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The Central Consumer Protection Authority (CCPA), headed by Chief Commissioner Smt. Nidhi Khare and Commissioner Shri Anupam Mishra, has taken decisive enforcement action against two prominent digital companies PhysicsWallah Limited and McAfee Software India Private Limited for employing manipulative interface designs on their platforms. The penalties have been issued under the Consumer Protection Act, 2019, the Consumer Protection (E-Commerce) Rules, 2020, and the Guidelines for Prevention and Regulation of Dark Patterns, 2023, marking a significant step in India’s effort to establish a fair and transparent digital marketplace.
What Are Dark Patterns?
Dark patterns are deliberate user interface design techniques that manipulate consumers into taking actions they would not otherwise choose — such as unintended purchases, involuntary data sharing, or coerced subscription renewals. The CCPA formally notified the Guidelines for Prevention and Regulation of Dark Patterns on 30 November 2023, following extensive stakeholder consultations, identifying 13 such practices as unfair trade and providing a regulatory framework for enforcement.
The PhysicsWallah Case
CCPA initiated suo motu proceedings against the edtech platform after identifying three distinct violations. During the checkout process, a ₹10 donation to the PW Foundation was automatically included in the payable amount without the consumer’s explicit consent — a practice classified as basket sneaking. Users were simultaneously shown emotionally charged messaging related to children’s education, healthcare, and marriages, designed to discourage removal of the donation, constituting confirm shaming.
Additionally, courses promoted as “free” on the platform required users to mandatorily submit their mobile number and email address before gaining access. The CCPA found that course content remained identical across user accounts, indicating that data collection served no functional necessity — amounting to forced action. Given that a substantial portion of PhysicsWallah’s user base comprises students, including minors, the authority flagged heightened consumer protection concerns. PhysicsWallah was accordingly fined ₹5,00,000.
The McAfee Case
McAfee’s subscription renewal interface presented users with only two choices “Renew Now” and “Accept Risk” with no neutral alternative available. The framing effectively portrayed non renewal as a reckless decision that would expose users to cybersecurity threats, a claim the company could neither substantiate nor guarantee. The renewal option was also given greater visual prominence, further steering consumers toward continued subscriptions. CCPA identified four violations: confirm shaming, interface interference, trick question, and forced action. McAfee was fined ₹1,00,000.
Broader Implications
These enforcement actions follow an advisory issued by CCPA on 5 June 2025, directing e-commerce platforms and digital interfaces to conduct self-audits and proactively remove dark patterns. The fact that penalties were still necessary a year later underscores the importance of sustained regulatory vigilance.
While the financial penalties may appear modest relative to the scale of the companies involved, the orders carry significant compliance and reputational weight. They establish clear precedent that consumer consent must always be explicit, informed, and entirely free from manipulative design — a standard that every digital platform operating in India is now expected to meet.
As digital commerce continues to expand, the CCPA’s proactive stance signals that regulators are increasingly equipped and willing to hold platforms accountable for the choices their interfaces make on behalf of consumers.
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