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

ItemBasisOutcome
Specified dark patterns
False urgencyDark Patterns Guidelines 2023, Annexure 1, item 1Issue identified and remediated
Basket sneakingDark Patterns Guidelines 2023, Annexure 1, item 2No issue identified
Confirm shamingDark Patterns Guidelines 2023, Annexure 1, item 3No issue identified
Forced actionDark Patterns Guidelines 2023, Annexure 1, item 4No issue identified
Subscription trapDark Patterns Guidelines 2023, Annexure 1, item 5No issue identified
Interface interferenceDark Patterns Guidelines 2023, Annexure 1, item 6No issue identified
Bait and switchDark Patterns Guidelines 2023, Annexure 1, item 7No issue identified
Drip pricingDark Patterns Guidelines 2023, Annexure 1, item 8Issue open
Disguised advertisementDark Patterns Guidelines 2023, Annexure 1, item 9No issue identified
NaggingDark Patterns Guidelines 2023, Annexure 1, item 10No issue identified
Trick questionDark Patterns Guidelines 2023, Annexure 1, item 11No issue identified
SaaS billingDark Patterns Guidelines 2023, Annexure 1, item 12No issue identified
Rogue malwareDark Patterns Guidelines 2023, Annexure 1, item 13No issue identified
Other duties under the Rules
Legal name, addresses, website and contact details for customer care and the grievance officerRule 4(2)No issue identified
Grievance acknowledged within 48 hours, copy of complaint supplied, redressal within one monthRule 4(5)No issue identified
Importer details and full name of country of origin for imported goodsRule 4(6)Not applicable
Partner in the National Consumer Helpline convergence processRule 4(7)No issue identified
Consent to purchase recorded only by explicit, affirmative action — no pre-ticked boxesRule 4(9)Issue identified and remediated
No misleading users by manipulating search results or indexesRule 4(11)(c)No issue identified
Sponsored listings distinctly identified with clear and prominent disclosureRule 4(12)Not applicable
Announced price reductions show the prior price — the lowest price in the preceding 30 daysRule 4(13)No issue identified
Seller's name shown in the invoice in the same font size as the entity's nameRule 4(14)No issue identified
Main ranking parameters explained in descending order of significance, in plain languageRule 5(3)(f)Not applicable
Collected information not used for associated or own-brand sellers without express consentRule 5(6)Not applicable
No bundled fees for services unrelated to the platformRule 5(7)Not applicable
Seller's GSTIN or MSME registration number displayedRule 6(5)(j)Not applicable
Return, refund, warranty, delivery, payment and grievance informationRule 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

This is a self-audit statement published by Example Retail Private Limited. It is not issued, endorsed, accredited or verified by any government authority, or by the publisher of the statement format, and it is not legal advice.

Prepared in the Open Self-Audit Statement format, version 0.1 (CC BY 4.0).

02Part by part

Why each section is there

SectionWhat it saysWhy it matters
Entity and platformsLegal 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.
DatesAudit 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 exclusionsThe 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.
MethodHow 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.
CoverageAn 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 itemsHow 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 signatoryA 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.