{"name":"Australian unfair trading practice implementation dataset","lastReviewed":"2026-09-14","reviewScope":"Amending Act and research context compared. A full current ACL compilation review and fact-specific legal assessment remain separate.","practices":[{"title":"Automatic attention capture","slug":"automatic-attention-capture","preferredName":"Automatic attention capture","directAnswer":"Automatic attention capture is a working label for this design mechanism: Content continues automatically or lacks meaningful stopping cues, reducing deliberate control over time and attention. This is editorial implementation guidance for Australian journeys, not a finding of unlawfulness. From 1 July 2027, a similar interface is relevant to ACL section 28B only if the complete consumer-connection, manipulation or unreasonable-distortion and actual-or-likely-detriment test is met. Current ACL rules require a separate assessment.","definition":"Content continues automatically or lacks meaningful stopping cues, reducing deliberate control over time and attention. This is a design and research taxonomy for learning and evidence review, not a statutory offence label or an automatic finding that an interface is unlawful.","synonyms":["autoplay","infinite scroll","continuous consumption","automatic next video","infinite feed without stopping cue","autoplay preference ignored"],"category":"Forced action","family":"Forced action","journeyStages":["Account Management","Pricing"],"jurisdiction":"Australia","status":"Editorial implementation guidance","howItWorks":"Content continues automatically or lacks meaningful stopping cues, reducing deliberate control over time and attention. Automatic continuation removes natural stopping cues and overrides a person’s effort to pause, leave or keep track of position and elapsed use.","warningSigns":["New content starts or loads without an affirmative request.","Stopping or disabling continuation is absent, hidden or non-persistent.","The mechanism plausibly extends use beyond the user's intended goal."],"harms":["The interface weakens a prior decision to stop and can extend use beyond the user’s intention.","A shopper can lose track of time, prior comparisons and where a considered choice occurred."],"legitimateUses":["User-initiated playlist or explicitly enabled autoplay with a persistent control","Ordinary pagination that loads another defined page only after a deliberate request","Content that advances only after a deliberate user request and preserves a visible stopping point"],"legalBasis":[{"provision":"ACL section 28B, inserted by the 2026 Act","sourceIds":["au-act-2026-64"],"classification":"Possible risk indicator","explanation":"In account management and pricing journeys, the automatic attention capture mechanism may warrant review where it manipulates a consumer or unreasonably distorts the decision environment and causes, or is likely to cause, detriment. The forced action label and an interface similarity do not establish a contravention; the complete section 28B test, scope, facts and evidence must be applied from 1 July 2027."},{"provision":"Dark-pattern research taxonomy","sourceIds":["oecd-dark-commercial-patterns-2022"],"classification":"Editorial analysis","explanation":"The cited research sources support this working pattern within the forced action family. It is editorial implementation guidance, not an Australian statutory category, regulator finding or legal safe harbour."}],"examples":[{"type":"Illustrative example","context":"Autoplay overrides a session limit","scenario":"A fictional video service starts another clip when a user’s chosen twenty-minute limit is reached and hides the leave action behind a full-screen recommendation.","harm":"The interface weakens a prior decision to stop and can extend use beyond the user’s intention."},{"type":"Illustrative example","context":"Infinite catalogue without progress cues","scenario":"A fictional marketplace continuously inserts new products and removes pagination, position and viewed-item markers while promotional prompts follow the shopper.","harm":"A shopper can lose track of time, prior comparisons and where a considered choice occurred."}],"problematicUi":{"label":"One more video","copy":"One more video The next clip starts automatically while the exit sits behind the recommendation. Keep watching Leave now","annotations":["Why this state matters: The additional dependency controls access to the account management goal. The panel states: “The next clip starts automatically while the exit sits behind the recommendation.” Reviewers need to establish whether “Keep watching” is necessary for the selected task or pressures the user into a separable action. The interface weakens a prior decision to stop and can extend use beyond the user’s intention.","Review prompt: What functional need makes “Keep watching” necessary for the short-video feed goal, and can that need be met with less disclosure or commitment?"]},"improvedUi":{"label":"Your 20-minute limit is reached","copy":"Your 20-minute limit is reached Playback pauses and stopping is the first available action. Leave now Keep watching What happens next Activating “Leave now” produces the outcome stated on the control.","annotations":["Fairer design: Pause at the selected limit and show stable choices to leave, extend once or change the setting.","Review prompt: Can the dialog be dismissed, what action does each control trigger, and what later state confirms or contradicts “New content starts or loads without an affirmative request”?"]},"uiComparisons":[{"id":"automatic-attention-capture-scenario-1","title":"Autoplay overrides a session limit","context":"Short-video feed","journeyStage":"Account Management","summary":"A fictional video service starts another clip when a user’s chosen twenty-minute limit is reached and hides the leave action behind a full-screen recommendation.","problematic":{"label":"One more video","layout":"dialog","elements":[{"id":"problematic-1-heading","type":"heading","text":"One more video"},{"id":"problematic-2-body","type":"text","text":"The next clip starts automatically while the exit sits behind the recommendation.","tone":"warning"},{"id":"problematic-3-button","type":"button","text":"Keep watching","emphasis":"primary"},{"id":"problematic-4-link","type":"link","text":"Leave now","emphasis":"subtle"}],"annotations":[{"targetId":"problematic-2-body","text":"Why this state matters: The additional dependency controls access to the account management goal. The panel states: “The next clip starts automatically while the exit sits behind the recommendation.” Reviewers need to establish whether “Keep watching” is necessary for the selected task or pressures the user into a separable action. The interface weakens a prior decision to stop and can extend use beyond the user’s intention."},{"targetId":"problematic-4-link","text":"Review prompt: What functional need makes “Keep watching” necessary for the short-video feed goal, and can that need be met with less disclosure or commitment?"}]},"neutral":{"label":"Your 20-minute limit is reached","layout":"dialog","elements":[{"id":"neutral-1-heading","type":"heading","text":"Your 20-minute limit is reached"},{"id":"neutral-2-body","type":"text","text":"Playback pauses and stopping is the first available action.","tone":"default"},{"id":"neutral-3-button","type":"button","text":"Leave now","emphasis":"secondary"},{"id":"neutral-4-link","type":"link","text":"Keep watching","emphasis":"default"},{"id":"neutral-5-disclosure","type":"disclosure","summary":"What happens next","content":"Activating “Leave now” produces the outcome stated on the control.","open":true}],"annotations":[{"targetId":"neutral-2-body","text":"Fairer design: Pause at the selected limit and show stable choices to leave, extend once or change the setting."},{"targetId":"neutral-5-disclosure","text":"Review prompt: Can the dialog be dismissed, what action does each control trigger, and what later state confirms or contradicts “New content starts or loads without an affirmative request”?"}]},"whyItMatters":"The additional dependency controls access to the account management goal. The panel states: “The next clip starts automatically while the exit sits behind the recommendation.” Reviewers need to establish whether “Keep watching” is necessary for the selected task or pressures the user into a separable action. The interface weakens a prior decision to stop and can extend use beyond the user’s intention.","fairDesignPrinciple":"Pause at the selected limit and show stable choices to leave, extend once or change the setting.","reviewPrompts":["What functional need makes “Keep watching” necessary for the short-video feed goal, and can that need be met with less disclosure or commitment?","Can the dialog be dismissed, what action does each control trigger, and what later state confirms or contradicts “New content starts or loads without an affirmative request”?","Could the stated purpose make this dependency genuinely necessary under the boundary “User-initiated playlist or explicitly enabled autoplay with a persistent control”, and what product evidence would demonstrate that necessity?"],"altText":"Side-by-side short-video feed interface showing “One more video” and the clearer alternative “Your 20-minute limit is reached”.","provenance":"Original hypothetical short-video feed example created for this library; no real business, product or interface is depicted."},{"id":"automatic-attention-capture-scenario-2","title":"Infinite catalogue without progress cues","context":"Shopping discovery feed","journeyStage":"Pricing","summary":"A fictional marketplace continuously inserts new products and removes pagination, position and viewed-item markers while promotional prompts follow the shopper.","problematic":{"label":"More picks loaded for you","layout":"account-panel","elements":[{"id":"problematic-1-heading","type":"heading","text":"More picks loaded for you"},{"id":"problematic-2-body","type":"text","text":"The list has no end, position or record of products already compared.","tone":"warning"},{"id":"problematic-3-link","type":"link","text":"Continue browsing","emphasis":"subtle"},{"id":"problematic-4-badge","type":"badge","text":"Unconfirmed state: Continue browsing","tone":"warning"}],"annotations":[{"targetId":"problematic-2-body","text":"Why this state matters: The additional dependency controls access to the pricing goal. The panel states: “The list has no end, position or record of products already compared.” Reviewers need to establish whether “Continue browsing” is necessary for the selected task or pressures the user into a separable action. A shopper can lose track of time, prior comparisons and where a considered choice occurred."},{"targetId":"problematic-4-badge","text":"Review prompt: What functional need makes “Continue browsing” necessary for the shopping discovery feed goal, and can that need be met with less disclosure or commitment?"}]},"neutral":{"label":"20 products reviewed","layout":"account-panel","elements":[{"id":"neutral-1-heading","type":"heading","text":"20 products reviewed"},{"id":"neutral-2-body","type":"text","text":"The shopper can stop, save the set or load another defined group.","tone":"default"},{"id":"neutral-3-link","type":"link","text":"Save and stop","emphasis":"default"},{"id":"neutral-4-badge","type":"badge","text":"Saved state: Save and stop","tone":"default"},{"id":"neutral-5-disclosure","type":"disclosure","summary":"Persisted account state","content":"The saved state behind “Save and stop” remains consistent after refresh and across supported channels.","open":true}],"annotations":[{"targetId":"neutral-2-body","text":"Fairer design: Provide meaningful batches, a visible position and a reliable way to pause, save or return to compared items."},{"targetId":"neutral-5-disclosure","text":"Review prompt: Test the control across refresh, device and account states; is “Stopping or disabling continuation is absent, hidden or non-persistent” still observable after persistence is considered?"}]},"whyItMatters":"The additional dependency controls access to the pricing goal. The panel states: “The list has no end, position or record of products already compared.” Reviewers need to establish whether “Continue browsing” is necessary for the selected task or pressures the user into a separable action. A shopper can lose track of time, prior comparisons and where a considered choice occurred.","fairDesignPrinciple":"Provide meaningful batches, a visible position and a reliable way to pause, save or return to compared items.","reviewPrompts":["What functional need makes “Continue browsing” necessary for the shopping discovery feed goal, and can that need be met with less disclosure or commitment?","Test the control across refresh, device and account states; is “Stopping or disabling continuation is absent, hidden or non-persistent” still observable after persistence is considered?","Could the stated purpose make this dependency genuinely necessary under the boundary “ordinary pagination”, and what product evidence would demonstrate that necessity?"],"altText":"Side-by-side shopping discovery feed interface showing “More picks loaded for you” and the clearer alternative “20 products reviewed”.","provenance":"Original hypothetical shopping discovery feed example created for this library; no real business, product or interface is depicted."