Dark patterns your online shop must avoid, and what to do instead

A dark pattern is a design or wording choice that pushes buyers into something they did not mean to do: buy faster, pay more or share more. India has an official list of dark patterns, and from 1 January 2027 e-commerce entities will also have to audit themselves against it every year. This post explains the rules, shows each of the 13 patterns as it might look in a small online shop, gives the honest alternative, and walks you through a self-audit.

The short descriptions here are ours, in plain words; read the guidelines for the official definitions. This post is not legal advice.

What the rules say, and who they cover

The Central Consumer Protection Authority (CCPA) issued the Guidelines for Prevention and Regulation of Dark Patterns, 2023 on 30 November 2023, under the Consumer Protection Act, 2019. They apply to platforms that systematically offer goods or services in India, to advertisers and to sellers, and they say no one may engage in a dark pattern. So sellers are covered too, whether they sell on their own website or through a marketplace.

The draft published in September 2023 listed ten patterns. After public comments, the final guidelines added three more: trick question (some releases call it trick wording), SaaS billing and rogue malwares, making 13.

Enforcement has followed. In June 2025 the CCPA advised e-commerce platforms to self-audit for dark patterns within three months, and 26 leading e-commerce platforms later declared that they comply. The CCPA has also fined an online education platform ₹5 lakh after a ₹10 donation was selected automatically at checkout, with emotional messages discouraging buyers from removing it.

In September 2026 the government amended the E-Commerce Rules. From 1 January 2027, e-commerce entities must comply with the 2023 guidelines, undertake a yearly self-audit and prominently display a certificate of compliance. Ask your lawyer how this applies to your shop.

The 13 dark patterns, in plain words

Here is each pattern as it might appear in a small online shop, and the honest version. The examples are ours.

Price tricks: the ones to fix first

Drip pricing, basket sneaking and bait and switch all change what the buyer pays, so fix them first.

• Show the full price early. The Consumer Protection (E-Commerce) Rules, 2020 ask for the total price with a breakup of compulsory and voluntary charges, such as delivery and handling. The Consumer Protection Act, 2019 treats an advertisement that deliberately conceals important information as misleading.
• Never pre-tick a purchase. The E-Commerce Rules say consent to a purchase must come from an explicit and affirmative action, never recorded automatically, including through pre-ticked checkboxes.
• Keep "free" honest. The CCPA's 2022 guidelines on misleading advertisements say something is not free if the buyer pays packing or handling charges for it, or if the price of what they must buy was raised for the offer.

Before a sale, put your MRP, cost and offer into the Discount and Sale Price Calculator. Besides the real discount and your margin, its honest pricing checks look at a price above the MRP, discount and "free" claims, countdowns and fees added at the last step.

Pressure and choice: wording and design

False urgency, confirm shaming and nagging push buyers to decide fast or feel bad. A countdown is fine when the offer really ends then; end it when you said you would. Show a stock count only if it comes from your real stock.

Forced action, interface interference and trick questions take a choice away. Let buyers check out as guests where you can, and ask only for details the order needs. For boxes that sign buyers up to offers, the Digital Personal Data Protection Act, 2023 asks for consent given with a clear affirmative action, so leave them unticked.

For disguised advertisement, the Department of Consumer Affairs asks that a paid or other material connection in an endorsement is disclosed in a way that is "clear, prominent and extremely hard to miss". That covers influencer posts and reviews you paid for or gave free products for.

A worked example: one small checkout

Rangoli Home Decor in Lucknow is a made-up shop selling cushion covers. Here is what its owner found on a walk through her own checkout, and what she changed:

• Product page: a theme app showed "Only 3 left, 14 people are viewing" on every product, whatever the real stock. She turned the app off and now shows stock only when it is truly low.
• Cart: "Gift wrap ₹49" was ticked for every order. She left the box unticked, with the price next to it.
• Payment step: a ₹29 convenience fee appeared only here. She folded it into her product prices instead.
• Exit pop-up: the button to close it read "No, I don't like saving money". It now reads "No thanks", in the same size as the other button.

None of these changes stopped her selling the offer. They only stopped the page from deciding for the buyer.

Your policies count too

A dark pattern can sit in your terms as well as your buttons. A refund policy that says "no refunds under any circumstances" can mislead buyers, because the E-Commerce Rules say a seller cannot refuse to take back goods, or refund them, if they are defective, deficient or spurious. The same Rules bar cancellation charges unless you bear similar charges when you cancel, and ask for a grievance officer who acknowledges complaints within 48 hours and resolves them within one month.

The Return and Refund Policy Builder turns your answers into a policy and checks it against those Rules and our checklist, flagging blanket lines like that one. If you charge for cash on delivery, say so upfront; our post on cutting COD returns shows how to nudge buyers to prepay without dark patterns.

Run your own self-audit

You do not need a big team. Set aside an hour and do this for your own shop:

1. Walk through your checkout as a buyer, on a phone, from a product page to the payment step. Screenshot every step.
2. Copy the text of each step, or the page's HTML source, into the Dark Pattern Checker for Online Shops. It marks phrases that point to 12 of the 13 patterns (rogue malwares cannot be seen in a page's text) and boxes ticked in advance.
3. Tick what the flow does, such as "a fee appears only at the last step" or "adds a donation to the cart by default", because text cannot show colours, timers or what happens after a click.
4. Fix the worst first, using the plain explanation and fix next to each flagged item.
5. Keep dated notes: the report, your screenshots and what you changed.

The checker uses fixed word lists, not AI, and a match is a reason to look, not proof. A page with no matches can still mislead. It does not issue a certificate.

Mistakes to avoid

• Copying a big platform's checkout. The CCPA has asked large platforms to audit theirs, so a pattern you see elsewhere is not proof that it is allowed.
• Forgetting your theme and apps. Shop themes and apps can add timers, pop-ups and pre-ticked boxes; switch off what you cannot stand behind.
• Checking only the desktop site. Check on a phone too: faded buttons and small print are hardest to read on a small screen.
• Auditing once. New offers, apps and sale banners bring patterns back, so check before every sale.

Your next step

Run the self-audit on your checkout this week, then again before your next sale. If you are also checking your pack labels, read our post on what must be printed on a product package. All our free tools for online sellers work in your browser and never sign in to your shop or seller accounts. If you want a second opinion on your pages, get in touch.