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…
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