What interested me about the recent order by the Central Consumer Protection Authority (CCPA) against Rapido was not the ₹10 lakh penalty. It was the pricing slider.
The regulator examined a feature that allowed customers to increase or reduce the fare while a ride request was being processed. It looked at the prompts shown to customers, the colours used on the slider, and the space available to move the fare up or down. The CCPA concluded that elements of the design amounted to dark patterns.
There is nothing unusual about a digital company making decisions about how a screen should look or how a customer should move through it. Product teams do this every day. Growth teams experiment with prompts and journeys. Commercial teams think about pricing, visibility, and conversion. Most of these discussions would probably never begin with someone asking whether they were making a regulatory decision.
That is what makes the Rapido order interesting.
The recently amended Consumer Protection (E-Commerce) Rules point in a similar direction. They deal with search and ranking, sponsored listings, the presentation of price reductions, dark patterns, consent and other parts of the online buying experience. An annual self-audit of dark patterns will also become part of the compliance framework when the amendments take effect on 1 January 2027.
Much of the immediate discussion around the rules has understandably been about compliance. Companies need to know what has changed and what they are required to do. There is another conversation worth having inside digital businesses, particularly those where product decisions can quickly change how customers discover, choose or pay for something.
A search ranking, for example, is part of the product. It can also determine which seller or product gets seen. Sponsored placement is a commercial proposition, but it changes what appears to a customer. The way a discount is displayed may be designed to improve conversion. None of this is unfamiliar territory for a digital business. What is changing is the extent to which these choices can also attract regulatory attention.
That makes the usual division of responsibilities inside a company less comfortable than it looks on an organisation chart. Legal can interpret a rule. Public Policy can follow what government and regulators are doing. Product can build and test a feature. Growth can measure whether it works. The difficulty is that a decision can travel quite far through the last two before anybody realises that the first two may need to look at it.
At PolicyBridge, we tend to look at developments like these from the business decision backwards. The notification matters, but so does the decision it changes. In this case, that decision may sit with a product, growth or commercial team rather than with Legal or Public Policy.
That changes how regulatory risk needs to be understood inside a business. Tracking a new rule is one part of the job. Recognising that a pricing feature, ranking system or customer journey may now carry an institutional question is another. The second is easier to miss because it may not appear to be a policy issue at all.
Putting Legal or Public Policy into every product discussion would solve very little. Most product changes do not need a regulatory debate, and a company cannot operate as though every experiment is a potential policy problem. What matters is whether the business can recognise the relatively small number of decisions where something more than product performance is at stake.
This becomes harder when the rule itself is still developing. A feature may not sit neatly against a specific prohibition. It may nevertheless influence consumer choice in ways that are beginning to concern regulators. By the time that concern becomes explicit, the feature may already be working well commercially and may have become part of the way the business operates.
India’s approach to dark patterns is a useful example. Guidelines were issued in 2023. In 2025, e-commerce platforms were advised to conduct self-audits to identify dark patterns on their own platforms rather than wait for regulatory intervention. The latest amendments take that process further by making the self-audit an annual requirement and mandating that a compliance certificate be displayed.
Seen over those three years, consumer regulation has moved closer to the actual experience of using a digital product. That experience is created through dozens of decisions about design, pricing, ranking, prompts, defaults, and information. Some of those decisions will remain exactly what they have always been: product decisions. Others may carry implications that are not obvious when they are first discussed.
Companies do not need to turn product managers into regulatory experts. They do need enough judgement across the organisation to recognise when a seemingly ordinary product decision deserves a wider conversation before it becomes difficult to change.
For management, the regulatory question may therefore need to be asked before something reaches Legal or Public Policy. By then, the more important business decision may already have been made.
Sources
Department of Consumer Affairs, Government of India — Government amends E-Commerce Rules to strengthen consumer protection and promote transparency, September 2026.
Central Consumer Protection Authority — CCPA Imposed ₹10 Lakh Penalty on Rapido for Misleading Tipping Prompts and Dark Patterns, 15 September 2026.
Central Consumer Protection Authority / Department of Consumer Affairs — Advisory to e-commerce platforms for self-audit to detect dark patterns, June 2025.
Central Consumer Protection Authority — Guidelines for Prevention and Regulation of Dark Patterns, 2023.