False Urgency explained: this guide covers what it means, who it applies to, the step-by-step process, documents required, fees, due dates and penalties in India — so you can stay compliant with confidence and avoid costly mistakes.
The first four specified dark patterns in Annexure 1 cover pressure and add-ons at the moment of purchase: false urgency, basket sneaking, confirm shaming and forced action. Each has a definition and printed illustrations. The Annexure says the practices and illustrations "provide only guidance and shall not be construed as an interpretation of law or as a binding opinion or decision as different facts or conditions may entail different interpretations".
The guidelines were issued by the Central Consumer Protection Authority (CCPA) on 30 November 2023 under section 18 of the Consumer Protection Act, 2019. This article takes them as amended up to 3 October 2026 (no amendment listed by the CCPA). Later amendments should be checked on the CCPA website. The scope and prohibition are in the article on guidelines 1 to 7. Consequences follow under the Act; this article quotes no penalty.
False urgency falsely states or implies urgency or scarcity to push an immediate purchase. Basket sneaking adds items or payments at checkout without the user's consent so that the total is higher than the chosen product. Confirm shaming uses fear, shame, ridicule or guilt to push a purchase or keep a subscription. Forced action makes a user buy more, sign up for an unrelated service or share personal information to get what they originally wanted. Each has a clean alternative: be accurate, ask for consent, respect a "no" and keep the original purchase separate.
Platforms and sellers who want these four patterns checked in a live journey can ask for compliance advisory support before the next sale season.
Item 1: false urgency
The definition
"False Urgency" means "falsely stating or implying the sense of urgency or scarcity so as to mislead a user into making an immediate purchase or taking an immediate action, which may lead to a purchase", including:
- showing false popularity of a product or service to manipulate user decision; and
- stating that quantities of a particular product or service are more limited than they actually are.
The printed illustrations
- (a) presenting false data on high demand without appropriate context, for instance "Only 2 rooms left! 30 others are looking at this right now".
- (b) falsely creating time-bound pressure to make a purchase, such as describing a sale as an "exclusive" sale for a limited time only for a select group of users.
A compliant alternative
Show real stock and real viewing numbers with context, or do not show them. A counter that reads "2 rooms left at this price on your dates" is acceptable only if it is true. A sale with an end date must really end on that date.
An invented example: a hotel app shows "Only 1 room left" for a property that has twelve rooms available. It is stating that quantities are more limited than they actually are, which is within the definition.
Item 2: basket sneaking
The definition
"Basket sneaking" means "inclusion of additional items such as products, services, payments to charity or donation at the time of checkout from a platform, without the consent of the user, such that the total amount payable by the user is more than the amount payable for the product or service chosen by the user".
The proviso and the Explanation
The proviso says that the addition of samples given at no charge, complimentary services or necessary fees disclosed at the time of purchase "shall not be considered as basket sneaking". The Explanation says "necessary fees" means the fees "necessary to fulfill the completion of the order such as delivery charges, gift wrapping, additional taxes on the product charged by the government or any other charges which are explicitly disclosed to the consumer at the time of purchase".
So a delivery charge shown clearly at checkout is not basket sneaking. A pre-ticked insurance box is.
The printed illustrations
- (a) automatic addition of paid ancillary services with a pre-ticked box or otherwise to the cart when a consumer is purchasing a product or service;
- (b) a user purchases a single salon service, but at checkout a subscription to the salon service is automatically added;
- (c) automatically adding travel insurance while a user purchases a flight ticket.
A compliant alternative
Leave add-ons unticked and let the user opt in. Show necessary fees clearly before payment. The E-Commerce Rules also require explicit and affirmative consent for such features; see the article on rule 4(8) to (11), which includes the sub-rules added from 1 January 2027.
Item 3: confirm shaming
The definition
"Confirm shaming" means "using a phrase, video, audio or any other means to create a sense of fear or shame or ridicule or guilt in the mind of the user so as to nudge the user to act in a certain way that results in the user purchasing a product or service from the platform or continuing a subscription of a service, primarily for the purpose of making commercial gains by subverting consumer choice".
