REFERENCEThe 13 dark patterns - mapped to insurance
IRDAI did not write a new framework - it directed regulated entities to comply with the CCPA Guidelines for Prevention and Regulation of Dark Patterns, 2023. Each statutory pattern is mapped below to how it manifests in insurance journeys, why it is a policyholder-protection issue, and the compliant alternative.
DP-01
False Urgency
Annexure 1, Cl. 1
Definition. Falsely stating or implying a sense of urgency or scarcity to mislead a user into making an immediate purchase or taking an immediate action.
In insurance
“Only 2 policies left at this price”, “Offer expires in 04:59”, “95% of customers buy this add-on” - countdowns and scarcity claims that are not objectively true for an underwritten product.
Why IRDAI cares
Pressuring a policyholder into a cover they did not consciously evaluate is a policyholder-protection issue, not a marketing tactic.
Compliant pattern
Remove non-genuine timers/scarcity. Any time-bound offer must reflect a real, dated tariff with the basis disclosed.
DP-02
Basket Sneaking
Annexure 1, Cl. 2
Definition. Adding additional products, services, payments to charity or donation at the time of checkout without the consent of the user, such that the total amount payable is more than the amount payable for the product(s) the user intended to purchase.
In insurance
A Personal Accident cover, telemedicine subscription or wellness package silently appears in the cart of a health buyer; an add-on premium is folded into the payable amount without an explicit opt-in.
Why IRDAI cares
The premium a customer pays must correspond only to covers they actively chose. Sneaked covers are mis-sold covers.
Compliant pattern
Every line item in the payable amount must trace to an explicit, logged opt-in by the customer.
DP-03
Confirm Shaming
Annexure 1, Cl. 3
Definition. Using a phrase, video, audio or any other means to create a sense of fear, shame, ridicule or guilt in the mind of the user, so as to nudge the user into acting in a manner desired by the platform.
In insurance
Decline buttons worded as “No, I don’t care about my family’s health” or “Skip accidental cover and take the risk.”
Why IRDAI cares
Declining an optional cover must be emotionally neutral. Guilt-loading a decline manufactures consent.
Compliant pattern
Use neutral decline copy: “No, continue without this cover.” Equal visual weight to accept / decline.
DP-04
Forced Action
Annexure 1, Cl. 4
Definition. Forcing a user into taking an action that would require the user to buy any additional good(s) or subscribe to an unrelated service, in order to buy or subscribe to the product originally intended.
In insurance
Requiring a wellness-app signup, mandatory rider, or cross-sell acceptance before the base motor/health policy can be issued.
Why IRDAI cares
Bundling an unrelated obligation onto issuance removes free choice over the base contract.
Compliant pattern
Base cover must be purchasable standalone. Riders and ancillary services strictly opt-in.
DP-05
Subscription Trap
Annexure 1, Cl. 5
Definition. Making cancellation of a paid subscription impossible or complex, hiding the cancellation option, or requiring action not intimated at sign-up to cancel.
In insurance
Auto-debit renewal enabled silently; cancellation / free-look exit buried, requires a call-centre, or demands steps never disclosed at purchase.
Why IRDAI cares
Free-look and cancellation rights are statutory. Friction that defeats them is a direct regulatory breach.
Compliant pattern
One-click online cancellation and free-look exit, with terms intimated at point of sale.
DP-06
Interface Interference
Annexure 1, Cl. 6
Definition. A design element that manipulates the user interface to highlight certain information and obscure other relevant information, to misdirect a user from taking a desired action.
In insurance
Pre-ticked riders (Zero Dep, Engine Protect, RSA); a giant “Buy” CTA next to a greyed, low-contrast “View exclusions”; the cheaper standalone option hidden below the fold.
Why IRDAI cares
Pre-selection converts assumed consent into a sale. IRDAI is moving explicitly toward informed, opt-in consent.
Compliant pattern
All optional covers default to unticked. Equal prominence for accept / decline / disclosures.
DP-07
Bait and Switch
Annexure 1, Cl. 7
Definition. Advertising a particular outcome based on the user’s action but deceptively serving an alternate outcome.
In insurance
Advertising a ₹1 crore cover or a headline premium, then issuing a sub-limited / co-pay-laden variant, or routing to a costlier plan at checkout.
Why IRDAI cares
The cover and price quoted must be the cover and price issued.
Compliant pattern
Quoted SI, premium and plan variant must equal the issued contract; any change re-triggers consent.
DP-08
Drip Pricing
Annexure 1, Cl. 8
Definition. Revealing prices in a piecemeal manner - hiding mandatory or elements of price initially and revealing them later in the journey; or hiding that a product is free.
In insurance
Headline “₹8,999” shown prominently; 18% GST (₹1,620) and add-on premiums revealed only on the payment screen - true payable ₹10,619.
Why IRDAI cares
Premium is a regulated disclosure. Showing a tax-exclusive teaser to win the click is exactly the practice flagged.
Compliant pattern
Display the all-inclusive payable (premium + GST + chosen add-ons) from the first quote screen.
DP-09
Disguised Advertisement
Annexure 1, Cl. 9
Definition. Designing an advertisement to masquerade as other types of content such as user-generated content, editorial, or a genuine recommendation.
In insurance
A sponsored insurer ranked #1 on an aggregator’s “Best plans” / “Recommended for you” list with no disclosure that placement is paid.
Why IRDAI cares
Aggregator rankings influence the customer’s choice of insurer; undisclosed paid placement distorts that choice.
Compliant pattern
Clearly label sponsored / paid placements; disclose ranking basis.
DP-10
Nagging
Annexure 1, Cl. 10
Definition. Persistent, repeated and excessive interactions in the form of requests, information, options, or interruptions to a user not material to the intended transaction.
In insurance
Repeated modals pushing an add-on after the customer has declined; persistent “Are you sure?” loops that re-pitch the same rider.
Why IRDAI cares
A logged decline must be respected. Re-pitching wears down an informed refusal.
Compliant pattern
Honour a decline for the session; cap re-prompts; never re-default a declined cover to selected.
DP-11
Trick Question
Annexure 1, Cl. 11
Definition. The use of confusing language, double negatives, or ambiguous phrasing to misdirect a user into taking a certain action.
In insurance
“Untick if you do not wish to not be covered for engine damage” - double negatives around opt-outs and consent checkboxes.
Why IRDAI cares
Consent obtained through confusing phrasing is not informed consent.
Compliant pattern
Plain-language, single-affirmative consent statements, in the customer’s chosen language.
DP-12
SaaS Billing
Annexure 1, Cl. 12
Definition. Generating recurring revenue by exploiting a user’s actions through deceptive interface choices that lead to unwanted recurring payments.
In insurance
Recurring auto-debit / EMI mandate enabled by default on a checkbox the customer didn’t notice, beyond the premium they intended.
Why IRDAI cares
Recurring mandates must be a conscious, separate authorisation - not a default state.
Compliant pattern
Payment frequency and auto-debit are explicit, defaulted off, separately consented.
DP-13
Rogue Malware / Scareware
Annexure 1, Cl. 13
Definition. Using a ransom/scare software or programme, or misleading the user to believe a problem exists, to demand payment for a non-existent or unnecessary product.
In insurance
Fabricated “Your previous policy has lapsed - buy now to avoid a penalty” alerts, or fake risk scores engineered to drive a panic purchase.
Why IRDAI cares
Manufacturing a fake risk state to force a purchase is coercive mis-selling.
Compliant pattern
Risk / lapse statements must be factual and traceable to the customer’s actual policy record.