}],"fairAlternative":"Require deliberate continuation or provide clear, persistent pause and disable controls with natural stopping cues.","whyProblematic":"Content continues automatically or lacks meaningful stopping cues, reducing deliberate control over time and attention. Automatic continuation removes natural stopping cues and overrides a person’s effort to pause, leave or keep track of position and elapsed use. These harms describe a review risk, not an automatic legal conclusion. Australian section 28B commences on 1 July 2027 and requires its complete, context-specific test. Existing ACL provisions remain a separate current-law assessment.","contextFactors":["New content starts or loads without an affirmative request.","Stopping or disabling continuation is absent, hidden or non-persistent.","The mechanism plausibly extends use beyond the user's intended goal.","Boundary to test: User-initiated playlist or explicitly enabled autoplay with a persistent control","Boundary to test: Ordinary pagination that loads another defined page only after a deliberate request","Boundary to test: Content that advances only after a deliberate user request and preserves a visible stopping point"],"affectedTeams":["Product","Design","Engineering","Legal","Compliance"],"reviewQuestions":["What functional need makes “Keep watching” necessary for the short-video feed goal, and can that need be met with less disclosure or commitment?","Can the dialog be dismissed, what action does each control trigger, and what later state confirms or contradicts “New content starts or loads without an affirmative request”?","Could the stated purpose make this dependency genuinely necessary under the boundary “User-initiated playlist or explicitly enabled autoplay with a persistent control”, and what product evidence would demonstrate that necessity?","What functional need makes “Continue browsing” necessary for the shopping discovery feed goal, and can that need be met with less disclosure or commitment?","Test the control across refresh, device and account states; is “Stopping or disabling continuation is absent, hidden or non-persistent” still observable after persistence is considered?","Could the stated purpose make this dependency genuinely necessary under the boundary “ordinary pagination”, and what product evidence would demonstrate that necessity?"],"evidence":["Annotated account management and pricing screenshots at each responsive breakpoint","The complete state sequence before, during and after the consumer decision","Design-system component, content, default and configuration records for the reviewed release","Operational records substantiating price, availability, timing and eligibility claims","Usability, accessibility, reversal, complaint and support evidence relevant to consumer impact","A dated product and legal review record identifying evidence, uncertainties and release decisions"],"related":["contact-harvesting-and-coerced-referrals","forced-disclosure-or-excessive-data-request","forced-or-bundled-consent","forced-registration-and-data-disclosure"],"sourceIds":["oecd-dark-commercial-patterns-2022","au-act-2026-64"],"altText":"Side-by-side short-video feed interface showing “One more video” and the clearer alternative “Your 20-minute limit is reached”.","provenance":"Original hypothetical interface comparisons from the shared learning library, adapted to Australian-dollar context for this portal; no real business, product or interface is depicted.","author":"Flowlane","datePublished":"2026-08-10","dateModified":"2026-09-14","lastReviewed":"2026-09-14","changeNote":"Source comparison recorded and the current status restated."},{"title":"Contact harvesting and coerced referrals","slug":"contact-harvesting-and-coerced-referrals","preferredName":"Contact harvesting and coerced referrals","directAnswer":"Contact harvesting and coerced referrals is a working label for this design mechanism: The service extracts contact information, sends or prepares unwanted invitations, or ties functionality to recruiting other people. This is editorial implementation guidance for Australian journeys, not a finding of unlawfulness. From 1 July 2027, a similar interface is relevant to ACL section 28B only if the complete consumer-connection, manipulation or unreasonable-distortion and actual-or-likely-detriment test is met. Current ACL rules require a separate assessment.","definition":"The service extracts contact information, sends or prepares unwanted invitations, or ties functionality to recruiting other people. This is a design and research taxonomy for learning and evidence review, not a statutory offence label or an automatic finding that an interface is unlawful.","synonyms":["friend spam","address book leeching","social pyramid","address-book extraction","preselected mass invitation","message sent under unclear consent","functionality or reward tied to recruitment"],"category":"Forced action","family":"Forced action","journeyStages":["Signup","Account Management"],"jurisdiction":"Australia","status":"Editorial implementation guidance","howItWorks":"The service extracts contact information, sends or prepares unwanted invitations, or ties functionality to recruiting other people. Progress depends on exposing or contacting other people, turning a referral or address-book permission into the price of access to an unrelated feature.","warningSigns":["Contact access, recipient selection, invitation or referral is involved.","Consent, recipient choice or downstream use is unclear, defaulted or coerced.","The behaviour is linked to access, reward or normal progression."],"harms":["Contacts who never used the service may be exposed or invited, while the new user loses a meaningful refusal.","The user is pressured to disclose other people’s contact data and send messages unrelated to the export task."],"legitimateUses":["Voluntary one-recipient sharing with preview and confirmation","clearly optional referral program with no functional penalty"],"legalBasis":[{"provision":"ACL section 28B, inserted by the 2026 Act","sourceIds":["au-act-2026-64"],"classification":"Possible risk indicator","explanation":"In signup and account management journeys, the contact harvesting and coerced referrals mechanism may warrant review where it manipulates a consumer or unreasonably distorts the decision environment and causes, or is likely to cause, detriment. The forced action label and an interface similarity do not establish a contravention; the complete section 28B test, scope, facts and evidence must be applied from 1 July 2027."},{"provision":"Dark-pattern research taxonomy","sourceIds":["oecd-dark-commercial-patterns-2022"],"classification":"Editorial analysis","explanation":"The cited research sources support this working pattern within the forced action family. It is editorial implementation guidance, not an Australian statutory category, regulator finding or legal safe harbour."}],"examples":[{"type":"Illustrative example","context":"Address-book import blocks onboarding","scenario":"A fictional community app stops onboarding at an address-book permission screen and gives no visible way to continue without uploading contacts.","harm":"Contacts who never used the service may be exposed or invited, while the new user loses a meaningful refusal."},{"type":"Illustrative example","context":"Feature unlocked by recruiting friends","scenario":"A fictional workspace keeps export disabled until the user supplies three colleagues’ addresses and sends invitations from the service.","harm":"The user is pressured to disclose other people’s contact data and send messages unrelated to the export task."}],"problematicUi":{"label":"Find everyone you know","copy":"Find everyone you know Onboarding cannot continue until contacts are uploaded. Allow contacts Skip for now","annotations":["Why this state matters: The additional dependency controls access to the signup goal. The panel states: “Onboarding cannot continue until contacts are uploaded.” Reviewers need to establish whether “Allow contacts” is necessary for the selected task or pressures the user into a separable action. Contacts who never used the service may be exposed or invited, while the new user loses a meaningful refusal.","Review prompt: What functional need makes “Allow contacts” necessary for the social app onboarding goal, and can that need be met with less disclosure or commitment?"]},"improvedUi":{"label":"Find contacts later","copy":"Find contacts later Contact discovery is optional and onboarding can continue without it. Skip for now Allow contacts What happens next Activating “Skip for now” produces the outcome stated on the control.","annotations":["Fairer design: Explain the optional discovery benefit, provide a visible skip control and do not prepare invitations without a separate deliberate action.","Review prompt: Can the dialog be dismissed, what action does each control trigger, and what later state confirms or contradicts “Contact access, recipient selection, invitation or referral is involved”?"]},"uiComparisons":[{"id":"contact-harvesting-and-coerced-referrals-scenario-1","title":"Address-book import blocks onboarding","context":"Social app onboarding","journeyStage":"Signup","summary":"A fictional community app stops onboarding at an address-book permission screen and gives no visible way to continue without uploading contacts.","problematic":{"label":"Find everyone you know","layout":"dialog","elements":[{"id":"problematic-1-heading","type":"heading","text":"Find everyone you know"},{"id":"problematic-2-body","type":"text","text":"Onboarding cannot continue until contacts are uploaded.","tone":"warning"},{"id":"problematic-3-button","type":"button","text":"Allow contacts","emphasis":"primary"},{"id":"problematic-4-link","type":"link","text":"Skip for now","emphasis":"subtle"}],"annotations":[{"targetId":"problematic-2-body","text":"Why this state matters: The additional dependency controls access to the signup goal. The panel states: “Onboarding cannot continue until contacts are uploaded.” Reviewers need to establish whether “Allow contacts” is necessary for the selected task or pressures the user into a separable action. Contacts who never used the service may be exposed or invited, while the new user loses a meaningful refusal."},{"targetId":"problematic-4-link","text":"Review prompt: What functional need makes “Allow contacts” necessary for the social app onboarding goal, and can that need be met with less disclosure or commitment?"}]},"neutral":{"label":"Find contacts later","layout":"dialog","elements":[{"id":"neutral-1-heading","type":"heading","text":"Find contacts later"},{"id":"neutral-2-body","type":"text","text":"Contact discovery is optional and onboarding can continue without it.","tone":"default"},{"id":"neutral-3-button","type":"button","text":"Skip for now","emphasis":"secondary"},{"id":"neutral-4-link","type":"link","text":"Allow contacts","emphasis":"default"},{"id":"neutral-5-disclosure","type":"disclosure","summary":"What happens next","content":"Activating “Skip for now” produces the outcome stated on the control.","open":true}],"annotations":[{"targetId":"neutral-2-body","text":"Fairer design: Explain the optional discovery benefit, provide a visible skip control and do not prepare invitations without a separate deliberate action."},{"targetId":"neutral-5-disclosure","text":"Review prompt: Can the dialog be dismissed, what action does each control trigger, and what later state confirms or contradicts “Contact access, recipient selection, invitation or referral is involved”?"}]},"whyItMatters":"The additional dependency controls access to the signup goal. The panel states: “Onboarding cannot continue until contacts are uploaded.” Reviewers need to establish whether “Allow contacts” is necessary for the selected task or pressures the user into a separable action. Contacts who never used the service may be exposed or invited, while the new user loses a meaningful refusal.","fairDesignPrinciple":"Explain the optional discovery benefit, provide a visible skip control and do not prepare invitations without a separate deliberate action.","reviewPrompts":["What functional need makes “Allow contacts” necessary for the social app onboarding goal, and can that need be met with less disclosure or commitment?","Can the dialog be dismissed, what action does each control trigger, and what later state confirms or contradicts “Contact access, recipient selection, invitation or referral is involved”?","Could the stated purpose make this dependency genuinely necessary under the boundary “Voluntary one-recipient sharing with preview and confirmation”, and what product evidence would demonstrate that necessity?"],"altText":"Side-by-side social app onboarding interface showing “Find everyone you know” and the clearer alternative “Find contacts later”.","provenance":"Original hypothetical social app onboarding example created for this library; no real business, product or interface is depicted."},{"id":"contact-harvesting-and-coerced-referrals-scenario-2","title":"Feature unlocked by recruiting friends","context":"Collaboration workspace","journeyStage":"Account Management","summary":"A fictional workspace keeps export disabled until the user supplies three colleagues’ addresses and sends invitations from the service.","problematic":{"label":"Invite three people to export","layout":"account-panel","elements":[{"id":"problematic-1-heading","type":"heading","text":"Invite three people to export"},{"id":"problematic-2-body","type":"text","text":"The export link stays locked until three invitations are sent.","tone":"warning"},{"id":"problematic-3-link","type":"link","text":"Add contacts","emphasis":"subtle"},{"id":"problematic-4-badge","type":"badge","text":"Unconfirmed state: Add contacts","tone":"warning"}],"annotations":[{"targetId":"problematic-2-body","text":"Why this state matters: The additional dependency controls access to the account management goal. The panel states: “The export link stays locked until three invitations are sent.” Reviewers need to establish whether “Add contacts” is necessary for the selected task or pressures the user into a separable action. The user is pressured to disclose other people’s contact data and send messages unrelated to the export task."},{"targetId":"problematic-4-badge","text":"Review prompt: What functional need makes “Add contacts” necessary for the collaboration workspace goal, and can that need be met with less disclosure or commitment?"