The government has launched a formal investigation into e-commerce platforms accused of imposing extra charges on Cash-on-Delivery (COD) orders, describing the practice as a “dark pattern” designed to mislead and exploit consumers.
Consumer Affairs Minister Pralhad Joshi confirmed the move on 3 October, by taking to posting on the social media platform X, “The Department of Consumer Affairs has received complaints against e-commerce platforms charging extra for Cash-on-Delivery, a practice classified as a dark pattern that misleads and exploits consumers. A detailed investigation has been initiated and steps are being taken to scrutinise these platforms closely. Strict action will be taken against those violating consumer rights to ensure transparency and uphold fair practices in India’s growing e-commerce sector.”
The decision comes as authorities intensify scrutiny of manipulative digital practices that can distort user behaviour and erode trust in online commerce.
What Triggered The Probe?
The inquiry follows a spate of consumer complaints earlier this year after some e-commerce players introduced so-called “cash handling fees” on COD orders. One case involving quick-commerce platform Zepto drew significant attention in July, when users highlighted the charges on social media and criticised the lack of transparency at checkout.
Such fees may fall under “drip pricing”, one of 13 dark patterns officially recognised under Indian law, and therefore require closer examination.
What Are Dark Patterns?
Dark patterns are design tricks embedded in digital platforms that nudge users into decisions favourable to companies, often at the cost of clarity and fairness. These tactics can include confusing interfaces, hidden charges, or misleading prompts that push customers into spending more, disclosing personal data, or accepting terms unknowingly.
Examples range from last-minute delivery fees and pre-ticked consent boxes to false urgency messages such as “only one item left”.
In November 2023, the Consumer Affairs Department formally designated 13 such practices — including drip pricing, false urgency, bait-and-switch, confirm shaming, subscription traps, disguised ads and forced action — as unfair trade practices under the Consumer Protection Act.
The issue is widespread. A 2024 report by the Advertising Standards Council of India (ASCI) found that 52 of the 53 most downloaded apps in the country deployed at least one dark pattern, particularly in e-commerce, fintech and online gaming.
According to the ASCI, these are not accidental glitches but deliberate features built into app design, making them difficult for users to identify until after transactions are completed.
Government’s Wider Crackdown
The probe into COD charges forms part of a broader push to curb deceptive digital practices. On 28 May, the Consumer Affairs Ministry convened a high-level meeting with leading e-commerce firms, directing them to conduct internal audits of their user interfaces and publish findings on compliance with 2023 guidelines.
Officials also floated the creation of a joint working group of government and industry representatives to address evolving challenges.
In the COD probe, authorities will review platform practices, collect consumer testimonies, and scrutinise when and how such charges were disclosed during the purchase process.
What Is Next?
If platforms are found in violation, they could face penalties under the Consumer Protection Act, alongside directives to alter interface designs or adopt clearer disclosure norms.
The outcome will be closely watched, as COD remains one of India’s most widely used payment modes, particularly beyond urban centres. The ministry’s intervention signals that digital design choices and fee structures will increasingly be held to the same regulatory standards as advertising claims and pricing transparency.
