LocalCircles finds Drip Pricing on 11 of the 26 platforms that have submitted “Dark Pattern Free” self-declaration to CCPA

November 26, 2025, New Delhi: India finds itself at a critical juncture in the fight against dark patterns, which are deceptive design tactics that steer users into unintended or disadvantageous decisions to implement. Out of 26 platforms that have submitted self-declarations to the Central Consumer Protection Authority’s (CCPA) about being Dark Pattern free, LocalCircles’ audit following consumers complaints has found that 21 of the 26 still have dark patterns as of today. The most talked about Dark Pattern called Drip Pricing or Hidden Charge alone was found on 11 of these 26 platforms submitting “dark pattern free” self-declarations to the Government. Other dark patterns still prevalent on platforms include Forced Action, Subscription Trap, Bait & Switch, Basket Sneaking, Interface Interference, etc.

In November 2023, the CCPA formally notified “Guidelines for Prevention and Regulation of Dark Patterns”, defining 13 specific types of manipulative design, such as false urgency, basket sneaking, subscription traps, and confirm shaming. Under these guidelines, use of such patterns may amount to unfair trade practices under the Consumer Protection Act. Seeing no or limited compliance by mid-2025, the CCPA had asked e-commerce platforms to carry out self-audits within three months to root out deceptive patterns. A Joint Working Group was set up to review compliance, promote consumer awareness, and monitor progress.

Last week, the CCPA announced that since September this year, 26 major e-commerce companies have submitted self-declarations affirming their compliance, claiming they had either conducted internal audits or engaged third-party evaluators to ensure their interfaces are “dark-pattern free.” The CCPA publicly welcomed this step, urging other platforms to follow suit and stated that momentum was building on platforms getting rid of dark patterns. However, multiple large-scale audits and consumer surveys by LocalCircles bring to light a far more troubling picture. 97% of the over 300 most used online platforms in India still have dark patterns. Forced Action (75%) leads among dark patterns as the most used manipulative practice where an action is forced upon the consumer against their wishes and consent. For example: Many consumers were made to purchase a Priority Pass by an eCommerce platform to get higher discounts on their phone purchases only to find that post the sale was concluded their order was cancelled by the platform. The priority pass charges were never reversed, said most consumers reporting this dark pattern The second dark pattern most common in India is Drip Pricing (66%) used by most platforms who without intimation levy a fee like convenience fee, platform fee, handling fee, rain fee, packaging fee on the last step of the transaction. Drip Pricing is one dark pattern which some platforms in India have recently removed, giving some respite to users. However, the bigger challenge is lack of understanding of the platforms on what constitutes drip pricing. As a result 11 of the 26 platforms despite giving a “dark pattern free” self-declaration to the Government still have Drip Pricing. These are Flipkart, Myntra, Cleartrip, MakeMyTrip, BigBasket, Axelia, ,Netmeds, TATA 1mg, Zomato, Blinkit, and Ixigo.

LocalCircles has compiled a fresh comprehensive report of dark patterns on various online platforms based on consumer feedback and AI powered platform research. With inputs from over 250,000 consumers located across 392 districts of India for over 300 different online platforms, LocalCircles has completed India’s most comprehensive aggregate sectoral audit on dark patterns and detailed audit of the platforms. Below are some key findings as of November 2025:

Sector wise Breakdown of Dark Pattern Prevalence in India

Analysis of over 300 platforms has found that 7 or more dark patterns are found on Digital Lending, Edtech, Online Banking, eCommerce, OTT, App Taxis, eCommerce, Inventory, Food Delivery, Quick Commerce, Apps and Software, Medicine and Health Services, Travel, Airlines, Movies/ Event Ticketing, Online Payments, Home/ Other Services, Online Gaming, Real Estate, Online Insurance, Foreign Currency, Broadband, Recruitment/ Professional Networking and Information Services. Next is the category with 4-6 dark patterns being reported. These include Train Ticketing, Mobile Telecom, Voice Assistants, Dining Services, Governance Services, Home Health Services, Others, Electric Scooter, Online Financial Trading, Car Resale, Pathology & Diagnostics, Cryptocurrency, Dating & Matrimonial, Digital Gold and Online Jewellery. The third category of those with 1-3 dark patterns being reported include Car Rental, Hotels/Homestays, Music Streaming and Mobile Devices.