}]},"neutral":{"label":"Export your workspace","layout":"account-panel","elements":[{"id":"neutral-1-heading","type":"heading","text":"Export your workspace"},{"id":"neutral-2-body","type":"text","text":"Export works independently; inviting collaborators remains optional.","tone":"default"},{"id":"neutral-3-link","type":"link","text":"Download export","emphasis":"default"},{"id":"neutral-4-badge","type":"badge","text":"Saved state: Download export","tone":"default"},{"id":"neutral-5-disclosure","type":"disclosure","summary":"Persisted account state","content":"The saved state behind “Download export” remains consistent after refresh and across supported channels.","open":true}],"annotations":[{"targetId":"neutral-2-body","text":"Fairer design: Keep export independent of referrals and let users invite collaborators only when collaboration is their chosen goal."},{"targetId":"neutral-5-disclosure","text":"Review prompt: Test the control across refresh, device and account states; is “Consent, recipient choice or downstream use is unclear, defaulted or coerced” still observable after persistence is considered?"}]},"whyItMatters":"The additional dependency controls access to the account management goal. The panel states: “The export link stays locked until three invitations are sent.” Reviewers need to establish whether “Add contacts” is necessary for the selected task or pressures the user into a separable action. The user is pressured to disclose other people’s contact data and send messages unrelated to the export task.","fairDesignPrinciple":"Keep export independent of referrals and let users invite collaborators only when collaboration is their chosen goal.","reviewPrompts":["What functional need makes “Add contacts” necessary for the collaboration workspace goal, and can that need be met with less disclosure or commitment?","Test the control across refresh, device and account states; is “Consent, recipient choice or downstream use is unclear, defaulted or coerced” still observable after persistence is considered?","Could the stated purpose make this dependency genuinely necessary under the boundary “clearly optional referral program with no functional penalty”, and what product evidence would demonstrate that necessity?"],"altText":"Side-by-side collaboration workspace interface showing “Invite three people to export” and the clearer alternative “Export your workspace”.","provenance":"Original hypothetical collaboration workspace example created for this library; no real business, product or interface is depicted."}],"fairAlternative":"Make contact access and referrals optional, granular and previewable; require affirmative confirmation for every recipient and message.","whyProblematic":"The service extracts contact information, sends or prepares unwanted invitations, or ties functionality to recruiting other people. Progress depends on exposing or contacting other people, turning a referral or address-book permission into the price of access to an unrelated feature. These harms describe a review risk, not an automatic legal conclusion. Australian section 28B commences on 1 July 2027 and requires its complete, context-specific test. Existing ACL provisions remain a separate current-law assessment.","contextFactors":["Contact access, recipient selection, invitation or referral is involved.","Consent, recipient choice or downstream use is unclear, defaulted or coerced.","The behaviour is linked to access, reward or normal progression.","Boundary to test: Voluntary one-recipient sharing with preview and confirmation","Boundary to test: clearly optional referral program with no functional penalty"],"affectedTeams":["Product","Design","Engineering","Legal","Compliance"],"reviewQuestions":["What functional need makes “Allow contacts” necessary for the social app onboarding goal, and can that need be met with less disclosure or commitment?","Can the dialog be dismissed, what action does each control trigger, and what later state confirms or contradicts “Contact access, recipient selection, invitation or referral is involved”?","Could the stated purpose make this dependency genuinely necessary under the boundary “Voluntary one-recipient sharing with preview and confirmation”, and what product evidence would demonstrate that necessity?","What functional need makes “Add contacts” necessary for the collaboration workspace goal, and can that need be met with less disclosure or commitment?","Test the control across refresh, device and account states; is “Consent, recipient choice or downstream use is unclear, defaulted or coerced” still observable after persistence is considered?","Could the stated purpose make this dependency genuinely necessary under the boundary “clearly optional referral program with no functional penalty”, and what product evidence would demonstrate that necessity?"],"evidence":["Annotated signup and account management screenshots at each responsive breakpoint","The complete state sequence before, during and after the consumer decision","Design-system component, content, default and configuration records for the reviewed release","Operational records substantiating price, availability, timing and eligibility claims","Usability, accessibility, reversal, complaint and support evidence relevant to consumer impact","A dated product and legal review record identifying evidence, uncertainties and release decisions"],"related":["automatic-attention-capture","forced-disclosure-or-excessive-data-request","forced-or-bundled-consent","forced-registration-and-data-disclosure"],"sourceIds":["oecd-dark-commercial-patterns-2022","au-act-2026-64"],"altText":"Side-by-side social app onboarding interface showing “Find everyone you know” and the clearer alternative “Find contacts later”.","provenance":"Original hypothetical interface comparisons from the shared learning library, adapted to Australian-dollar context for this portal; no real business, product or interface is depicted.","author":"Flowlane","datePublished":"2026-08-10","dateModified":"2026-09-14","lastReviewed":"2026-09-14","changeNote":"Source comparison recorded and the current status restated."},{"title":"Forced or bundled consent","slug":"forced-or-bundled-consent","preferredName":"Forced or bundled consent","directAnswer":"Forced or bundled consent is a working label for this design mechanism: Access is conditioned on accepting optional or separable data uses, communications or permissions as one bundled choice. This is editorial implementation guidance for Australian journeys, not a finding of unlawfulness. From 1 July 2027, a similar interface is relevant to ACL section 28B only if the complete consumer-connection, manipulation or unreasonable-distortion and actual-or-likely-detriment test is met. Current ACL rules require a separate assessment.","definition":"Access is conditioned on accepting optional or separable data uses, communications or permissions as one bundled choice. This is a design and research taxonomy for learning and evidence review, not a statutory offence label or an automatic finding that an interface is unlawful.","synonyms":["take-it-or-leave-it consent","consent wall","bundled permission","service access tied to optional tracking","multiple unrelated purposes under one accept action","decline blocks unrelated core function"],"category":"Forced action","family":"Forced action","journeyStages":["Signup","Checkout"],"jurisdiction":"Australia","status":"Editorial implementation guidance","howItWorks":"Access is conditioned on accepting optional or separable data uses, communications or permissions as one bundled choice. Several distinct processing purposes are collapsed into one take-it-or-leave-it permission, so a person cannot accept necessary operation without optional uses.","warningSigns":["Multiple consequences or purposes are attached to one acceptance control.","At least one consequence appears separable from the core function.","Refusal blocks or materially burdens access."],"harms":["A visitor cannot distinguish necessary operation from optional data uses or express separate choices.","Refusing unrelated marketing appears to prevent completion of the requested transaction."],"legitimateUses":["Single necessary processing operation clearly explained","bundle with granular equivalent controls and no penalty for refusal"],"legalBasis":[{"provision":"ACL section 28B, inserted by the 2026 Act","sourceIds":["au-act-2026-64"],"classification":"Possible risk indicator","explanation":"In signup and checkout journeys, the forced or bundled consent mechanism may warrant review where it manipulates a consumer or unreasonably distorts the decision environment and causes, or is likely to cause, detriment. The forced action label and an interface similarity do not establish a contravention; the complete section 28B test, scope, facts and evidence must be applied from 1 July 2027."},{"provision":"Dark-pattern research taxonomy","sourceIds":["gray-ontology-dark-patterns-2024","eu-behavioural-study-digital-environment-2022"],"classification":"Editorial analysis","explanation":"The cited research sources support this working pattern within the forced action family. It is editorial implementation guidance, not an Australian statutory category, regulator finding or legal safe harbour."}],"examples":[{"type":"Illustrative example","context":"Optional analytics bundled with access","scenario":"A fictional news service presents one accept control for essential storage, audience analytics, advertising profiles and partner sharing, while access is blocked.","harm":"A visitor cannot distinguish necessary operation from optional data uses or express separate choices."},{"type":"Illustrative example","context":"Purchase terms combined with promotions","scenario":"A fictional ticket seller requires one checkbox that accepts the purchase terms, promotional messages and sharing with event partners.","harm":"Refusing unrelated marketing appears to prevent completion of the requested transaction."}],"problematicUi":{"label":"Accept and enter","copy":"Accept and enter Essential storage, analytics, advertising and partner sharing are one package. Accept everything Use necessary storage only","annotations":["Why this state matters: The additional dependency controls access to the signup goal. The panel states: “Essential storage, analytics, advertising and partner sharing are one package.” Reviewers need to establish whether “Accept everything” is necessary for the selected task or pressures the user into a separable action. A visitor cannot distinguish necessary operation from optional data uses or express separate choices.","Review prompt: What functional need makes “Accept everything” necessary for the news site entry goal, and can that need be met with less disclosure or commitment?"]},"improvedUi":{"label":"Choose data uses","copy":"Choose data uses Necessary storage is explained and optional purposes have separate controls. Use necessary storage only Accept everything Choice consequences The consequence of selecting “Use necessary storage only” is displayed beside the option.","annotations":["Fairer design: Separate purposes, explain consequences and keep optional permissions off unless the visitor chooses them.","Review prompt: Capture every peer option, its default state and visual prominence; do those states support “Multiple consequences or purposes are attached to one acceptance control”?"]},"uiComparisons":[{"id":"forced-or-bundled-consent-scenario-1","title":"Optional analytics bundled with access","context":"News site entry","journeyStage":"Signup","summary":"A fictional news service presents one accept control for essential storage, audience analytics, advertising profiles and partner sharing, while access is blocked.","problematic":{"label":"Accept and enter","layout":"choice-list","elements":[{"id":"problematic-1-heading","type":"heading","text":"Accept and enter"},{"id":"problematic-2-body","type":"text","text":"Essential storage, analytics, advertising and partner sharing are one package.","tone":"warning"},{"id":"problematic-3-radio","type":"radio","label":"Accept everything","checked":true},{"id":"problematic-4-radio","type":"radio","label":"Use necessary storage only","checked":false}],"annotations":[{"targetId":"problematic-2-body","text":"Why this state matters: The additional dependency controls access to the signup goal. The panel states: “Essential storage, analytics, advertising and partner sharing are one package.” Reviewers need to establish whether “Accept everything” is necessary for the selected task or pressures the user into a separable action. A visitor cannot distinguish necessary operation from optional data uses or express separate choices."},{"targetId":"problematic-4-radio","text":"Review prompt: What functional need makes “Accept everything” necessary for the news site entry goal, and can that need be met with less disclosure or commitment?"}]},"neutral":{"label":"Choose data uses","layout":"choice-list","elements":[{"id":"neutral-1-heading","type":"heading","text":"Choose data uses"},{"id":"neutral-2-body","type":"text","text":"Necessary storage is explained and optional purposes have separate controls.","tone":"default"},{"id":"neutral-3-radio","type":"radio","label":"Use necessary storage only","checked":false},{"id":"neutral-4-radio","type":"radio","label":"Accept everything","checked":false},{"id":"neutral-5-disclosure","type":"disclosure","summary":"Choice consequences","content":"The consequence of selecting “Use necessary storage only” is displayed beside the option.","open":true}],"annotations":[{"targetId":"neutral-2-body","text":"Fairer design: Separate purposes, explain consequences and keep optional permissions off unless the visitor chooses them."},{"targetId":"neutral-5-disclosure","text":"Review prompt: Capture every peer option, its default state and visual prominence; do those states support “Multiple consequences or purposes are attached to one acceptance control”?"