Mitigating dark patterns to drive the growth of digital insurance in India

India’s digital economy is expanding rapidly. This is creating disproportionate growth opportunities while also uncovering newer risks for businesses. According to a November 2025 report by the India Brand Equity Foundation, India’s e-commerce market, valued at $125 billion in FY24, is expected to nearly triple to$345 billion by FY30, at a 15% CAGR. 

As Indian consumers increasingly turn to digital channels, insurance has emerged as a key beneficiary. However, with low insurance penetration (around 4%) and declining trust in institutions as a structural risk driver, strong regulatory scrutiny is imperative to strengthening customers’ confidence in digital journeys. This transparency remains critical to achieving “Insurance for All by 2047” and enabling trust-led growth. 

Dark patterns in India: A growing regulatory concern preying on consumer vulnerabilities 

Dark patterns have emerged as a key area of regulatory scrutiny in India’s insurance sector, particularly as insurers accelerate digital distribution through websites, apps, and aggregator platforms. Across the policy lifecycle, from buying and choosing add-ons to renewals and claims, regulators are paying closer attention to designs that may hide important terms, play down exclusions or push customers towards choices they might not make if everything were clearly explained. 

This development signifies a wider transformation in policy perspectives: dark patterns are now regarded as evidence of corporate behaviour, market integrity, and the advancement of consumer protection standards. 

Consumer complaints and regulatory reviews consistently reveal critical vulnerabilities across the policy lifecycle, such as ambiguous pricing disclosures, convoluted cancellation, refund, or surrender processes, default opt-ins for additional riders or services, manufactured urgency, and navigation hurdles that obstruct access to essential servicing and claims support. 

To mitigate this, the Central Consumer Protection Authority of India (CCPA) issued its 2023 guidelines, establishing a formal taxonomy of interface practices considered misleading or deceptive. The framework outlines 13 categories of dark patterns, namely: false urgency, basket sneaking, confirm shaming, forced action, subscription traps, interface interference, bait-and-switch, drip pricing, nagging, disguised advertisements, trick questions, SaaS billing, and rogue malware. 

Regulation trajectory to mitigate dark patterns 

The CCPA’s recent initiatives indicate a marked shift towards rigorous examination of digital interfaces that may distort consumer choice, including non-transparent pricing mechanisms, misleading representations, and design elements that impede informed decision-making. While earlier enforcement was largely focussed on e-commerce and digital marketplaces, the scope has now expanded to include insurance distribution platforms, where consumer decisions involve long-term financial commitments and high trust. 

This evolving enforcement approach underscores clear regulatory expectations: digital platforms must ensure transparency, accuracy, and fairness throughout consumer interactions, regardless of industry or business model. 

The CCPA has intensified its oversight of digital marketplaces by initiating enforcement actions against platforms that employ misleading design practices, opaque pricing structures, deceptive advertising, or fail to comply with mandatory product standards. Recent measures demonstrate that regulatory focus now addresses broader consumer protection issues, setting clear expectations for digital platforms to maintain robust transparency, accuracy, and legal compliance across their interfaces and offerings. 

Taking a cue from the CCPA, the Insurance Regulatory and Development Authority of India (IRDAI) has asked regulated entities to conduct a self-assessment of their compliance status and submit a report within 15 days. Also, in case of non-compliance, they need to submit an action plan with timelines for removing dark patterns within a month. 

Designing an ethical platform strategy 

Both globally and within India, mature digital organisations are systematically embedding dark patterns compliance into their broader trust and safety, product governance, and consumer-protection frameworks. 

To reinforce transparency and ethical operations, leading platforms are increasingly engaging independent experts to assist with self-assessment and to conduct comprehensive reviews of their digital interfaces. 

Also, any organisation is now creating and enforcing robust internal policies to set clear benchmarks for ethical interface design. These guidelines define acceptable design practices, explicitly prohibit deceptive or manipulative elements, and outline actionable measures to reinforce transparency and fairness in every consumer interaction. 

Insurers need to relook at their online fulfilment journeys, identify ‘trust eroding’ touchpoints, redesign them at speed, and test multiple scenarios in a champion-challenger mode. Some of these may also call for more transparent communication strategies, especially when leads are solicited through third-party channels or bundled with a product. 

Sustaining ethical design practices requires ongoing investment in employee capacity. Organisations are therefore providing comprehensive training and sensitisation programmes for teams across product, UI/UX, legal, and compliance functions. 

The way forward 

Impartial evaluations will increasingly help organisations identify and address potential dark patterns, assess regulatory compliance, and promote user experiences free from manipulative design tactics. Raising awareness of the risks of dark patterns, explaining regulatory obligations, and equipping employees to create user journeys that are compliant and consumer-centric need to be woven into the fabric of good governance practices. By fostering a culture of “trust by design,” organisations can embed integrity across all aspects of their digital platforms. 

(The authors are partners at Deloitte India. Views are personal.)