Frequent complaints include unexpected rental charges, ads during paid subscriptions and difficult cancellations. These tactics, commonly referred to as dark patterns, can mislead users into continuing subscriptions, sharing personal data, or paying extra charges not clearly disclosed.
Some users also report being asked to install separate apps or re-register to access certain content.
A LocalCircles study of over 95,000 responses from OTT users identified six dominant dark patterns: interface interference, forced action, bait and switch, drip pricing, subscription traps and SaaS billing. Users cited hidden cancel buttons, surprise rental fees, unclear final pricing and charges even after cancellation.
To tackle these concerns, the Department of Consumer Affairs introduced Guidelines for Prevention and Regulation of Dark Patterns in 2023, listing 13 such practices, including false urgency, confirm shaming, basket sneaking, disguised ads, nagging, trick wording and rogue malwares.
While the union government’s guidelines are aimed at improving digital transparency, some OTT platforms argue they apply only to e-commerce services.“Dark patterns like forced action, where ads are added to a plan that was earlier ad-free, or subscriptions with difficult cancellation processes lead to a direct erosion of consumer trust,” said Sachin Taparia, founder of LocalCircles.“The need of the hour is for all OTT platforms to assess which of the 13 dark patterns exist on their platforms and resolve them at the earliest. Such a move will improve transparency, and platforms that act swiftly will gain a long-term advantage over their competitors,” he added.
Experts say greater clarity and enforcement are needed as streaming becomes the primary mode of content consumption in India. The ministry of information and broadcasting listed 69 OTT platforms in the country, including Netflix, Prime Video, JioHotstar, ZEE5 and SonyLIV.
“India’s regulatory approach is rapidly evolving from a reactive stance to a proactive one. The CCPA (Central Consumer Protection Authority) has taken the lead by defining and warning against dark patterns, and by holding platforms—including OTT services—accountable. MeitY’s (ministry of electronics and information technology) policies and Trai’s (Telecom Regulatory Authority of India) oversight play supporting roles in ensuring that digital marketplaces are fair and that no regulatory gaps allow these practices to persist unchecked,” said Consumer Protection Association president Kashyapnath N Upadhyay.
“While enforcement is still ramping up and some platforms are dragging their feet by claiming the guidelines are not binding, the trajectory is clear: deceptive design in OTT subscriptions is on the regulators’ radar, and India is moving towards a regime of greater transparency and stronger consumer rights online,” he added.
