Drip Pricing 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.
Items 5 to 8 of Annexure 1 deal with money and design: making it hard to cancel a subscription, steering users with visual tricks, advertising one outcome and delivering another, and revealing the true price only late in the journey. 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".
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, and items 1 to 4 are in the previous article. This article quotes no penalty.
A subscription trap makes cancellation impossible, complex, hidden or ambiguous, or forces payment details or auto-debit authorisation for a subscription offered at no charge. Interface interference highlights some information and obscures other relevant information to misdirect the user. Bait and switch advertises one outcome and deceptively serves another. Drip pricing reveals price elements late, charges more than shown at checkout, hides that continued use needs payment or blocks a paid-for service unless something more is bought. A marketplace e-commerce entity is not liable for price changes made by third-party sellers or factors beyond its control.
Subscription businesses and marketplaces that want their cancellation and pricing journeys reviewed can ask for compliance advisory support before changing their flows.
Item 5: subscription trap
The definition
"Subscription trap" means the process of:
- making cancellation of a paid subscription impossible or a complex and lengthy process; or
- hiding the cancellation option for a subscription; or
- forcing a user to provide payment details or authorisation for auto debits for availing a subscription offered at no charge; or
- making the instructions related to cancellation of subscription ambiguous, latent, confusing or cumbersome.
The Annexure prints no separate illustrations for this item, and the four limbs are themselves the practices.
A compliant alternative
Make cancellation as simple as sign-up, show where it is, give clear steps and do not demand payment details for a subscription that is offered at no charge. An invented example: a streaming app lets users join in one tap but buries cancellation under several menus and a long form. The cancellation path is "complex and lengthy" and may be a subscription trap.
Item 6: interface interference
The definition
"Interface interference" means a design element that manipulates the user interface in ways that (a) highlights certain specific information and (b) obscures other relevant information relative to the other information, to misdirect a user from taking an action as desired.
The printed illustrations
- (a) designing a light coloured option for selecting "No" in response to a pop-up asking a user if they wish to make a purchase, or concealing the cancellation symbol in tiny font or changing the meaning of key symbols to mean the opposite;
- (b) an "X" icon on the top-right corner of a pop-up screen leading to the opening of another advertisement instead of closing it;
- (c) designing a virtually less prominent option, such as a light coloured option for selecting "No", in response to a pop-up asking if the user wishes to make a purchase (illustration (c) repeats the idea in (a)).
A compliant alternative
Give "Yes" and "No" equal visual weight, keep symbols to their usual meaning, and make a close icon close the window.
Item 7: bait and switch
The definition
"Bait and switch" means "the practice of advertising a particular outcome based on the user's action but deceptively serving an alternate outcome".
The printed illustrations
- (a) a seller offers a quality product at a cheap price but when the consumer is about to pay or buy, states that the product is no longer available and offers a similar looking but more expensive product;
- (b) a product is unavailable but is falsely shown as available to lure the consumer to move it to the shopping cart; once it is in the cart, it is revealed as "out of stock" and a higher-priced product is available instead.
A compliant alternative
Show availability accurately and early. Mark unavailable items as unavailable, and offer alternatives openly as alternatives. The 2022 advertisement guidelines address the same idea for bait advertisements; see the article on guidelines 5 to 7.
Item 8: drip pricing
The definition
"Drip pricing" means a practice whereby:
- elements of prices are not revealed upfront or are revealed surreptitiously within the user experience; or
- the price is revealed post-confirmation of purchase, that is, an amount higher than the amount disclosed at checkout is charged; or
- a product or service is advertised as available at no charge without appropriate disclosure that continued use requires in-app purchase; or
- a user is prevented from availing a service that is already paid for unless something additional is purchased.
The Explanation
"A marketplace e-commerce entity shall not be liable for price fluctuations to the extent attributable to price changes by third party sellers or due to other factors beyond their control." This protects a marketplace for price movements that it did not cause. It does not protect a marketplace from its own undisclosed charges.
The printed illustrations
- (a) a consumer booking a flight sees price X at the checkout page, and when payment is made, price Y (more than X) is charged by the platform;
- (b) a consumer downloads a chess app advertised as available to play at no charge; after 7 days the app asks for payment to continue, and the fact that the no-charge version is available only for a limited time was not disclosed at download;
- (c) a consumer buys a gym membership, but to actually use the gym must buy special shoes or boxing gloves from the gym, which was not displayed when the membership was offered.
A compliant alternative
Show the full price, with all compulsory components, from the first screen. Disclose the time limit or the in-app payment before a user starts something advertised at no charge. Do not charge more at payment than at checkout. For marketplaces, price display is also relevant to the added E-Commerce rule 4(13) from 1 January 2027, explained in the article on rule 4(8) to (11).
The four patterns side by side
| Item | Pattern | Core test | Fix in plain words |
|---|---|---|---|
| 5 | Subscription trap | Is it hard to find or use the cancellation route, or are payment details demanded for a no-charge subscription? | Easy, visible cancellation; no payment details for no-charge access |
| 6 | Interface interference | Does design highlight one option and obscure another to steer the user? | Equal prominence; honest icons |
| 7 | Bait and switch | Does the user get something other than the advertised outcome? | Accurate availability; open alternatives |
| 8 | Drip pricing | Is the price revealed in parts, late or higher than shown? | Full price upfront; disclose limits |
Items 9 to 13 are in the next article.
Need help with pricing display or cancellation journeys?
Hidden costs and hard-to-find cancel buttons are the patterns that most often lead to complaints. Our compliance advisory team can walk through your price display, subscription and cancellation journeys against items 5 to 8 and propose changes.
Key takeaways
- A subscription trap covers impossible, complex, hidden or ambiguous cancellation, and forced payment details for a subscription offered at no charge.
- Interface interference highlights some information and obscures other relevant information to misdirect users.
- Bait and switch advertises one outcome and deceptively serves another.
- Drip pricing covers late or hidden price elements, higher charges than shown at checkout, undisclosed limits on offers at no charge and blocking paid services unless more is bought.
- A marketplace is not liable for price changes made by third-party sellers or caused by factors beyond its control.
- The Annexure's illustrations are guidance only.
Read next
- Annexure 1, items 1–4: false urgency, basket sneaking, confirm shaming and forced action
- Annexure 1, items 9–13: disguised advertisement, nagging, trick question, SaaS billing and rogue malware
- Guidelines 5–7 of the Misleading Advertisements Guidelines, 2022
- 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.