Dark Patterns were first officially recognised in 2023 in the “Guidelines for Prevention and Regulation of Dark Patterns” released by the Central Consumer Protection Authority (CCPA). RBI referred to them explicitly in its latest Amendment on “Responsible Business Conduct 2026”. RBI wants the entities regulated by it (Banks/NBFCs/SFBs) to ensure that their consumer interfaces do not employ any dark patterns. And has also mandated periodic user testing and internal audit to ensure the same.

Dark patterns are essentially user interface or user experience (UI/UX) interactions on any platform that are designed to influence the users to do something they originally did not intend or want to do. About eleven dark patterns have been explicitly called out by both the RBI and Central Consumer Protection Authority, I will be covering about seven common ones in this newsletter.

Please note that screenshots used below are from real loan journeys of apps in India. They have been sourced from either app directly or YouTube. The names of providers have been anonymized as the purpose of usage is for illustrative purposes only and not to call out any one provider. These screenshots might not be upto date with the latest screens being offered by these providers.

False Urgency is creating a sense of urgency or scarcity so as to influence the user int taking an immediate action, which may lead to a purchase. Some of the common tactics used here are:

(i) Limited Period Offers: Letting Customers know that charges / fees for certain products/ services will increase after a specific date, thereby, pushing customers to
purchase quickly without comparing with other available options.

(ii) Expiry of Offer: Offering loans at attractive interest rates and luring the customer that the interest rate of the loan is likely to rise if the offer is not availed.
(Illustration Above shows urging completion of loan in next 3 days. Why 3 days one might ask ? What will change on the 4th day? Even the credit bureau updates data only twice a month)

(iii) Countdown timers on the bank's website or app for promotional offers / cash back/ reward points, forcing users to act fast to benefit from the deal.I

(iv) ‘Act Now’, ‘Hurry’, ‘Limited Time Only’, or ‘Offer Ends Soon’ in communications, thereby, inducing a sense of urgency, leading customers to act faster than they might otherwise.2. Basket Sneaking

Forcing the user to purchase additional items such as products / services,
payments to charity or donation at the time of checkout from a platform as a default option is called Basket Sneaking. The user ends up purchasing a product that he/she did not want in the first place.

Refer above illustration, in the default option both the products are checked. Furthermore since there is no different payment for these services and they are to be deducted from the loan amount, it is even more difficult for the user to realise that he/she has opted for an additional product/service.

Contrast the same with the illustration below that is much more transparent and gives the customer an unbiased choice. Notice that the checkboxes are not clicked and offer the customer a clear “opt in” instead of an “opt out”. Also notice the clear way charges have been stated on the same page and are not being surreptitiously deducted.
Please note, if the addition of necessary fees is disclosed at the time of purchase and customer willingly opts for it, then it shall not be considered as basket sneaking.

Confirm Shaming is using language in a way that creates a sense of fear or shame or guilt in the mind of the user so as to nudge the user to act in a certain way. This tactic is often used in Insurance sales- making the customer feel irresponsible if they don’t opt for protection. Refer above illustration, the language for not opting for insurance has been framed as “No, I’ll take the risk” definitely creating the feeling of guilt in the mind of the customer.

Interface Interference is essentially using design elements to take up an option which is desirable for the provider but not necessarily the customer. The user interface highlights certain information while obscuring other relevant information. For example a longer tenure loan has a higher interest outgo for the customer. And is hence a desirable outcome for the loan provider but not so desirable for the customer esp. if they can afford a higher EMI and go for a lower tenure.
Refer above illustration which nudges the customer to opt for a higher tenure while not disclosing that it might actually result in higher interest outgo.

Drip pricing occurs when all price elements are not revealed upfront or are revealed surreptitiously. Often,a product or service is advertised as free without appropriate disclosure of the fact that the continuation of use requires an additional purchase.
In the above illustration, customer has already signed up for a card and been allocated a limit. Post that customer is informed that they need to pay a one time joining fee to be able to use the limit.

Forced Action is forcing a user into taking an action that would require the user to buy an additional product or share personal information in order to buy or subscribe to the product/ service originally intended by the user.
The above illustration shows a blatant example of Forced Action where customer is forced to agree to set of coercive collection practices in order to move ahead in the loan process.

Subscription Trap is makes it very easy for customers to sign up for a product / service (e.g., credit card, insurance product, etc.) in fact sometimes customer might not even know that they are signing for a subscription till the time it hits the bank.
At the same time, the process for cancelling the subscription is made very difficult and cumbersome, and hidden under various menu options.
In the above illustration, customer is signing up for Auto Renewal of Auto Insurance. Please note that in the next year, the quote from the same company might not be the most competitive, as Auto Insurance is a one year product. No claim bonus is also being offered by all companies, so essentially it is a new purchase every year. By signing this, customer is entering into a subscription trap. The way to cancel this is only by cancelling the payment mandate, which is under various sub menus.