Forced Action and Drip Pricing dark patterns used by over 60% platforms

Based on analysis of over 300 online platforms in India, it was found that among most used dark patterns, Forced Action tops the list with 239 or 75% of platforms studied using it; 210 platforms or 66% have been found to use Drip Pricing; 172 platforms or 54% have been found to use Interface Interference; 164 platforms or 52% have been found to use Bait and Switch; 117 platforms or 37% have been found to use Nagging, 108 platforms or 34% have been found to use Subscription Trap. 71 platforms or 22% have been found to use Privacy Zuckering. In the next category, 50 platforms or 16% have been found to use Confirm Shaming tactics; 48 platforms or 15% have been found to use Basket Sneaking; 35 platforms or 11% have been found to use False Urgency dark pattern. In the third category 24 platforms or 8% have been found to use SaaS Billing; 18 platforms or 6% have been found to use Disguised Ads to lure unsuspecting customers, while 1 platform or 0.42% has been found to use Trick Question method of dark pattern.

Sectors and platforms audited by LocalCircles for Dark Patterns

Based on consumers inputs, below are the 30+ sectors and 300+ platforms that LocalCircles has done audits on:

• Mobile Telecom Services:Airtel, Vodafone Idea (VI), Jio
• Digital Lending:Bajaj Finserv, PhonePe, Navi Finserv, KreditBee, CASHe, Truebalance, Dhani, Stashfin, Lazypay, Buddy Loan, Loanfront, Smartcoin, Finnable, MoneyTap, Kissht, Indialends, L&T Finance, Jio Finance, Flipkart , Paytm, Hero Fincorp, Paisabazaar, MobiCred, Aditya Birla PF, PaySense, IndusInd Bank, Tata Capital, Moneyview, mPokket, Fibe, Home Credit, KredX, Freo, DMI Finance, LendingKart, KapitalTech, CapitalFloat, Indifi, Flexiloans
• Recruitment & Professional Networking Platforms: Naukri, LinkedIn
• IRCTC Platform: IRCTC
• Online Financial Trading Platforms: Zerodha, Groww, Upstox, ICICI Direct, HDFC Securities, IIFL, Paytm Money, AngelOne
• Car Rental Platforms: Zoomcar, Revv, MyChoize, Savaari, Avis, Redbus, Ecorentacar, Mylescars
• Electric Scooters Platforms: Okinawa Autotech, Hero Electric Vehicles, Ola Electric Technologies, Ampere Vehicles, Pur Energy (PURE), TVS Motor
• OTT Platforms: Netflix, JioHotstar, Prime Video, Apple TV+, Sony LIV, Youtube, Zee5, Voot, MX Player, ALT Balaji, Eros Now, Ullu
• Edtech Platforms: BYJU's, Unacademy, Vedantu, Physicswallah, Simplilearn, Udemy, Cuemath
• Voice Assistants Platforms: Amazon Alexa, Google Assistant, Apple Siri, Samsung Bixby
• Online Banking Platforms: ICICI Bank, HDFC Bank, AXIS Bank, SBI, Vijaya Bank, Kotak Mahindra Bank, Standard Chartered Bank, HSBC Bank, Punjab National Bank, Bank of Baroda, IndusInd Bank, IDFC First Bank, Bank of India, Yes Bank, Central Bank of India, Paytm Payments Bank
• Taxi Aggregator Platforms: Uber, Ola, InDrive, Rapido, Namma Yatri
• eCommerce Inventory Platforms: H & M, Adidas, Urbanic, UNIQLO, Marks & Spencer, IKEA, Decathlon, Jockey India, William Penn, Curaden India, Duroflex, Tira Beauty, Reliance Digital, Hamleys India, Shoppers Stop, Ferns & Petals (FNP), Firstcry, Pepperfry, AJIO, Lenskart, Nykaa
• Medicine Supply & Health Services Platforms: Pharmeasy, Tata 1MG, Zepto Pharmacy, Amazon Pharmacy, Medibuddy, Practo, Netmeds, Apollo Health
• Travel Booking Platforms: EaseMyTrip, Booking.com, Skyscanner, Paytm Travel, Google Flights, MakeMyTrip, Cleartrip, Yatra, Goibibo, Ixigo
• Airlines Platforms: Air India, Akasa Air, Spicejet, Indigo
• Music Streaming Platforms: Spotify, Amazon Prime Music, Youtube Music, Apple Music, Gaana, WYNK, Jiosaavn