}]},"whyItMatters":"The additional dependency controls access to the signup goal. The panel states: “Essential storage, analytics, advertising and partner sharing are one package.” Reviewers need to establish whether “Accept everything” is necessary for the selected task or pressures the user into a separable action. A visitor cannot distinguish necessary operation from optional data uses or express separate choices.","fairDesignPrinciple":"Separate purposes, explain consequences and keep optional permissions off unless the visitor chooses them.","reviewPrompts":["What functional need makes “Accept everything” necessary for the news site entry goal, and can that need be met with less disclosure or commitment?","Capture every peer option, its default state and visual prominence; do those states support “Multiple consequences or purposes are attached to one acceptance control”?","Could the stated purpose make this dependency genuinely necessary under the boundary “Single necessary processing operation clearly explained”, and what product evidence would demonstrate that necessity?"],"altText":"Side-by-side news site entry interface showing “Accept and enter” and the clearer alternative “Choose data uses”.","provenance":"Original hypothetical news site entry example created for this library; no real business, product or interface is depicted."},{"id":"forced-or-bundled-consent-scenario-2","title":"Purchase terms combined with promotions","context":"Ticket checkout","journeyStage":"Checkout","summary":"A fictional ticket seller requires one checkbox that accepts the purchase terms, promotional messages and sharing with event partners.","problematic":{"label":"Agree to continue","layout":"form","elements":[{"id":"problematic-1-heading","type":"heading","text":"Agree to continue"},{"id":"problematic-2-body","type":"text","text":"Purchase, newsletters and partner offers use one required checkbox.","tone":"warning"},{"id":"problematic-3-checkbox","type":"checkbox","label":"Accept all terms and offers","checked":true},{"id":"problematic-4-button","type":"button","text":"Continue with selected choices","emphasis":"primary"}],"annotations":[{"targetId":"problematic-2-body","text":"Why this state matters: The additional dependency controls access to the checkout goal. The panel states: “Purchase, newsletters and partner offers use one required checkbox.” Reviewers need to establish whether “Accept all terms and offers” is necessary for the selected task or pressures the user into a separable action. Refusing unrelated marketing appears to prevent completion of the requested transaction."},{"targetId":"problematic-4-button","text":"Review prompt: What functional need makes “Accept all terms and offers” necessary for the ticket checkout goal, and can that need be met with less disclosure or commitment?"}]},"neutral":{"label":"Confirm purchase terms","layout":"form","elements":[{"id":"neutral-1-heading","type":"heading","text":"Confirm purchase terms"},{"id":"neutral-2-body","type":"text","text":"The contract control is required; marketing and partner choices are separate and optional.","tone":"default"},{"id":"neutral-3-button","type":"button","text":"Complete purchase","emphasis":"secondary"},{"id":"neutral-4-badge","type":"badge","text":"Only task-relevant details requested","tone":"default"},{"id":"neutral-5-disclosure","type":"disclosure","summary":"Purpose and refusal effect","content":"The form explains why “Complete purchase” is requested and what happens if it is not used.","open":true}],"annotations":[{"targetId":"neutral-2-body","text":"Fairer design: Keep contract acceptance distinct from optional marketing and partner permissions with unticked controls."},{"targetId":"neutral-5-disclosure","text":"Review prompt: Which fields or permissions are required, what happens on refusal, and does the resulting state support this criterion: “At least one consequence appears separable from the core function”?"}]},"whyItMatters":"The additional dependency controls access to the checkout goal. The panel states: “Purchase, newsletters and partner offers use one required checkbox.” Reviewers need to establish whether “Accept all terms and offers” is necessary for the selected task or pressures the user into a separable action. Refusing unrelated marketing appears to prevent completion of the requested transaction.","fairDesignPrinciple":"Keep contract acceptance distinct from optional marketing and partner permissions with unticked controls.","reviewPrompts":["What functional need makes “Accept all terms and offers” necessary for the ticket checkout goal, and can that need be met with less disclosure or commitment?","Which fields or permissions are required, what happens on refusal, and does the resulting state support this criterion: “At least one consequence appears separable from the core function”?","Could the stated purpose make this dependency genuinely necessary under the boundary “bundle with granular equivalent controls and no penalty for refusal”, and what product evidence would demonstrate that necessity?"],"altText":"Side-by-side ticket checkout interface showing “Agree to continue” and the clearer alternative “Confirm purchase terms”.","provenance":"Original hypothetical ticket checkout example created for this library; no real business, product or interface is depicted."}],"fairAlternative":"Separate distinct purposes, make optional uses genuinely optional, and provide an equally accessible refusal path.","whyProblematic":"Access is conditioned on accepting optional or separable data uses, communications or permissions as one bundled choice. Several distinct processing purposes are collapsed into one take-it-or-leave-it permission, so a person cannot accept necessary operation without optional uses. These harms describe a review risk, not an automatic legal conclusion. Australian section 28B commences on 1 July 2027 and requires its complete, context-specific test. Existing ACL provisions remain a separate current-law assessment.","contextFactors":["Multiple consequences or purposes are attached to one acceptance control.","At least one consequence appears separable from the core function.","Refusal blocks or materially burdens access.","Boundary to test: Single necessary processing operation clearly explained","Boundary to test: bundle with granular equivalent controls and no penalty for refusal"],"affectedTeams":["Product","Design","Engineering","Legal","Compliance"],"reviewQuestions":["What functional need makes “Accept everything” necessary for the news site entry goal, and can that need be met with less disclosure or commitment?","Capture every peer option, its default state and visual prominence; do those states support “Multiple consequences or purposes are attached to one acceptance control”?","Could the stated purpose make this dependency genuinely necessary under the boundary “Single necessary processing operation clearly explained”, and what product evidence would demonstrate that necessity?","What functional need makes “Accept all terms and offers” necessary for the ticket checkout goal, and can that need be met with less disclosure or commitment?","Which fields or permissions are required, what happens on refusal, and does the resulting state support this criterion: “At least one consequence appears separable from the core function”?","Could the stated purpose make this dependency genuinely necessary under the boundary “bundle with granular equivalent controls and no penalty for refusal”, and what product evidence would demonstrate that necessity?"],"evidence":["Annotated signup and checkout screenshots at each responsive breakpoint","The complete state sequence before, during and after the consumer decision","Design-system component, content, default and configuration records for the reviewed release","Operational records substantiating price, availability, timing and eligibility claims","Usability, accessibility, reversal, complaint and support evidence relevant to consumer impact","A dated product and legal review record identifying evidence, uncertainties and release decisions"],"related":["automatic-attention-capture","contact-harvesting-and-coerced-referrals","forced-disclosure-or-excessive-data-request","forced-registration-and-data-disclosure"],"sourceIds":["gray-ontology-dark-patterns-2024","eu-behavioural-study-digital-environment-2022","au-act-2026-64"],"altText":"Side-by-side news site entry interface showing “Accept and enter” and the clearer alternative “Choose data uses”.","provenance":"Original hypothetical interface comparisons from the shared learning library, adapted to Australian-dollar context for this portal; no real business, product or interface is depicted.","author":"Flowlane","datePublished":"2026-08-10","dateModified":"2026-09-14","lastReviewed":"2026-09-14","changeNote":"Source comparison recorded and the current status restated."},{"title":"Forced disclosure or excessive data request","slug":"forced-disclosure-or-excessive-data-request","preferredName":"Forced disclosure or excessive data request","directAnswer":"Forced disclosure or excessive data request is a working label for this design mechanism: Access or progression is conditioned on disclosing personal information that appears unnecessary, excessive or used for an insufficiently explained secondary purpose. This is editorial implementation guidance for Australian journeys, not a finding of unlawfulness. From 1 July 2027, a similar interface is relevant to ACL section 28B only if the complete consumer-connection, manipulation or unreasonable-distortion and actual-or-likely-detriment test is met. Current ACL rules require a separate assessment.","definition":"Access or progression is conditioned on disclosing personal information that appears unnecessary, excessive or used for an insufficiently explained secondary purpose. This is a design and research taxonomy for learning and evidence review, not a statutory offence label or an automatic finding that an interface is unlawful.","synonyms":["privacy zuckering","excessive data requests","forced communication","apparently unnecessary required field","sensitive data gate","secondary-use disclosure","tracking-for-access"],"category":"Forced action","family":"Forced action","journeyStages":["Pricing"],"jurisdiction":"Australia","status":"Editorial implementation guidance","howItWorks":"Access or progression is conditioned on disclosing personal information that appears unnecessary, excessive or used for an insufficiently explained secondary purpose. The interface makes apparently disproportionate personal information a prerequisite and withholds the selected result when a field or permission is refused.","warningSigns":["Personal data is mandatory or refusal blocks a desired goal.","Necessity is apparently unrelated, disproportionate or unexplained.","The requested data creates a plausible privacy or choice detriment."],"harms":["The visitor must disclose identity and contact information that is unrelated to a preliminary delivery-availability check.","The user may disclose more personal information than the preliminary comparison reasonably needs."],"legitimateUses":["Data evidently required for delivery, payment, security, age, safety or law","voluntary field with a clear skip path and purpose"],"legalBasis":[{"provision":"ACL section 28B, inserted by the 2026 Act","sourceIds":["au-act-2026-64"],"classification":"Possible risk indicator","explanation":"In pricing journeys, the forced disclosure or excessive data request mechanism may warrant review where it manipulates a consumer or unreasonably distorts the decision environment and causes, or is likely to cause, detriment. The forced action label and an interface similarity do not establish a contravention; the complete section 28B test, scope, facts and evidence must be applied from 1 July 2027."},{"provision":"Dark-pattern research taxonomy","sourceIds":["oecd-dark-commercial-patterns-2022"],"classification":"Editorial analysis","explanation":"The cited research sources support this working pattern within the forced action family. It is editorial implementation guidance, not an Australian statutory category, regulator finding or legal safe harbour."}],"examples":[{"type":"Illustrative example","context":"Exact birth date required for a delivery estimate","scenario":"A fictional furniture shop requires a visitor to disclose an exact birth date and mobile number before showing whether delivery is available to the entered postcode.","harm":"The visitor must disclose identity and contact information that is unrelated to a preliminary delivery-availability check."},{"type":"Illustrative example","context":"Excessive details for product comparison","scenario":"A fictional comparison tool requires occupation, exact birth date, mobile number and marketing preference before showing the plans that are available in a postcode.","harm":"The user may disclose more personal information than the preliminary comparison reasonably needs."}],"problematicUi":{"label":"Tell us who you are first","copy":"Tell us who you are first Birth date and mobile number block a postcode-based availability estimate. Exact date of birth Enter exact date of birth Mobile number Enter mobile number Delivery postcode Enter delivery postcode Submit personal details","annotations":["Why this state matters: The additional dependency controls access to the pricing goal. The panel states: “Birth date and mobile number block a postcode-based availability estimate.” Reviewers need to establish whether “Submit personal details” is necessary for the selected task or pressures the user into a separable action. The visitor must disclose identity and contact information that is unrelated to a preliminary delivery-availability check.","Review prompt: What functional need makes “Submit personal details” necessary for the furniture delivery estimate goal, and can that need be met with less disclosure or commitment?"]},"improvedUi":{"label":"Check delivery availability","copy":"Check delivery availability The estimate uses the postcode; contact details remain optional until booking. Delivery postcode Enter delivery postcode Show delivery estimate Purpose and refusal effect The form explains why “Show delivery estimate” is requested and what happens if it is not used.","annotations":["Fairer design: Use the postcode for the estimate, explain any genuinely necessary field and defer contact details until the visitor asks to book or save it.","Review prompt: Which fields or permissions are required, what happens on refusal, and does the resulting state support this criterion: “Personal data is mandatory or refusal blocks a desired goal”?"]