The Reserve Bank of India (RBI) has issued draft amendments to its Responsible Business Conduct Directions that would prohibit dark patterns in banking apps and websites, mandate audits and user testing of digital interfaces, tighten consent architecture, expand mis-selling liability, and require banks to assess product suitability before targeted marketing of financial products.
The draft, released on February 11, 2026, applies to commercial banks and is proposed to take effect from July 1, 2026.
The amendments expand regulatory oversight beyond disclosure compliance to the design, targeting, and behavioural architecture of digital financial product distribution.
Dark Patterns Formally Enter Banking Regulation
For the first time in sectoral banking rules, the RBI explicitly defines and prohibits dark patterns.
The draft describes a dark pattern as a “practice or deceptive design pattern using user interface or user experience interactions… designed to mislead or trick users to do something they originally did not intend or want to do, by subverting or impairing the consumer autonomy, decision making or choice.”
Importantly, the definition links such practices to “misleading advertisement or unfair trade practice or violation of consumer rights.” This connects banking regulation directly with consumer protection principles.
The draft also requires adherence to the Central Consumer Protection Authority (CCPA) Guidelines for Prevention and Regulation of Dark Patterns. This alignment signals cross-regulatory convergence between financial supervision and consumer protection enforcement.
The RBI provides an illustrative list of practices that may fall within the dark pattern definition.
Default Add-ons and Basket Sneaking
The draft identifies “basket sneaking” as the inclusion of additional products or services at the time of checkout without clear consent.
In banking flows, this could involve adding loan protection insurance, fraud cover, or other optional services by default during a loan application. Even where such add-ons are disclosed somewhere in the flow, pre-selection or embedding them in the payable amount without affirmative user action may constitute manipulative design.
The regulatory focus is on whether the user actively and deliberately chose the product.
Urgency Messaging and Artificial Scarcity
The draft flags countdown timers and phrases such as “Act Now” or “Offer Ends Soon” as potentially problematic.
Digital banking apps frequently use urgency in pre-approved loan banners or promotional credit offers. The regulator’s concern is that artificial scarcity or time pressure may push users into financial commitments without adequate evaluation.
Where urgency materially influences a financial decision, it may fall under scrutiny.
Subscription Traps and Hidden Cancellation
Subscription traps refer to situations where enrolment is simple but cancellation…
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