come into force on 1 January 2027 (source: https://www.legal500.com/intelligence/india/consumer-protection/consumer-protection-e-commerce-amendment-rules-2026-what-online-platforms-and-sellers-must-change-by-1-january-2027).

Related terms

Sources

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