The Central Consumer Protection Authority (CCPA) has issued an advisory on June 5, 2025, directing all e-commerce platforms to conduct self-audits to detect and eliminate “Dark Patterns” within three months. This directive, issued under the Consumer Protection Act, 2019, aims to ensure fair and ethical digital practices. The CCPA notes that despite its 2023 Guidelines for Prevention and Regulation of Dark Patterns, which outline 13 types of such deceptive practices, instances of their use persist. The advisory specifically references Rule 4(9) of the Consumer Protection (E-Commerce) Rules, 2020, which requires explicit and affirmative consumer consent for purchases, prohibiting automatic consent via pre-ticked checkboxes. E-commerce platforms are encouraged to provide self-declarations based on their audits, fostering consumer trust. The CCPA has requested wide dissemination of this advisory among e-commerce entities, industry associations, consumer organizations, and academic institutions to promote internal audits for Dark Pattern prevention. Also Read Press Release: CCPA Urges E-commerce Platforms to Self-Audit for Dark Patterns
CCPA-1/1/2023-CCPA
Central Consumer Protection Authority
Krishi Bhawan, New Delhi
Dated: 5th June, 2025
Subject: Advisory in terms of Consumer Protection Act, 2019 on Self-Audit by E-Commerce Platforms for detecting the Dark Patterns on their platforms to create a fair, ethical, and consumer-centric digital ecosystem.
The Central Consumer Protection Authority (CCPA) has been established under Section 10 of the Consumer Protection Act, 2019 to regulate matters relating to violation of consumer rights, unfair trade practices and false or misleading advertisements prejudicial to the interest of public and consumers to promote, protect and enforce the rights of consumers as a class.
2. Whereas, the CCPA under Section 18(1) is empowered to ensure that no person shall engages himself in unfair trade practice and therefore, to safeguard the rights of class of consumers the Guidelines for Prevention and Regulation of Dark Patterns, 2023 were also notified which categorically encompasses 13 types of Dark Patterns.
3. Whereas, it has come to the notice of Central Consumer Protection Authority (CCPA) that despite these Guidelines instances of Dark Patterns have been noticed on E-Commerce platforms. Notices in certain cases have also been issued by the CCPA.
4. Whereas, the Consumer Protection (E-Commerce) Rules, 2020 clearly stipulates under Rule 4(9) that every e-commerce entity shall only record the consent of a consumer for the purchase of any good or service offered on its platform where such consent is expressed through an explicit and affirmative action, and no such entity shall record such consent automatically, including in the form of pre-ticked checkboxes.
5. Therefore, all e-commerce platforms are advised to take necessary steps to ensure that their platforms do not engage in such deceptive and unfair trade practice which are in the nature of Dark Patterns. Inter-alia, all e-commerce platforms are advised to conduct self-audits to identify dark patterns, within 3 months of the issue of this advisory, and take necessary steps to ensure that their platforms are free from such dark patterns. The e commerce platforms, based on the self-audit reports, are also encouraged to give self-declarations that their platform is not indulging in any dark patterns. The self-declarations by the platforms will enable fair digital ecosystem along with building trust between consumers and e-commerce platforms.
6. All e-commerce platforms, industry associations, voluntary consumer organization and academic institutions are hereby requested to give wide dissemination of this Advisory to impress upon the practice of prevention of Dark Patterns through internal audits to identify and eliminate Dark Patterns.
(Nidhi Khare)
Chief Commissioner
To:
1. Secretary, Ministry of Electronics & Information Technology,
2. Secretary, DPIIT, Ministry of Commerce & Industry,
3. Secretary, Department for Telecommunication – Ministry of Communication,
4. Secretary, Ministry of Information and Broadcasting
5. Director General, Press Information Bureau,
6. Director, National Information Centre, Department of Consumer Affairs
Copy to:
1. All E-Commerce entities.
2. CII/FICCl/ ASSOCHAM/ PHDCCl/ RAI / CAIIT with a request to circulate it amongst their members.
3. All Voluntary Consumer Organizations.
4. All National Law Universities
5. All the I ITs
