Boardrooms Beware: India's Evolving Digital Governance Framework

In June of 2025, the Central Consumer Protection Authority of India (CCPA) issued an advisory to e-commerce companies and industry associations to conduct self-audits and identify dark patterns within 3 months, from the date of the advisory. Based on the voluntary audit reports, e-commerce platforms were encouraged to self-declare and enable fair digital ecosystems for consumers.

Thirteen dark patterns were identified by the CCPA in its 2023 guidelines, including false urgency, forced actions, subscription traps, interface interference, nagging, trick questions etc. While the guidelines per se have no teeth, they represent India's walk into the realm of digital governance, which among others includes the Digital Personal Data Protection Act, 2023 with its accompanying rules, the Competition Act, 2002 and the Draft Digital Competition Bill (DCB), the Consumer Protection (E-Commerce) Rules, 2020, the 2023 dark patterns guidelines, and the upcoming Digital India Act.