An RTI filed by MediaNama reveals that 25 major platforms have submitted their mandatory dark pattern self-declarations to the Central Consumer Protection Authority (CCPA). Notably, these include companies operating in the e-commerce, travel, food delivery, pharmacy and retail domains.
However, the CCPA refused to share any of the actual self-audit reports. Instead, it directed MediaNama to its advisory issued on June 5, 2025, and said that companies have been instructed to make their self-audit reports public on their own websites. Thus in effect, the RTI does confirm who filed declarations, but offers no visibility into what their internal audits found.
For context, major consumer platforms including Flipkart, BigBasket, Myntra, JioMart, Swiggy, Zomato, Zepto, Tata 1mg, Blinkit, Cleartrip and Ixigo, as well as multiple Reliance Retail brands have submitted mandatory self-declarations for dark patterns.
Government’s Push on Dark Pattern Compliance
For context, the RTI response arrives during a period of heightened regulatory scrutiny: on June 5, the CCPA issued an advisory under Section 18(1) of the Consumer Protection Act directing all platforms to complete self-audits for dark patterns within three months.
The advisory referenced the Dark Pattern Guidelines, 2023, and reminds platforms of the requirement for clear affirmative user action as per Rule 4(9) of the E-Commerce Rules, 2020.
Furthermore, the Department of Consumer Affairs formed a 19-member Joint Working Group to study dark patterns and recommend safeguards. Officials have also showcased tools from the Dark Patterns Buster Hackathon, including user-reporting and link-scoring systems.
Previously, on May 28, Union Consumer Affairs Minister Pralhad Joshi met Amazon, Flipkart, Swiggy, Zomato, MakeMyTrip, Meta, WhatsApp and Apple, urging them to eliminate manipulative design patterns.
LocalCircles Audit Suggests Widespread Violations
Notably, LocalCircles’ four-month national audit from June to September 2025 provides additional context on why transparency around self-audits matters. The audit found that 97% of India’s 290 major online platforms continue to use dark patterns despite the guidelines.
Its findings notably include:
- 75% of users faced hidden fees
- 48% experienced bait and switch
- 44% reported privacy misuse
- 29% encountered forced actions
- 21% saw basket sneaking
Interestingly, Meesho was the only platform that cleared all tests. These results suggest that several of the platforms listed in the RTI may be using manipulative design practices even after filing declarations.
Enforcement Gaps and Ongoing Hidden-Fee Investigation
The Department of Consumer Affairs (DoCA) also launched an investigation in October 2025 into undisclosed Cash-on-Delivery fees such as platform charges, handling fees and “offer” or “promise” surcharges. These appear only at checkout and fall under the drip pricing dark pattern identified by the CCPA.
However, enforcement remains limited. For context, the dark patterns guidelines define prohibited patterns but do not impose automatic penalties because Clause 8 linking violations to the Consumer Protection Act was removed from the final notification.
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As a result, compliance depends largely on voluntary action by platforms, supported only by occasional fines for unrelated misleading conduct, such as the penalties on Rapido and Drishti IAS.
Additionally, the CCPA’s refusal to release the audit reports creates an information gap at the very moment the government expects platforms to increase transparency. This combination of opaque reporting and weak enforcement reduces the effectiveness of the regulatory framework.
Why It Matters
The present RTI highlights a structural weakness in India’s dark patterns oversight. Without access to self-audit reports, users and regulators have no way to assess whether platforms have made meaningful changes to their interfaces.
Furthermore, LocalCircles’ findings show that dark patterns remain deeply entrenched across India’s digital ecosystem. And ongoing investigations into hidden fees indicate that consumers continue to face some of the very practices that the government’s guidelines sought to curb.
Additionally, the credibility of self-audits depends on public disclosure: if companies file declarations but do not publish their results, the process risks becoming a compliance formality rather than a tool for user protection.
Therefore, unless platforms publish their self-audit reports and regulators introduce clear consequences for non-compliance, dark patterns will continue to shape how millions of Indians shop, consent and share data online.
Note: MediaNama will be contacting key platforms listed in the RTI to request copies of their self-audit reports, in line with CCPA’s directive that companies must publish these findings.
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