},"uiComparisons":[{"id":"forced-disclosure-or-excessive-data-request-scenario-1","title":"Exact birth date required for a delivery estimate","context":"Furniture delivery estimate","journeyStage":"Pricing","summary":"A fictional furniture shop requires a visitor to disclose an exact birth date and mobile number before showing whether delivery is available to the entered postcode.","problematic":{"label":"Tell us who you are first","layout":"form","elements":[{"id":"problematic-1-heading","type":"heading","text":"Tell us who you are first"},{"id":"problematic-2-body","type":"text","text":"Birth date and mobile number block a postcode-based availability estimate.","tone":"warning"},{"id":"problematic-3-input","type":"input","label":"Exact date of birth","placeholder":"Enter exact date of birth"},{"id":"problematic-4-input","type":"input","label":"Mobile number","placeholder":"Enter mobile number"},{"id":"problematic-5-input","type":"input","label":"Delivery postcode","placeholder":"Enter delivery postcode"},{"id":"problematic-6-button","type":"button","text":"Submit personal details","emphasis":"primary"}],"annotations":[{"targetId":"problematic-2-body","text":"Why this state matters: The additional dependency controls access to the pricing goal. The panel states: “Birth date and mobile number block a postcode-based availability estimate.” Reviewers need to establish whether “Submit personal details” is necessary for the selected task or pressures the user into a separable action. The visitor must disclose identity and contact information that is unrelated to a preliminary delivery-availability check."},{"targetId":"problematic-6-button","text":"Review prompt: What functional need makes “Submit personal details” necessary for the furniture delivery estimate goal, and can that need be met with less disclosure or commitment?"}]},"neutral":{"label":"Check delivery availability","layout":"form","elements":[{"id":"neutral-1-heading","type":"heading","text":"Check delivery availability"},{"id":"neutral-2-body","type":"text","text":"The estimate uses the postcode; contact details remain optional until booking.","tone":"default"},{"id":"neutral-3-input","type":"input","label":"Delivery postcode","placeholder":"Enter delivery postcode"},{"id":"neutral-4-button","type":"button","text":"Show delivery estimate","emphasis":"secondary"},{"id":"neutral-5-disclosure","type":"disclosure","summary":"Purpose and refusal effect","content":"The form explains why “Show delivery estimate” is requested and what happens if it is not used.","open":true}],"annotations":[{"targetId":"neutral-2-body","text":"Fairer design: Use the postcode for the estimate, explain any genuinely necessary field and defer contact details until the visitor asks to book or save it."},{"targetId":"neutral-5-disclosure","text":"Review prompt: Which fields or permissions are required, what happens on refusal, and does the resulting state support this criterion: “Personal data is mandatory or refusal blocks a desired goal”?"}]},"whyItMatters":"The additional dependency controls access to the pricing goal. The panel states: “Birth date and mobile number block a postcode-based availability estimate.” Reviewers need to establish whether “Submit personal details” is necessary for the selected task or pressures the user into a separable action. The visitor must disclose identity and contact information that is unrelated to a preliminary delivery-availability check.","fairDesignPrinciple":"Use the postcode for the estimate, explain any genuinely necessary field and defer contact details until the visitor asks to book or save it.","reviewPrompts":["What functional need makes “Submit personal details” necessary for the furniture delivery estimate goal, and can that need be met with less disclosure or commitment?","Which fields or permissions are required, what happens on refusal, and does the resulting state support this criterion: “Personal data is mandatory or refusal blocks a desired goal”?","Could the stated purpose make this dependency genuinely necessary under the boundary “Data evidently required for delivery, payment, security, age, safety or law”, and what product evidence would demonstrate that necessity?"],"altText":"Side-by-side furniture delivery estimate interface showing “Tell us who you are first” and the clearer alternative “Check delivery availability”.","provenance":"Original hypothetical furniture delivery estimate example created for this library; no real business, product or interface is depicted."},{"id":"forced-disclosure-or-excessive-data-request-scenario-2","title":"Excessive details for product comparison","context":"Insurance comparison","journeyStage":"Pricing","summary":"A fictional comparison tool requires occupation, exact birth date, mobile number and marketing preference before showing the plans that are available in a postcode.","problematic":{"label":"Tell us everything first","layout":"form","elements":[{"id":"problematic-1-heading","type":"heading","text":"Tell us everything first"},{"id":"problematic-2-body","type":"text","text":"Four personal fields block access to a basic plan comparison.","tone":"warning"},{"id":"problematic-3-input","type":"input","label":"Occupation","placeholder":"Enter occupation"},{"id":"problematic-4-input","type":"input","label":"Exact date of birth","placeholder":"Enter exact date of birth"},{"id":"problematic-5-input","type":"input","label":"Mobile number","placeholder":"Enter mobile number"},{"id":"problematic-6-checkbox","type":"checkbox","label":"Receive comparison offers","checked":false},{"id":"problematic-7-button","type":"button","text":"Reveal plans","emphasis":"primary"}],"annotations":[{"targetId":"problematic-2-body","text":"Why this state matters: The additional dependency controls access to the pricing goal. The panel states: “Four personal fields block access to a basic plan comparison.” Reviewers need to establish whether “Reveal plans” is necessary for the selected task or pressures the user into a separable action. The user may disclose more personal information than the preliminary comparison reasonably needs."},{"targetId":"problematic-7-button","text":"Review prompt: What functional need makes “Reveal plans” necessary for the insurance comparison goal, and can that need be met with less disclosure or commitment?"}]},"neutral":{"label":"Compare available plans","layout":"form","elements":[{"id":"neutral-1-heading","type":"heading","text":"Compare available plans"},{"id":"neutral-2-body","type":"text","text":"Postcode and the minimum eligibility facts are requested with a reason.","tone":"default"},{"id":"neutral-3-input","type":"input","label":"Postcode","placeholder":"Enter postcode"},{"id":"neutral-4-input","type":"input","label":"Relevant eligibility facts","placeholder":"Enter relevant eligibility facts"},{"id":"neutral-5-button","type":"button","text":"Show plans","emphasis":"secondary"},{"id":"neutral-6-disclosure","type":"disclosure","summary":"Purpose and refusal effect","content":"The form explains why “Show plans” is requested and what happens if it is not used.","open":true}],"annotations":[{"targetId":"neutral-2-body","text":"Fairer design: Ask only for information needed for the comparison, explain why each field matters and defer contact details until the user requests follow-up."},{"targetId":"neutral-6-disclosure","text":"Review prompt: Which fields or permissions are required, what happens on refusal, and does the resulting state support this criterion: “Necessity is apparently unrelated, disproportionate or unexplained”?"}]},"whyItMatters":"The additional dependency controls access to the pricing goal. The panel states: “Four personal fields block access to a basic plan comparison.” Reviewers need to establish whether “Reveal plans” is necessary for the selected task or pressures the user into a separable action. The user may disclose more personal information than the preliminary comparison reasonably needs.","fairDesignPrinciple":"Ask only for information needed for the comparison, explain why each field matters and defer contact details until the user requests follow-up.","reviewPrompts":["What functional need makes “Reveal plans” necessary for the insurance comparison goal, and can that need be met with less disclosure or commitment?","Which fields or permissions are required, what happens on refusal, and does the resulting state support this criterion: “Necessity is apparently unrelated, disproportionate or unexplained”?","Could the stated purpose make this dependency genuinely necessary under the boundary “voluntary field with a clear skip path and purpose”, and what product evidence would demonstrate that necessity?"],"altText":"Side-by-side insurance comparison interface showing “Tell us everything first” and the clearer alternative “Compare available plans”.","provenance":"Original hypothetical insurance comparison example created for this library; no real business, product or interface is depicted."}],"fairAlternative":"Request only data necessary for the current goal, make secondary uses optional, and explain purpose and consequences clearly.","whyProblematic":"Access or progression is conditioned on disclosing personal information that appears unnecessary, excessive or used for an insufficiently explained secondary purpose. The interface makes apparently disproportionate personal information a prerequisite and withholds the selected result when a field or permission is refused. These harms describe a review risk, not an automatic legal conclusion. Australian section 28B commences on 1 July 2027 and requires its complete, context-specific test. Existing ACL provisions remain a separate current-law assessment.","contextFactors":["Personal data is mandatory or refusal blocks a desired goal.","Necessity is apparently unrelated, disproportionate or unexplained.","The requested data creates a plausible privacy or choice detriment.","Boundary to test: Data evidently required for delivery, payment, security, age, safety or law","Boundary to test: voluntary field with a clear skip path and purpose"],"affectedTeams":["Product","Design","Engineering","Legal","Compliance"],"reviewQuestions":["What functional need makes “Submit personal details” necessary for the furniture delivery estimate goal, and can that need be met with less disclosure or commitment?","Which fields or permissions are required, what happens on refusal, and does the resulting state support this criterion: “Personal data is mandatory or refusal blocks a desired goal”?","Could the stated purpose make this dependency genuinely necessary under the boundary “Data evidently required for delivery, payment, security, age, safety or law”, and what product evidence would demonstrate that necessity?","What functional need makes “Reveal plans” necessary for the insurance comparison goal, and can that need be met with less disclosure or commitment?","Which fields or permissions are required, what happens on refusal, and does the resulting state support this criterion: “Necessity is apparently unrelated, disproportionate or unexplained”?","Could the stated purpose make this dependency genuinely necessary under the boundary “voluntary field with a clear skip path and purpose”, and what product evidence would demonstrate that necessity?"],"evidence":["Annotated pricing screenshots at each responsive breakpoint","The complete state sequence before, during and after the consumer decision","Design-system component, content, default and configuration records for the reviewed release","Operational records substantiating price, availability, timing and eligibility claims","Usability, accessibility, reversal, complaint and support evidence relevant to consumer impact","A dated product and legal review record identifying evidence, uncertainties and release decisions"],"related":["automatic-attention-capture","contact-harvesting-and-coerced-referrals","forced-or-bundled-consent","forced-registration-and-data-disclosure"],"sourceIds":["oecd-dark-commercial-patterns-2022","au-act-2026-64"],"altText":"Side-by-side furniture delivery estimate interface showing “Tell us who you are first” and the clearer alternative “Check delivery availability”.","provenance":"Original hypothetical interface comparisons from the shared learning library, adapted to Australian-dollar context for this portal; no real business, product or interface is depicted.","author":"Flowlane","datePublished":"2026-08-10","dateModified":"2026-09-14","lastReviewed":"2026-09-14","changeNote":"Source comparison recorded and the current status restated."},{"title":"Forced registration","slug":"forced-registration-and-data-disclosure","preferredName":"Forced registration","directAnswer":"Forced registration is a working label for this design mechanism: The user must create an account, or is led to believe one is required, to complete a goal that could plausibly be provided without it. This is editorial implementation guidance for Australian journeys, not a finding of unlawfulness. From 1 July 2027, a similar interface is relevant to ACL section 28B only if the complete consumer-connection, manipulation or unreasonable-distortion and actual-or-likely-detriment test is met. Current ACL rules require a separate assessment.","definition":"The user must create an account, or is led to believe one is required, to complete a goal that could plausibly be provided without it. This is a design and research taxonomy for learning and evidence review, not a statutory offence label or an automatic finding that an interface is unlawful.","synonyms":["forced enrolment","forced enrollment","account required for purchase","registration presented as technically necessary","guest path withheld","forced registration","account wall","data gate","forced data disclosure","unnecessary sign-up","Forced registration and data disclosure"],"category":"Forced action","family":"Forced action","journeyStages":["Checkout","Pricing"],"jurisdiction":"Australia","status":"Commences 1 July 2027","howItWorks":"The user must create an account, or is led to believe one is required, to complete a goal that could plausibly be provided without it. The gate converts an otherwise available task into account creation, so the user must create a persistent identity record before reaching the requested outcome.","warningSigns":["A desired goal is gated by account creation.","No equivalent guest or bypass route is available or discoverable.","Registration is not evidently necessary for the specific function."],"harms":["A shopper may surrender unnecessary information or abandon a purchase after investing time in the basket.","People cannot compare the offer without creating an identity record and may receive communications they did not seek."],"legitimateUses":["Account creation that is inherently necessary for persistent account functionality","legally or operationally necessary identity verification with clear explanation"],"legalBasis":[{"provision":"ACL section 28B(2), inserted by the 2026 Act","sourceIds":["au-act-2026-64"],"classification":"Possible risk indicator","explanation":"Potentially applies when the gate forms part of manipulative or unreasonably distorting conduct and likely detriment results."