• Food Delivery Platforms: Swiggy, Zomato, Magicpin, Dominos, Pizza Hut, Swish, EatSure
• Online Gaming Platforms: Dream11, Games24X7, MPL, Gameskraft, Zupee, Winzo, RummyCircle, Junglee Games
• Quick Commerce & Grocery Platforms: Blinkit, Swiggy Instamart, Big Basket, Zepto, Amazon Fresh, Milk Basket, Country Delight, JioMart, Flipkart Minutes, Amazon Now, Dmart
• eCommerce Platforms: Amazon, Flipkart, Tata Neu, Myntra, JioMart, Meesho
• Apps & Software Platforms: Apple Store, Play Store, Microsoft Office, Adobe, McAfee, iCloud, Google One
• Movie & Event Ticketing Platforms: PVR Cinemas, BookMyShow, District
• Online Payment: Paytm, PhonePe, Google Pay, Amazon Pay, Super Money, WhatsApp Pay, Razorpay, CRED
• Insurance Services Platforms: Star Health, Go Digit, Turtlemint, Coverfox, InsuranceDekho, RenewBuy, Toffee, Universal Sompo, Policy Bazaar, ACKO, ICICI Lombard, TATA AIG, Bajaj Allianz, HDFC Ergo, Royal Sundaram, Niva Bupa
• Mobile Devices Platforms: Apple, Samsung, Xiaomi, OnePlus, Realme, Oppo, Vivo
• Real Estate Platforms: Magicbricks, NoBrokers, 99acres, Square Yards, Housing.com, Makaan.com, Proptiger.com
• Dating and Matrimonial Platforms: Shaadi.com, Bharat Matrimony, Jeevansathi, Tinder, Bumble, OkCupid, Truelymadly
• Hotels/Homestays Platforms: OYO Rooms, Airbnb, Taj Hotels, ITC Hotels, Marriott Hotels, Accor Hotels India, The Leela, Lemon Tree Hotels
• Car Resale Platforms: Cars24, Droom, Spinny
• Other Platforms: Cashify
• Home and Other Services Platforms: Yes Madam, Urban Company, Cult.fit
• Broadband Platforms: Airtel Xstream Fiber, Jio Fiber, Tata Play Fiber, Excitel Broadband, ACT
• Information Service Platforms: Trucaller, Justdial, Facebook, Instagram, Astrotalk
• Home Health Services Platforms: Apollo HealthCo Ltd, Portea Medical
• Governance Services: DigiYatra
• Pathology and Diagnostics: Thyrocare, Dr Lal PathLabs, Metropolis, Tata 1mg, SRL Diagnostics, Redcliffe Labs, Practo
• Foreign Currency Platforms: BookMyForex, Niyo Global, Wise, Revolut, Thomas Cook Forex, Western Union, Instarem, Remitly
• Cryptocurrency Platforms: WazirX, CoinDCX, ZebPay, Giottus, Bitbns, Unocoin, BuyUCoin, KoinBX
• Online Jewellery Platforms: CaratLane, BlueStone, Melorra, GIVA, Voylla, Reliance Jewels, Tanishq
• Digital Gold Platforms: SafeGold, DigiGold, MMTC-PAMP Digital Gold, Augmont Digital Gold, eBullion, Fiydaa, Jupiter Digital Gold, Aditya Birla Capital Digital Gold
• Dining Services Platforms: EasyDiner, Swiggy Dineout, District

To summarise, they survey and audits by LocalCircles make it evident that many companies are giving dark pattern free declarations to the CCPA without undertaking comprehensive review, corrective actions and user testing. As a result, LocalCircles found that 21 of the 26 companies that submitted a “dark pattern free” self-declaration still have dark patterns. One of the most talked about dark pattern, “Drip Pricing” is still found on 11 of these 26 platforms. The need of the hour here is for the CCPA to define a standardized template for dark pattern self-declaration followed by a check and balance exercise to ensure that the platform is indeed dark pattern free, atleast at that time of self-declaration submission. In absence of such a mechanism and press releases issued by the companies giving self-declarations and those by the CCPA, there is the risk of the consumer believing that these platforms are dark pattern free, only to find later that they aren’t. That would lead to a breach of trust for the consumer, both with the platform and the regulator and such credibility is hard to rebuild.