GuideRule 4(15) · Sample · Updated 5 October 2026
A sample dark-pattern self-audit statement
Rule 4(15) asks every e-commerce entity to self-audit for dark patterns each year and display a certificate saying its platform is free of them. It doesn't say what that certificate should look like. Below is a complete, filled-in specimen for a fictitious company, written in the open format, with notes on what each part is for.
01The specimen
What a complete statement contains
This is the statement exactly as the generator on this site produces it. Example Retail Private Limited is fictitious; the dates are set in December 2026, as a store preparing for 1 January would be.
Notice three things a one-line declaration leaves out:
- Scope. It says which website was examined, which journeys, and what was not examined: here, the mobile app.
- Outcomes for every item. All thirteen patterns and the 2026 duties, each with an outcome, including the one still open.
- A qualified declaration. The signatory states what was found "to the best of my knowledge and belief", within the stated scope, and names the open item instead of hiding it.
This is a specimen for illustration, not legal advice. Your statement should describe your own self-audit; have it reviewed by your counsel before you publish.
Specimen · fictitious company
Dark patterns self-audit statement
Example Retail Private Limited
Published under Rule 4(15) of the Consumer Protection (E-Commerce) Rules, 2020, as amended by the Consumer Protection (E-Commerce) (Amendment) Rules, 2026 (G.S.R. 789(E), 9 September 2026).
- Platform(s)
- https://www.example.in
- CIN / LLPIN
- U52100HR2024PTC000000
- Audit date
- 9 December 2026
- Period covered
- 9 November 2026 to 9 December 2026
- Next audit due
- 31 December 2027
Scope
Public website journeys (before login); Logged-in journeys: account, subscription, renewal, cancellation.
Browse to checkout for 12 products across 4 categories, as a new and a returning visitor; sign-up, renewal and cancellation of the Example Plus membership.
What this self-audit did not examine
- Mobile application
This self-audit examined the scope described above, by the method described above. The absence of a finding is not proof that no dark pattern exists.
Method
Each journey was walked through on desktop and mobile web by the product and legal teams: in a fresh session, after a reload, in a private window and again after 30 minutes. Every step was screenshotted with the date and time, and the screenshots are kept with this statement's working file.
Coverage
| Item | Basis | Outcome |
|---|---|---|
| Specified dark patterns | ||
| False urgency | Dark Patterns Guidelines 2023, Annexure 1, item 1 | Issue identified and remediated |
| Basket sneaking | Dark Patterns Guidelines 2023, Annexure 1, item 2 | No issue identified |
| Confirm shaming | Dark Patterns Guidelines 2023, Annexure 1, item 3 | No issue identified |
| Forced action | Dark Patterns Guidelines 2023, Annexure 1, item 4 | No issue identified |
| Subscription trap | Dark Patterns Guidelines 2023, Annexure 1, item 5 | No issue identified |
| Interface interference | Dark Patterns Guidelines 2023, Annexure 1, item 6 | No issue identified |
| Bait and switch | Dark Patterns Guidelines 2023, Annexure 1, item 7 | No issue identified |
| Drip pricing | Dark Patterns Guidelines 2023, Annexure 1, item 8 | Issue open |
| Disguised advertisement | Dark Patterns Guidelines 2023, Annexure 1, item 9 | No issue identified |
| Nagging | Dark Patterns Guidelines 2023, Annexure 1, item 10 | No issue identified |
| Trick question | Dark Patterns Guidelines 2023, Annexure 1, item 11 | No issue identified |
| SaaS billing | Dark Patterns Guidelines 2023, Annexure 1, item 12 | No issue identified |
| Rogue malware | Dark Patterns Guidelines 2023, Annexure 1, item 13 | No issue identified |
| Other duties under the Rules | ||
| Legal name, addresses, website and contact details for customer care and the grievance officer | Rule 4(2) | No issue identified |
| Grievance acknowledged within 48 hours, copy of complaint supplied, redressal within one month | Rule 4(5) | No issue identified |
| Importer details and full name of country of origin for imported goods | Rule 4(6) | Not applicable |
| Partner in the National Consumer Helpline convergence process | Rule 4(7) | No issue identified |
| Consent to purchase recorded only by explicit, affirmative action — no pre-ticked boxes | Rule 4(9) | Issue identified and remediated |
| No misleading users by manipulating search results or indexes | Rule 4(11)(c) | No issue identified |
| Sponsored listings distinctly identified with clear and prominent disclosure | Rule 4(12) | Not applicable |
| Announced price reductions show the prior price — the lowest price in the preceding 30 days | Rule 4(13) | No issue identified |
| Seller's name shown in the invoice in the same font size as the entity's name | Rule 4(14) | No issue identified |
| Main ranking parameters explained in descending order of significance, in plain language | Rule 5(3)(f) | Not applicable |
| Collected information not used for associated or own-brand sellers without express consent | Rule 5(6) | Not applicable |
| No bundled fees for services unrelated to the platform | Rule 5(7) | Not applicable |
| Seller's GSTIN or MSME registration number displayed | Rule 6(5)(j) | Not applicable |
| Return, refund, warranty, delivery, payment and grievance information | Rule 7(1)(a) | No issue identified |
Open items
1 open · 2 remediated before publication · Owner: Head of E-commerce · Target: 31 January 2027
A ₹49 handling fee is shown only at the payment step. It will be shown on the product page before add-to-cart.
Declaration
I, A. N. Other, Director, on behalf of Example Retail Private Limited, state that a self-audit of the platform(s) named in this statement was conducted as described in it, and that to the best of my knowledge and belief the platform(s), within the scope described above, are free from the dark patterns specified in the Guidelines for Prevention and Regulation of Dark Patterns, 2023, save for the open item listed in this statement, which is being remediated.
A. N. Other, Director · 15 December 2026
02Part by part
Why each section is there
| Section | What it says | Why it matters |
|---|---|---|
| Entity and platforms | Legal name, CIN, address, and every website and app the statement covers. | A reader can tell exactly whose statement it is and what it covers. An app you didn't examine shouldn't be silently included. |
| Dates | Audit date, the period examined, and when the next audit is due. | The rule asks for a yearly self-audit. A visible next-due date shows you know that. |
| Scope and exclusions | The journeys examined, and what wasn't examined, with the same prominence. | Most published declarations omit this. It is the difference between a claim and a record. |
| Method | How the journeys were checked: sessions, reloads, waiting periods, devices, and how evidence was kept. | Many dark patterns only show across steps and time. Saying you checked across them is what makes the result meaningful. |
| Coverage | An outcome for each of the thirteen patterns and each duty: no issue identified, remediated, open, not applicable or not examined. | No "pass" or "fail": outcomes record what was found. "Not examined" is allowed, but it narrows the declaration. |
| Open items | How many, who owns them, and the target date. | An honest open item with an owner is far stronger than a claim of perfection that a customer can disprove. |
| Declaration and signatory | A named person's qualified statement, on behalf of the entity. | The rule makes the entity certify itself. Nobody else certifies it for you. |
03Publishing it
Where to put the statement
The rule says the certificate must be displayed prominently, and doesn't define the word. A sensible reading: a page of its own, linked from the footer of every page, and from your policies and help pages.
The generator gives you the statement as HTML for your site and as JSON. The JSON makes it machine-readable, so tools, including our free store check, can find it and read its dates.
Before you publish
- Run the self-audit for real: the checklist lists every item, with its rule.
- Keep dated screenshots of every step you checked.
- Fix what you can; list what's open, with an owner and a date.
- Have counsel review the wording, then publish and link it.