},{"provision":"ACL section 28B(6)(d), inserted by the 2026 Act","sourceIds":["au-act-2026-64"],"classification":"Possible risk indicator","explanation":"Offers a non-exhaustive example involving unreasonable obstruction of making or fulfilling a decision."}],"examples":[{"type":"Illustrative example","context":"Account wall at guest checkout","scenario":"A fictional retailer removes guest checkout after an item is added and requires a full account, date of birth and saved password before payment can continue.","harm":"A shopper may surrender unnecessary information or abandon a purchase after investing time in the basket."},{"type":"Illustrative example","context":"Profile required before price estimate","scenario":"A fictional repair service asks visitors to create a profile and verify a phone number before it reveals even an indicative service price.","harm":"People cannot compare the offer without creating an identity record and may receive communications they did not seek."}],"problematicUi":{"label":"Create an account to continue","copy":"Create an account to continue No guest route is shown after the basket has been prepared. Email address Enter email address Date of birth Enter date of birth Password Enter password Register and save my details","annotations":["Why this state matters: The additional dependency controls access to the checkout goal. The panel states: “No guest route is shown after the basket has been prepared.” Reviewers need to establish whether “Register and save my details” is necessary for the selected task or pressures the user into a separable action. A shopper may surrender unnecessary information or abandon a purchase after investing time in the basket.","Review prompt: What functional need makes “Register and save my details” necessary for the online retail checkout goal, and can that need be met with less disclosure or commitment?"]},"improvedUi":{"label":"Choose how to check out","copy":"Choose how to check out Guest checkout and optional account creation are presented together. Delivery email Enter delivery email Continue as guest Purpose and refusal effect The form explains why “Continue as guest” is requested and what happens if it is not used.","annotations":["Fairer design: Keep a clearly labelled guest route beside account creation and request only delivery and payment data needed for the order.","Review prompt: Which fields or permissions are required, what happens on refusal, and does the resulting state support this criterion: “A desired goal is gated by account creation”?"]},"uiComparisons":[{"id":"forced-registration-scenario-1","title":"Account wall at guest checkout","context":"Online retail checkout","journeyStage":"Checkout","summary":"A fictional retailer removes guest checkout after an item is added and requires a full account, date of birth and saved password before payment can continue.","problematic":{"label":"Create an account to continue","layout":"form","elements":[{"id":"problematic-1-heading","type":"heading","text":"Create an account to continue"},{"id":"problematic-2-body","type":"text","text":"No guest route is shown after the basket has been prepared.","tone":"warning"},{"id":"problematic-3-input","type":"input","label":"Email address","placeholder":"Enter email address"},{"id":"problematic-4-input","type":"input","label":"Date of birth","placeholder":"Enter date of birth"},{"id":"problematic-5-input","type":"input","label":"Password","placeholder":"Enter password"},{"id":"problematic-6-button","type":"button","text":"Register and save my details","emphasis":"primary"}],"annotations":[{"targetId":"problematic-2-body","text":"Why this state matters: The additional dependency controls access to the checkout goal. The panel states: “No guest route is shown after the basket has been prepared.” Reviewers need to establish whether “Register and save my details” is necessary for the selected task or pressures the user into a separable action. A shopper may surrender unnecessary information or abandon a purchase after investing time in the basket."},{"targetId":"problematic-6-button","text":"Review prompt: What functional need makes “Register and save my details” necessary for the online retail checkout goal, and can that need be met with less disclosure or commitment?"}]},"neutral":{"label":"Choose how to check out","layout":"form","elements":[{"id":"neutral-1-heading","type":"heading","text":"Choose how to check out"},{"id":"neutral-2-body","type":"text","text":"Guest checkout and optional account creation are presented together.","tone":"default"},{"id":"neutral-3-input","type":"input","label":"Delivery email","placeholder":"Enter delivery email"},{"id":"neutral-4-button","type":"button","text":"Continue as guest","emphasis":"secondary"},{"id":"neutral-5-disclosure","type":"disclosure","summary":"Purpose and refusal effect","content":"The form explains why “Continue as guest” is requested and what happens if it is not used.","open":true}],"annotations":[{"targetId":"neutral-2-body","text":"Fairer design: Keep a clearly labelled guest route beside account creation and request only delivery and payment data needed for the order."},{"targetId":"neutral-5-disclosure","text":"Review prompt: Which fields or permissions are required, what happens on refusal, and does the resulting state support this criterion: “A desired goal is gated by account creation”?"}]},"whyItMatters":"The additional dependency controls access to the checkout goal. The panel states: “No guest route is shown after the basket has been prepared.” Reviewers need to establish whether “Register and save my details” is necessary for the selected task or pressures the user into a separable action. A shopper may surrender unnecessary information or abandon a purchase after investing time in the basket.","fairDesignPrinciple":"Keep a clearly labelled guest route beside account creation and request only delivery and payment data needed for the order.","reviewPrompts":["What functional need makes “Register and save my details” necessary for the online retail checkout goal, and can that need be met with less disclosure or commitment?","Which fields or permissions are required, what happens on refusal, and does the resulting state support this criterion: “A desired goal is gated by account creation”?","Could the stated purpose make this dependency genuinely necessary under the boundary “Account creation that is inherently necessary for persistent account functionality”, and what product evidence would demonstrate that necessity?"],"altText":"Side-by-side online retail checkout interface showing “Create an account to continue” and the clearer alternative “Choose how to check out”.","provenance":"Original hypothetical online retail checkout example created for this library; no real business, product or interface is depicted."},{"id":"forced-registration-scenario-2","title":"Profile required before price estimate","context":"Home-services quote","journeyStage":"Pricing","summary":"A fictional repair service asks visitors to create a profile and verify a phone number before it reveals even an indicative service price.","problematic":{"label":"Unlock your estimate","layout":"form","elements":[{"id":"problematic-1-heading","type":"heading","text":"Unlock your estimate"},{"id":"problematic-2-body","type":"text","text":"Name, phone, birth date and password are required before any price appears.","tone":"warning"},{"id":"problematic-3-input","type":"input","label":"Full name","placeholder":"Enter full name"},{"id":"problematic-4-input","type":"input","label":"Mobile number","placeholder":"Enter mobile number"},{"id":"problematic-5-input","type":"input","label":"Date of birth","placeholder":"Enter date of birth"},{"id":"problematic-6-input","type":"input","label":"Password","placeholder":"Enter password"},{"id":"problematic-7-button","type":"button","text":"Create profile","emphasis":"primary"}],"annotations":[{"targetId":"problematic-2-body","text":"Why this state matters: The additional dependency controls access to the pricing goal. The panel states: “Name, phone, birth date and password are required before any price appears.” Reviewers need to establish whether “Create profile” is necessary for the selected task or pressures the user into a separable action. People cannot compare the offer without creating an identity record and may receive communications they did not seek."},{"targetId":"problematic-7-button","text":"Review prompt: What functional need makes “Create profile” necessary for the home-services quote goal, and can that need be met with less disclosure or commitment?"}]},"neutral":{"label":"Estimated service price","layout":"form","elements":[{"id":"neutral-1-heading","type":"heading","text":"Estimated service price"},{"id":"neutral-2-body","type":"text","text":"The indicative range and assumptions appear before optional saving or booking.","tone":"default"},{"id":"neutral-3-input","type":"input","label":"Service postcode","placeholder":"Enter service postcode"},{"id":"neutral-4-button","type":"button","text":"View estimate without an account","emphasis":"secondary"},{"id":"neutral-5-disclosure","type":"disclosure","summary":"Purpose and refusal effect","content":"The form explains why “View estimate without an account” is requested and what happens if it is not used.","open":true}],"annotations":[{"targetId":"neutral-2-body","text":"Fairer design: Show the estimate and its assumptions first, then offer account creation only when it is needed to book or save the quote."},{"targetId":"neutral-5-disclosure","text":"Review prompt: Which fields or permissions are required, what happens on refusal, and does the resulting state support this criterion: “No equivalent guest or bypass route is available or discoverable”?"}]},"whyItMatters":"The additional dependency controls access to the pricing goal. The panel states: “Name, phone, birth date and password are required before any price appears.” Reviewers need to establish whether “Create profile” is necessary for the selected task or pressures the user into a separable action. People cannot compare the offer without creating an identity record and may receive communications they did not seek.","fairDesignPrinciple":"Show the estimate and its assumptions first, then offer account creation only when it is needed to book or save the quote.","reviewPrompts":["What functional need makes “Create profile” necessary for the home-services quote goal, and can that need be met with less disclosure or commitment?","Which fields or permissions are required, what happens on refusal, and does the resulting state support this criterion: “No equivalent guest or bypass route is available or discoverable”?","Could the stated purpose make this dependency genuinely necessary under the boundary “legally or operationally necessary identity verification with clear explanation”, and what product evidence would demonstrate that necessity?"],"altText":"Side-by-side home-services quote interface showing “Unlock your estimate” and the clearer alternative “Estimated service price”.","provenance":"Original hypothetical home-services quote example created for this library; no real business, product or interface is depicted."