User interface (“UI”) and user experience (“UX”) design play a vital role in how we navigate daily life—whether we are shopping online, connecting with others, or working digitally. These designs have a powerful impact on our choices, feelings, and behavior. As digital platforms increasingly shape the way we access information and make decisions, addressing dark patterns has become a crucial part of the conversation around consumer rights. It is not just about upholding ethical standards but ensuring that consumers have the power to make informed and voluntary decisions.
India’s journey toward regulating dark patterns began with the Information Technology Act, 2000. However, it lacked provisions specifically targeting manipulative user interface designs or deceptive consent mechanisms, leaving a gap in addressing dark patterns in digital interactions.
A major leap came with the Consumer Protection Act, 2019 (“CPA”), which broadened the scope of unfair trade practices and established the Central Consumer Protection Authority (“CCPA”). While the CPA marked progress in consumer rights, it did not explicitly address dark patterns, leaving ambiguity in its application to emerging online behaviors.
Significant development was followed, with the E-Commerce Rules in 2020, which mandated clear, affirmative consumer consent and prohibited tactics like pre-ticked checkboxes—practices often linked to dark patterns.
The regulatory landscape was strengthened with the Digital Personal Data Protection Act, 2023, which introduced stricter norms for informed, explicit user consent in data processing, empowering users with the right to manage/ withdraw consent, directly countering dark pattern strategies used to obtain/ retain data access.
The direct and comprehensive move came with the 2023 Guidelines for Prevention and Regulation of Dark Patterns (“the Guidelines”), issued by the CCPA. They apply broadly to all platforms that systematically offer goods or services in India, including advertisers and sellers. “Platform” is interpreted widely to include websites, software, and applications.
Unlike the E-Commerce Rules, the Guidelines do not clearly extend to foreign platforms targeting Indian users, posing a potential gap in cross-border enforcement. While the Guidelines effectively capture the complexity of dark patterns across various forms, their wide-ranging scope presents both a strength and a challenge i.e. they must be interpreted carefully to avoid overregulation that could stifle legitimate digital marketing innovations.
Section 4 imposes a categorical prohibition on all dark patterns, reinforcing India’s strong stance against such practices. As digital ecosystems continue to evolve, so must the interpretations and enforcement mechanisms to maintain a balance between user protection and innovation.
India took a significant step in strengthening digital consumer protection with the enforcement of the Guidelines since November 2023. They target deceptive design tactics used by digital platforms to manipulate users into actions they might not have taken voluntarily. Recognizing the urgency of curbing such practices, the CCPA placed them under strict scrutiny.
A major development occurred on May 28, 2025, during a high-level meeting chaired by the Consumer Affairs Minister, Pralhad Joshi. Over 50 key stakeholders from sectors including e-commerce, travel, fintech, food tech, and healthcare participated. They collectively pledged support for the Guidelines and committed to conducting compliance audits and launching consumer awareness campaigns. Further institutional support has been structured through a Joint Working Group, comprising the CCPA, NGOs, and academic bodies, aimed at overseeing the implementation, compliance, and educational outreach.
Technological innovation has played a pivotal role in enforcement. Following the “Dark Patterns Buster” hackathon, tools like the Jagriti Dashboard, and a real-time Jago Grahak Jago safety rating system were developed. These tools empower consumers to report violations, enhance digital literacy, and enable AI-powered monitoring for real-time oversight of deceptive practices.
On June 7, 2025, the CCPA escalated its efforts by issuing an advisory to over 50 online platforms, ranging from e-commerce giants to Meditech start-ups, mandating self-audits within a three-month period to eliminate any of the explicitly banned dark patterns. Platforms must also submit self-declarations affirming compliance and adherence to ethical design standards.
Since the guidelines' rollout, the CCPA has issued 11 specific notices for dark pattern violations and over 400 for broader unfair trade practices. The new advisory warns that non-compliance post the audit period may lead to strict enforcement actions, including legal penalties under the CPA.
This move positions India as a front-runner in addressing manipulative online behaviors, with clear frameworks for compliance, timelines for audit, and cross-sectoral engagement. The CCPA's actions reflect a robust shift towards pro-consumer digital governance, ensuring fair digital markets and standards across the online ecosystem.
By explicitly identifying manipulative design tactics and instituting enforceable compliance mechanisms, the authority has signaled a zero-tolerance approach to deceptive user interfaces. The integration of self-audits, cross-sector collaboration, and tech-enabled oversight not only empowers consumers but also holds platforms accountable in a rapidly digitizing economy. As digital interfaces continue to evolve, continued monitoring, regular updates to the Guidelines, and judicial interpretation will be essential to ensure their effectiveness without stifling innovation.
About the authors: Stella Joseph is a Partner, Prakhil Mishra is a Principal Associate and Sonalika Khatri is an Advocate with Economic Laws Practice.
Disclaimer: The opinions expressed in this article are those of the author(s). The opinions presented do not necessarily reflect the views of Bar & Bench.
If you would like your Deals, Columns, Press Releases to be published on Bar & Bench, please fill in the form available here.