MediaNama’s Take:

The Central Consumer Protection Authority (CCPA) releasing 18 dark pattern self-audit declarations marks the first time the public can see how some of India’s largest online platforms actually comply with the 2023 Dark Patterns Guidelines.

However, the disclosures show a fragmented compliance landscape. Some companies describe structured audits, training programmes and external reviews. Meanwhile, others have submitted brief one-page assurances that offer almost no visibility into what they checked, what they found or how they fixed it.

The contrast becomes sharper when placed alongside independent evidence. For context, a LocalCircles audit, conducted between June and September 2025, found that 97% of major online platforms continue to use manipulative design. This includes hidden fees, drip pricing, bait and switch, false urgency, privacy zuckering and forced action. Interestingly, these findings overlap with the exact period during which the same companies conducted self-audits and submitted their declarations.

Furthermore, MediaNama’s recent RTI filing confirmed that 25 platforms filed their declarations, while the CCPA has published only 18. As such, there is no clarity on why seven remain undisclosed. Until the complete set of disclosures is available, the public record is still partial.

Another clear divide appears between platforms that commissioned independent reviews and those that relied only on internal checks. Flipkart, Myntra and Walmart India engaged Deloitte to test their interfaces, websites and policies. While, every other company used internal assessments and provided no information about the methodologies used.

Taken together, these disclosures show some progress but highlight the limits of voluntary compliance. As long as platforms audit themselves and report findings in formats of their choosing, there will be a gap between what companies claim and what users experience. Without enforcement, dark pattern rules will remain principles rather than obligations.

What’s the News

The CCPA has published dark pattern self-audit declarations submitted by 18 e-commerce and quick commerce platforms. The publication follows the CCPA’s June 5 advisory directing platforms to conduct internal reviews under the 2023 Dark Patterns Guidelines.

Notably, this release comes days after MediaNama’s RTI confirmed that 25 companies filed their declarations, making this the first official disclosure at how platforms claim to comply with the rules.

However, these disclosures show large variations in detail and methodology. For context, some companies outline multi-step audit frameworks, training sessions and external validation. While others send minimal statements asserting compliance without describing any substantive process.

What the Declarations Reveal

The declarations reveal clear patterns in how e-commerce and quick commerce companies approached the June advisory….


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Last Update: November 21, 2025