}],"fairAlternative":"Provide a clearly visible guest or no-account path unless registration is genuinely necessary, and explain necessity before collecting data.","whyProblematic":"The user must create an account, or is led to believe one is required, to complete a goal that could plausibly be provided without it. The gate converts an otherwise available task into account creation, so the user must create a persistent identity record before reaching the requested outcome. Apply section 28B(2) to the whole journey. Section 28B(6)(d)'s obstruction example may be relevant where a gate makes a decision or its fulfilment disproportionately difficult. The Act does not say that every registration requirement is unreasonable or unnecessary. Existing misleading-conduct, privacy and sector-specific rules may apply depending on the representation and data involved; this record does not determine those regimes. No final ACCC section 28B guidance addressing account walls had been identified by the review date.","contextFactors":["A desired goal is gated by account creation.","No equivalent guest or bypass route is available or discoverable.","Registration is not evidently necessary for the specific function.","Boundary to test: Account creation that is inherently necessary for persistent account functionality","Boundary to test: legally or operationally necessary identity verification with clear explanation","Why is an account or each requested field operationally necessary?","Can the transaction be completed as a guest?","Is the gate imposed before the consumer can see price or material terms?","Does a registration step enrol the consumer in anything beyond the requested transaction?","Can support, returns or cancellation be accessed without creating a new account?","What non-financial detriment or abandoned effort could result?"],"affectedTeams":["Product","Design","Engineering","Privacy","Legal","Customer Support","Marketing"],"reviewQuestions":["What functional need makes “Register and save my details” necessary for the online retail checkout goal, and can that need be met with less disclosure or commitment?","Which fields or permissions are required, what happens on refusal, and does the resulting state support this criterion: “A desired goal is gated by account creation”?","Could the stated purpose make this dependency genuinely necessary under the boundary “Account creation that is inherently necessary for persistent account functionality”, and what product evidence would demonstrate that necessity?","What functional need makes “Create profile” necessary for the home-services quote goal, and can that need be met with less disclosure or commitment?","Which fields or permissions are required, what happens on refusal, and does the resulting state support this criterion: “No equivalent guest or bypass route is available or discoverable”?","Could the stated purpose make this dependency genuinely necessary under the boundary “legally or operationally necessary identity verification with clear explanation”, and what product evidence would demonstrate that necessity?","Can the operational owner explain why every required field is needed at this exact stage?","What material information is unavailable until after registration?","Are marketing choices genuinely optional and separate?","Can a guest purchaser obtain support, return or cancel without creating an account?","Does the same outcome require fewer steps through another channel?"],"evidence":["field-by-field necessity register","journey map for guest and account users","consent and copy approvals","data-flow diagram and retention decision","support and cancellation test scripts","abandonment and complaint analysis","Annotated checkout and pricing screenshots at each responsive breakpoint","The complete state sequence before, during and after the consumer decision","Design-system component, content, default and configuration records for the reviewed release","Operational records substantiating price, availability, timing and eligibility claims","Usability, accessibility, reversal, complaint and support evidence relevant to consumer impact","A dated product and legal review record identifying evidence, uncertainties and release decisions"],"related":["automatic-attention-capture","contact-harvesting-and-coerced-referrals","forced-disclosure-or-excessive-data-request","forced-or-bundled-consent"],"sourceIds":["oecd-dark-commercial-patterns-2022","au-act-2026-64","au-acl-2010","au-accc-priorities-2026"],"altText":"Side-by-side online retail checkout interface showing “Create an account to continue” and the clearer alternative “Choose how to check out”.","provenance":"Original hypothetical interface comparisons from the shared learning library, adapted to Australian-dollar context for this portal; no real business, product or interface is depicted.","author":"Flowlane","datePublished":"2026-08-09","dateModified":"2026-09-14","lastReviewed":"2026-09-14","changeNote":"Source comparison recorded and the current status restated."},{"title":"Gamified or paid access coercion","slug":"gamified-or-paid-access-coercion","preferredName":"Gamified or paid access coercion","directAnswer":"Gamified or paid access coercion is a working label for this design mechanism: Desired functionality is practically conditioned on repetitive engagement or an additional payment not sufficiently clear at acquisition. This is editorial implementation guidance for Australian journeys, not a finding of unlawfulness. From 1 July 2027, a similar interface is relevant to ACL section 28B only if the complete consumer-connection, manipulation or unreasonable-distortion and actual-or-likely-detriment test is met. Current ACL rules require a separate assessment.","definition":"Desired functionality is practically conditioned on repetitive engagement or an additional payment not sufficiently clear at acquisition. This is a design and research taxonomy for learning and evidence review, not a statutory offence label or an automatic finding that an interface is unlawful.","synonyms":["gamification","grinding","pay-to-play","repetitive grinding","paid bypass","function withheld after acquisition","daily-streak access"],"category":"Forced action","family":"Forced action","journeyStages":["Account Management"],"jurisdiction":"Australia","status":"Editorial implementation guidance","howItWorks":"Desired functionality is practically conditioned on repetitive engagement or an additional payment not sufficiently clear at acquisition. A purchased or expected function is placed behind extra play, streak, points or payment mechanics that were not part of the user’s original access decision.","warningSigns":["A concrete function is withheld or made impractical.","Repeated labour or additional payment is the effective unlock route.","The condition was unexpected, disproportionate or insufficiently disclosed."],"harms":["Players may pay twice or spend unplanned time to reach content they reasonably understood was included.","Learners may be forced into additional engagement or lose a completion record they already earned."],"legitimateUses":["Ordinary progression intrinsic to a game and transparently described","clearly disclosed optional cosmetic purchases"],"legalBasis":[{"provision":"ACL section 28B, inserted by the 2026 Act","sourceIds":["au-act-2026-64"],"classification":"Possible risk indicator","explanation":"In account management journeys, the gamified or paid access coercion mechanism may warrant review where it manipulates a consumer or unreasonably distorts the decision environment and causes, or is likely to cause, detriment. The forced action label and an interface similarity do not establish a contravention; the complete section 28B test, scope, facts and evidence must be applied from 1 July 2027."},{"provision":"Dark-pattern research taxonomy","sourceIds":["oecd-dark-commercial-patterns-2022"],"classification":"Editorial analysis","explanation":"The cited research sources support this working pattern within the forced action family. It is editorial implementation guidance, not an Australian statutory category, regulator finding or legal safe harbour."}],"examples":[{"type":"Illustrative example","context":"Energy gate before a purchased level","scenario":"A fictional game sells a chapter pass but requires hours of repetitive daily tasks or another payment before the purchased final level becomes playable.","harm":"Players may pay twice or spend unplanned time to reach content they reasonably understood was included."},{"type":"Illustrative example","context":"Reward loop required for document export","scenario":"A fictional study service makes certificate export depend on completing seven daily streak tasks that were not disclosed when the course was bought.","harm":"Learners may be forced into additional engagement or lose a completion record they already earned."}],"problematicUi":{"label":"Chapter pass · $12","copy":"Chapter pass · $12 The final level also needs 4,000 energy points or a $6 boost. Displayed amount $6 Unlock boost $6 Play purchased level","annotations":["Why this state matters: The additional dependency controls access to the account management goal. The panel states: “The final level also needs 4,000 energy points or a $6 boost.” Reviewers need to establish whether “Unlock boost $6” is necessary for the selected task or pressures the user into a separable action. Players may pay twice or spend unplanned time to reach content they reasonably understood was included.","Review prompt: What functional need makes “Unlock boost $6” necessary for the mobile game goal, and can that need be met with less disclosure or commitment?"]},"improvedUi":{"label":"Complete chapter access · $12","copy":"Complete chapter access · $12 All purchased levels are available; optional challenges are labelled separately. Play purchased level Unlock boost $6 Price, period and commitment The price and material terms associated with “Play purchased level” remain beside this choice.","annotations":["Fairer design: State the access conditions before purchase and provide a direct route to purchased content without undisclosed grinding or another charge.","Review prompt: Place the compared prices, billing periods and material terms on one evidence sheet; where does it support “A concrete function is withheld or made impractical”?"]},"uiComparisons":[{"id":"gamified-or-paid-access-coercion-scenario-1","title":"Energy gate before a purchased level","context":"Mobile game","journeyStage":"Account Management","summary":"A fictional game sells a chapter pass but requires hours of repetitive daily tasks or another payment before the purchased final level becomes playable.","problematic":{"label":"Chapter pass · $12","layout":"pricing-card","elements":[{"id":"problematic-1-heading","type":"heading","text":"Chapter pass · $12"},{"id":"problematic-2-body","type":"text","text":"The final level also needs 4,000 energy points or a $6 boost.","tone":"warning"},{"id":"problematic-3-price","type":"price","label":"Displayed amount","amount":"$6"},{"id":"problematic-4-button","type":"button","text":"Unlock boost $6","emphasis":"primary"},{"id":"problematic-5-link","type":"link","text":"Play purchased level","emphasis":"subtle"}],"annotations":[{"targetId":"problematic-2-body","text":"Why this state matters: The additional dependency controls access to the account management goal. The panel states: “The final level also needs 4,000 energy points or a $6 boost.” Reviewers need to establish whether “Unlock boost $6” is necessary for the selected task or pressures the user into a separable action. Players may pay twice or spend unplanned time to reach content they reasonably understood was included."},{"targetId":"problematic-5-link","text":"Review prompt: What functional need makes “Unlock boost $6” necessary for the mobile game goal, and can that need be met with less disclosure or commitment?"}]},"neutral":{"label":"Complete chapter access · $12","layout":"pricing-card","elements":[{"id":"neutral-1-heading","type":"heading","text":"Complete chapter access · $12"},{"id":"neutral-2-body","type":"text","text":"All purchased levels are available; optional challenges are labelled separately.","tone":"default"},{"id":"neutral-3-button","type":"button","text":"Play purchased level","emphasis":"secondary"},{"id":"neutral-4-link","type":"link","text":"Unlock boost $6","emphasis":"default"},{"id":"neutral-5-disclosure","type":"disclosure","summary":"Price, period and commitment","content":"The price and material terms associated with “Play purchased level” remain beside this choice.","open":true}],"annotations":[{"targetId":"neutral-2-body","text":"Fairer design: State the access conditions before purchase and provide a direct route to purchased content without undisclosed grinding or another charge."},{"targetId":"neutral-5-disclosure","text":"Review prompt: Place the compared prices, billing periods and material terms on one evidence sheet; where does it support “A concrete function is withheld or made impractical”?"}]},"whyItMatters":"The additional dependency controls access to the account management goal. The panel states: “The final level also needs 4,000 energy points or a $6 boost.” Reviewers need to establish whether “Unlock boost $6” is necessary for the selected task or pressures the user into a separable action. Players may pay twice or spend unplanned time to reach content they reasonably understood was included.","fairDesignPrinciple":"State the access conditions before purchase and provide a direct route to purchased content without undisclosed grinding or another charge.","reviewPrompts":["What functional need makes “Unlock boost $6” necessary for the mobile game goal, and can that need be met with less disclosure or commitment?","Place the compared prices, billing periods and material terms on one evidence sheet; where does it support “A concrete function is withheld or made impractical”?","Could the stated purpose make this dependency genuinely necessary under the boundary “Ordinary progression intrinsic to a game and transparently described”, and what product evidence would demonstrate that necessity?"],"altText":"Side-by-side mobile game interface showing “Chapter pass · $12” and the clearer alternative “Complete chapter access · $12”.","provenance":"Original hypothetical mobile game example created for this library; no real business, product or interface is depicted."},{"id":"gamified-or-paid-access-coercion-scenario-2","title":"Reward loop required for document export","context":"Learning platform","journeyStage":"Account Management","summary":"A fictional study service makes certificate export depend on completing seven daily streak tasks that were not disclosed when the course was bought.","problematic":{"label":"Keep the streak to export","layout":"account-panel","elements":[{"id":"problematic-1-heading","type":"heading","text":"Keep the streak to export"},{"id":"problematic-2-body","type":"text","text":"Seven more daily tasks are required before the certificate link activates.","tone":"warning"},{"id":"problematic-3-link","type":"link","text":"Return tomorrow","emphasis":"subtle"},{"id":"problematic-4-badge","type":"badge","text":"Unconfirmed state: Return tomorrow","tone":"warning"}],"annotations":[{"targetId":"problematic-2-body","text":"Why this state matters: The additional dependency controls access to the account management goal. The panel states: “Seven more daily tasks are required before the certificate link activates.” Reviewers need to establish whether “Return tomorrow” is necessary for the selected task or pressures the user into a separable action. Learners may be forced into additional engagement or lose a completion record they already earned."},{"targetId":"problematic-4-badge","text":"Review prompt: What functional need makes “Return tomorrow” necessary for the learning platform goal, and can that need be met with less disclosure or commitment?"