IRDAI proposes ban on dark patterns in insurance websites, seeks greater transparency

The Insurance Regulatory and Development Authority of India (IRDAI) on Wednesday proposed prohibiting “dark patterns” on insurance websites, including practices that require consumers to share personal details before accessing product features and pricing information. 

The proposal is part of IRDAI’s consultation paper, “Recalibrating Economics of Insurance Distribution”, which seeks wider reforms across insurance distribution, expenses, commissions, market conduct and digital infrastructure. The regulator has invited comments from stakeholders until October 25. 

IRDAI wants insurers to disclose prices without personal details 

IRDAI said product, pricing, and quality information should be disclosed by all insurers in a standard and easy-to-understand format without seeking personal details from consumers. 

The regulator noted that requiring customers to provide personal information before allowing them to access product and pricing details is a dark pattern commonly seen on insurer and distributor websites. It also said such practices are contrary to guidelines issued by the Central Consumer Protection Authority (CCPA) under the Consumer Protection Act, 2019. 

The consultation paper also proposes tracking dark patterns and making relevant performance information publicly available. IRDAI has proposed stronger safeguards against mis-selling, including making suitability an enforceable obligation and documenting customer needs and suitability for specified life insurance sales. 

Consumer groups seek action on ‘Privacy Zuckering’ 

The proposal follows sustained calls from consumer advocacy platform LocalCircles for tighter regulation of dark patterns in online insurance. 

On March 18, 2026, LocalCircles wrote to IRDAI Chairman Ajay Seth, citing a survey of more than 87,000 consumers and an audit of over 20 platforms. It sought a framework, similar to measures applicable to banks, to prohibit insurance aggregators and companies from using dark patterns. 

On April 2, IRDAI directed regulated entities to self-assess their compliance with CCPA guidelines on dark patterns and submit action plans. After insurers reported finding no dark patterns, IRDAI engaged the Institute of Public Auditors of India (IPAI) to independently monitor such practices for nine months. 

In July, Seth publicly flagged insurance websites that require consumers to provide their name, mobile number and consent to be contacted before revealing premium prices. 

LocalCircles subsequently wrote to IRDAI and CCPA on July 30 and September 22 seeking the explicit inclusion of “Privacy Zuckering” in India’s list of dark patterns. The term refers to practices in which platforms seek more personal information than necessary and subsequently use it for purposes such as marketing messages, differential pricing or other actions without explicit consumer consent. 

According to a LocalCircles survey of more than 22,000 users of online insurance platforms, 77% said they had frequently experienced Privacy Zuckering, including 59% who said they experienced it “very frequently”. The broader survey also found that 90% of respondents had experienced nagging, 85% forced action, 82% bait-and-switch, 80% subscription traps and 65% drip pricing or hidden charges.