The printed illustrations
- (a) a platform for booking flight tickets using the phrase "I will stay unsecured" when a user does not include insurance in the cart;
- (b) a platform that adds a charity in the basket without the user's consent and uses a phrase such as "charity is for rich, I don't care" when a user opts out of contributing to charity.
A compliant alternative
Use neutral wording for the decline option: "No, thanks" or "Continue without insurance". The test is whether the words create fear, shame, ridicule or guilt to nudge a purchase or the continuation of a subscription. Wording that is plain and neutral does not.
Item 4: forced action
The definition
"Forced action" means "forcing a user into taking an action that would require the user to buy any additional goods or subscribe or sign up for an unrelated service or share personal information in order to buy or subscribe to the product or service originally intended by the user".
The printed illustrations
- (a) prohibiting a user from continuing with the use of a product or service for the consideration originally paid and contracted for, unless they upgrade for a higher rate or fees;
- (b) forcing a user to subscribe to a newsletter in order to purchase a product;
- (c) forcing a user to download an unintended or unrelated separate app to access a service originally advertised on another app, for example a user downloads app X for listing rental houses and is then forced to download app Y for hiring a painter, without which X's services cannot be used;
- (d) forcing a user to share personal information linked with Aadhaar or a credit card, even when such details are not necessary for the intended purchase;
- (e) forcing a user to share details of contacts or social networks to access products or services purchased or intended to be purchased;
- (f) making it difficult for consumers to understand and alter their privacy settings, thereby encouraging them to give more personal information than they mean to while making the intended purchase.
A compliant alternative
Make the original purchase stand alone. Newsletters, additional apps and extra data should be optional and separate. Ask only for the information needed for the intended purchase, and make privacy settings easy to understand and change. For the data protection law on personal data, see the post on DPDP Act for e-commerce companies.
The four patterns side by side
| Item | Pattern | Core test | Fix in plain words |
|---|---|---|---|
| 1 | False urgency | Is the scarcity or popularity message untrue? | Show only true stock, demand and deadlines |
| 2 | Basket sneaking | Was anything added at checkout without consent, raising the total beyond the chosen item? | Opt-in add-ons; disclose necessary fees |
| 3 | Confirm shaming | Does the wording create fear, shame, ridicule or guilt to push a purchase? | Neutral decline wording |
| 4 | Forced action | Must the user buy, subscribe or share data beyond what the original purchase needs? | Keep the original purchase stand-alone |
The next specified patterns are in the article on items 5 to 8.
Need help with checkout design and consent?
A pre-ticked box or a countdown timer can create exposure long before anyone complains. Our compliance advisory team can review your checkout and decline wording against items 1 to 4 and suggest changes that keep conversion honest.
Key takeaways
- False urgency covers false popularity and false limited-quantity claims.
- Basket sneaking is adding items or payments at checkout without consent; necessary fees disclosed at purchase and samples at no charge or complimentary services are excepted.
- Confirm shaming uses fear, shame, ridicule or guilt to nudge a purchase or continued subscription.
- Forced action requires extra purchases, unrelated sign-ups or personal data to get the original product.
- The illustrations are guidance, not an exhaustive list or binding interpretation.
- E-Commerce Rules sub-rule 4(15) will require compliance and a yearly self-audit from 1 January 2027.
Read next
- Guidelines 1–7: definitions, application and prohibition
- Annexure 1, items 5–8: subscription trap, interface interference, bait and switch, drip pricing
- Rule 4(8)–(11) of the E-Commerce Rules: cancellation charges, consent, refunds and price manipulation
- CCPA guidelines on dark patterns 2023: overview
Disclaimer: Based on the rules, regulations and guidelines named above as published in the Gazette of India or on the CCPA website, with the amending notifications the article names (consulted on 3 October 2026). Later amendments, the Consumer Protection Act, 2019 provisions referred to, State rules and CCPA advisories should be checked. This article is general information, not legal advice; check the official text before acting.