Among the companies screened for dark patterns, the only five listed companies with consumer-facing online transaction platforms have been found to have removed dark patterns
Around 95 per cent of publicly listed companies in India with consumer-facing online platforms are using dark patterns, a study revealed. Community platform LocalCircles has reiterated the need for the Securities and Exchange Board of India (Sebi) to implement a ‘dark pattern-free’ self-declaration for all listed companies and those planning to list.
“LocalCircles study based on consumers’ complaints has revealed that 95 per cent of publicly listed companies with online transactions taking place with consumers are riddled with various dark patterns. In effect, out of every 100 companies with online transactions with consumers, 95 have been found to use dark patterns,” the report pointed out.
Among the companies screened for dark patterns, the only five listed companies with consumer-facing online transaction platforms have been found to have removed dark patterns, including Meesho, Jockey (Page Industries), Hamleys (Division of Reliance Retail), ECOS (India) Mobility and Hospitality and Easy Trip Planners.
Beyond the publicly listed companies with online platforms, LocalCircles’ analysis revealed that only 7 companies out of 23, which claimed themselves to be dark pattern free and submitted a self-declaration to the consumer regulator CCPA, were actually free of the deceptive manipulative practices.
Sebi’s Common Advertisement Code
The report added that Sebi’s proposed Common Advertisement Code (CAC) is a step towards curbing deceptive practices or dark patterns in financial advertising. Released as a consultation paper, the CAC or draft code prohibits the use of dark patterns, which are the deceptive user interface designs that manipulate users into making decisions they might not otherwise make.
By incorporating the Central Consumer Protection Authority’s (CCPA) guidelines for Prevention and Regulation of Dark Patterns, 2023, Sebi seeks to ensure that advertisements and investor communications are transparent and free from manipulative design.
“While the proposed CAC covers financial advertising, the use of dark patterns in a company’s core business operations is a much more critical element and should have consequences under securities regulation. A company could fully comply with Sebi’s advertising requirements while continuing to rely on manipulative digital practices in its consumer-facing products or services,” the report noted.
The report highlighted that Sebi needs to ensure that all listed companies and those planning to list in India do not use dark patterns in their digital consumer journey and transactions. In response to Sebi’s inputs for dark pattern governance, LocalCircles shared a dark pattern free self-declaration framework in March 2026 which all listed companies and those wanting to list must submit to the regulator.
