Travel Aggregators Find Zero Dark Patterns in Audits

Cleartrip engaged Deloitte as an independent auditor to check for potential and unintended dark patterns across its platform, the company explained in a self-audit declaration it submitted to the Central Consumer Protection Authority (CCPA). This comes after the CCPA issued an advisory in June this year, directing a range of digital platforms to conduct internal audits to detect dark patterns within three months. Deloitte’s review, which Cleartrip undertook to ensure compliance with the advisory, covered the user interface and user experience (UI/UX) for the company’s websites and mobile apps. It also looked into consumer-facing policies such as terms and conditions, cancellation policy, refund policy and related documents.

“All potential and unintended dark patterns that were identified by Deloitte were thoroughly remediated by our internal teams to ensure compliance with the CCPA Guidelines on Dark Patterns, 2023,” Cleartrip mentioned. Besides Cleartrip, other online travel aggregators (OTAs), namely, Ixigo and MakeMyTrip, have also submitted their declarations. Both companies emphasise that there are no dark patterns on their platforms. 

Highlights from the self-audit declarations of Cleartrip:

Cleartrip explained that the Flipkart Group developed and circulated Dark Patterns Guidelines to UI/UX, category and product teams across all business-to-consumer (B2C) platforms to ensure all relevant teams are aware of examples of dark patterns. These guidelines are also applicable to Cleartrip. The company also organised workshops and internal sessions on reading and understanding the guidelines with UI/UX, category and product teams. Cleartrip also said that it sent out regular communication about the guidelines to the teams. Further, the company mentioned that its UI/UX, category and product teams conducted integrated product design reviews (for unintended dark pattern identification/elimination) before any feature launch and also continuously monitor the platform for unintended dark patterns. 

Meanwhile, MakeMyTrip mentioned that based on its self-audit, “no good or service is offered for purchase on the website or application of MakeMyTrip without the explicit, clear and affirmative consent of the customer.” It also added that there are no pre-ticked boxes that induce unwilling purchases on MakeMyTrip’s website or app. Ixigo, on the other hand, shared no details about its self-audit efforts, only confirming the absence of dark patterns and affirming its compliance with applicable laws, guidance or directions. 

Concerns about dark patterns in OTAs:

As per a LocalCircle’s survey from September 2025, the travel and airline sectors have seven or more dark patterns based on inputs from over 250,000 customers from across 392 districts. Similarly, the product design firm Parallel and the Advertising Standards Council of India’s (ASCI) study on dark patterns from August last year, the travel booking industry had nine out of 12 deceptive patterns. The companies that ASCI and Parallel studied under the travel booking industry category included Cleartrip and MakeMyTrip, as well as others like Agoda, Goibibo and Yatra. 

ASCI and Parallel found that 100% of the travel booking businesses studied had instances of confirm shaming. This is a practice where businesses use fear, shame, or guilt to pressure customers into buying something. For instance, if you are booking a trip, a travel booking company may ask you to click on a phrase like “I will stay unsecured” if you opt out of purchasing travel insurance.

Besides the two studies, users on Reddit have also claimed that travel booking companies in India are engaged in deceptive practices. A user booking a flight from Goa to Chandigarh reported a difference between the initial price MakeMyTrip showed them and the price on the final page. They said that the final price was Rs 700-1000 more than the initial price. Some users have complained about misleading travel guarantees on Ixigo.

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Questions:

MediaNama sent the following questions to the online travel aggregators:

For Cleartrip:

• What specific dark patterns did Deloitte identify before remediation, and what changes did you implement to address them?
• When was the Deloitte audit conducted, and how do you ensure ongoing compliance after the audit period ended?
• Why did you engage an external auditor while most other platforms conducted self-audits? What advantages did this provide?
• What criteria did Deloitte use to distinguish between “intentional” and “unintended” dark patterns?

For MakeMyTrip and Ixigo:

•  Who conducted the audit – internal or external parties? When did you conduct it?
• What specific steps did you take to identify and assess potential dark patterns on your platform? 
• (To Ixigo) Users have complained about misleading travel guarantees on your platform. What are these guarantees, and how do you ensure that you clearly communicate them without deceptive elements? 
• (To MakeMyTrip) Reddit users report significant price increases (Rs 700-1000) between initial search results and final booking pages. How is this not “drip pricing” as defined by CCPA guidelines?

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