}]},"neutral":{"label":"Your certificate is ready","layout":"account-panel","elements":[{"id":"neutral-1-heading","type":"heading","text":"Your certificate is ready"},{"id":"neutral-2-body","type":"text","text":"Course completion unlocks export immediately; practice streaks remain optional.","tone":"default"},{"id":"neutral-3-link","type":"link","text":"Download certificate","emphasis":"default"},{"id":"neutral-4-badge","type":"badge","text":"Saved state: Download certificate","tone":"default"},{"id":"neutral-5-disclosure","type":"disclosure","summary":"Persisted account state","content":"The saved state behind “Download certificate” remains consistent after refresh and across supported channels.","open":true}],"annotations":[{"targetId":"neutral-2-body","text":"Fairer design: Provide the earned certificate directly and present streak activities as optional learning support."},{"targetId":"neutral-5-disclosure","text":"Review prompt: Test the control across refresh, device and account states; is “Repeated labour or additional payment is the effective unlock route” still observable after persistence is considered?"}]},"whyItMatters":"The additional dependency controls access to the account management goal. The panel states: “Seven more daily tasks are required before the certificate link activates.” Reviewers need to establish whether “Return tomorrow” is necessary for the selected task or pressures the user into a separable action. Learners may be forced into additional engagement or lose a completion record they already earned.","fairDesignPrinciple":"Provide the earned certificate directly and present streak activities as optional learning support.","reviewPrompts":["What functional need makes “Return tomorrow” necessary for the learning platform goal, and can that need be met with less disclosure or commitment?","Test the control across refresh, device and account states; is “Repeated labour or additional payment is the effective unlock route” still observable after persistence is considered?","Could the stated purpose make this dependency genuinely necessary under the boundary “clearly disclosed optional cosmetic purchases”, and what product evidence would demonstrate that necessity?"],"altText":"Side-by-side learning platform interface showing “Keep the streak to export” and the clearer alternative “Your certificate is ready”.","provenance":"Original hypothetical learning platform example created for this library; no real business, product or interface is depicted."}],"fairAlternative":"Disclose access conditions before acquisition and avoid making disproportionate repetition or surprise payment the practical path to expected functionality.","whyProblematic":"Desired functionality is practically conditioned on repetitive engagement or an additional payment not sufficiently clear at acquisition. A purchased or expected function is placed behind extra play, streak, points or payment mechanics that were not part of the user’s original access decision. These harms describe a review risk, not an automatic legal conclusion. Australian section 28B commences on 1 July 2027 and requires its complete, context-specific test. Existing ACL provisions remain a separate current-law assessment.","contextFactors":["A concrete function is withheld or made impractical.","Repeated labour or additional payment is the effective unlock route.","The condition was unexpected, disproportionate or insufficiently disclosed.","Boundary to test: Ordinary progression intrinsic to a game and transparently described","Boundary to test: clearly disclosed optional cosmetic purchases"],"affectedTeams":["Product","Design","Engineering","Legal","Compliance"],"reviewQuestions":["What functional need makes “Unlock boost $6” necessary for the mobile game goal, and can that need be met with less disclosure or commitment?","Place the compared prices, billing periods and material terms on one evidence sheet; where does it support “A concrete function is withheld or made impractical”?","Could the stated purpose make this dependency genuinely necessary under the boundary “Ordinary progression intrinsic to a game and transparently described”, and what product evidence would demonstrate that necessity?","What functional need makes “Return tomorrow” necessary for the learning platform goal, and can that need be met with less disclosure or commitment?","Test the control across refresh, device and account states; is “Repeated labour or additional payment is the effective unlock route” still observable after persistence is considered?","Could the stated purpose make this dependency genuinely necessary under the boundary “clearly disclosed optional cosmetic purchases”, and what product evidence would demonstrate that necessity?"],"evidence":["Annotated account management screenshots at each responsive breakpoint","The complete state sequence before, during and after the consumer decision","Design-system component, content, default and configuration records for the reviewed release","Operational records substantiating price, availability, timing and eligibility claims","Usability, accessibility, reversal, complaint and support evidence relevant to consumer impact","A dated product and legal review record identifying evidence, uncertainties and release decisions"],"related":["automatic-attention-capture","contact-harvesting-and-coerced-referrals","forced-disclosure-or-excessive-data-request","forced-or-bundled-consent"],"sourceIds":["oecd-dark-commercial-patterns-2022","au-act-2026-64"],"altText":"Side-by-side mobile game interface showing “Chapter pass · $12” and the clearer alternative “Complete chapter access · $12”.","provenance":"Original hypothetical interface comparisons from the shared learning library, adapted to Australian-dollar context for this portal; no real business, product or interface is depicted.","author":"Flowlane","datePublished":"2026-08-10","dateModified":"2026-09-14","lastReviewed":"2026-09-14","changeNote":"Source comparison recorded and the current status restated."},{"title":"Bundled options","slug":"bundled-options","preferredName":"Bundled options","directAnswer":"Bundled options is a working label for this design mechanism: Distinct products, services, permissions or purposes are grouped under one choice so the user cannot readily understand or select them separately. This is editorial implementation guidance for Australian journeys, not a finding of unlawfulness. From 1 July 2027, a similar interface is relevant to ACL section 28B only if the complete consumer-connection, manipulation or unreasonable-distortion and actual-or-likely-detriment test is met. Current ACL rules require a separate assessment.","definition":"Distinct products, services, permissions or purposes are grouped under one choice so the user cannot readily understand or select them separately. This is a design and research taxonomy for learning and evidence review, not a statutory offence label or an automatic finding that an interface is unlawful.","synonyms":["bundling","bundle default","combined choice","products grouped without component choice","permissions under one switch","unbundled price hidden","multiple marketing channels under one control"],"category":"Interface interference","family":"Interface interference","journeyStages":["Checkout","Pricing"],"jurisdiction":"Australia","status":"Editorial implementation guidance","howItWorks":"Distinct products, services, permissions or purposes are grouped under one choice so the user cannot readily understand or select them separately. Distinct products or services are packaged behind one selection even though their separate price, function or necessity matters to the choice.","warningSigns":["One control has two or more separable consequences.","Component choices or prices are absent, hidden or materially harder.","The bundle favours a business outcome or adds cost, data use or commitment."],"harms":["A customer may pay for an unwanted component because two distinct products are presented as one indivisible choice.","A buyer may pay for unwanted services or misunderstand which components are optional."],"legitimateUses":["Genuinely indivisible product","transparent bundle with equally accessible component options and prices"],"legalBasis":[{"provision":"ACL section 28B, inserted by the 2026 Act","sourceIds":["au-act-2026-64"],"classification":"Possible risk indicator","explanation":"In checkout and pricing journeys, the bundled options mechanism may warrant review where it manipulates a consumer or unreasonably distorts the decision environment and causes, or is likely to cause, detriment. The interface interference label and an interface similarity do not establish a contravention; the complete section 28B test, scope, facts and evidence must be applied from 1 July 2027."},{"provision":"Dark-pattern research taxonomy","sourceIds":["gray-ontology-dark-patterns-2024","eu-behavioural-study-digital-environment-2022"],"classification":"Editorial analysis","explanation":"The cited research sources support this working pattern within the interface interference family. It is editorial implementation guidance, not an Australian statutory category, regulator finding or legal safe harbour."}],"examples":[{"type":"Illustrative example","context":"Ticket and travel pass presented as one package","scenario":"A fictional ticket seller offers a concert ticket only through a control that also adds a city travel pass, although the travel component is separately deliverable and not required for entry.","harm":"A customer may pay for an unwanted component because two distinct products are presented as one indivisible choice."},{"type":"Illustrative example","context":"Support and migration locked into one plan","scenario":"A fictional service offers a core plan only as a bundle with premium support and data migration, while implying those extras can be removed later although no controls exist.","harm":"A buyer may pay for unwanted services or misunderstand which components are optional."}],"problematicUi":{"label":"Ticket plus city travel","copy":"Ticket plus city travel The only visible selection combines entry and an optional transport product. Choose package $78 Choose ticket only $65","annotations":["Why this state matters: The presentation changes what the user can notice or predict at the checkout decision. The problematic state shows: “The only visible selection combines entry and an optional transport product.” Its influence should be tested by comparing the consequence and usability of “Choose package $78” with “Choose ticket only $65”. A customer may pay for an unwanted component because two distinct products are presented as one indivisible choice.","Review prompt: Do “Choose package $78” and “Choose ticket only $65” receive comparable prominence and explain their consequences before activation?"]},"improvedUi":{"label":"Build your booking","copy":"Build your booking The $65 ticket and optional $13 travel pass have separate controls. Choose ticket only $65 Choose package $78 Choice consequences The consequence of selecting “Choose ticket only $65” is displayed beside the option.","annotations":["Fairer design: Show the event ticket and optional travel pass as separately priced selections before the basket changes.","Review prompt: Capture every peer option, its default state and visual prominence; do those states support “One control has two or more separable consequences”?"]},"uiComparisons":[{"id":"bundled-options-scenario-1","title":"Ticket and travel pass presented as one package","context":"Event booking","journeyStage":"Checkout","summary":"A fictional ticket seller offers a concert ticket only through a control that also adds a city travel pass, although the travel component is separately deliverable and not required for entry.","problematic":{"label":"Ticket plus city travel","layout":"choice-list","elements":[{"id":"problematic-1-heading","type":"heading","text":"Ticket plus city travel"},{"id":"problematic-2-body","type":"text","text":"The only visible selection combines entry and an optional transport product.","tone":"warning"},{"id":"problematic-3-radio","type":"radio","label":"Choose package $78","checked":true},{"id":"problematic-4-radio","type":"radio","label":"Choose ticket only $65","checked":false}],"annotations":[{"targetId":"problematic-2-body","text":"Why this state matters: The presentation changes what the user can notice or predict at the checkout decision. The problematic state shows: “The only visible selection combines entry and an optional transport product.” Its influence should be tested by comparing the consequence and usability of “Choose package $78” with “Choose ticket only $65”. A customer may pay for an unwanted component because two distinct products are presented as one indivisible choice."},{"targetId":"problematic-4-radio","text":"Review prompt: Do “Choose package $78” and “Choose ticket only $65” receive comparable prominence and explain their consequences before activation?"}]},"neutral":{"label":"Build your booking","layout":"choice-list","elements":[{"id":"neutral-1-heading","type":"heading","text":"Build your booking"},{"id":"neutral-2-body","type":"text","text":"The $65 ticket and optional $13 travel pass have separate controls.","tone":"default"},{"id":"neutral-3-radio","type":"radio","label":"Choose ticket only $65","checked":false},{"id":"neutral-4-radio","type":"radio","label":"Choose package $78","checked":false},{"id":"neutral-5-disclosure","type":"disclosure","summary":"Choice consequences","content":"The consequence of selecting “Choose ticket only $65” is displayed beside the option.","open":true}],"annotations":[{"targetId":"neutral-2-body","text":"Fairer design: Show the event ticket and optional travel pass as separately priced selections before the basket changes."},{"targetId":"neutral-5-disclosure","text":"Review prompt: Capture every peer option, its default state and visual prominence; do those states support “One control has two or more separable consequences”?"}]},"whyItMatters":"The presentation changes what the user can notice or predict at the checkout decision. The problematic state shows: “The only visible selection combines entry and an optional transport product.” Its influence should be tested by comparing the consequence and usability of “Choose package $78” with “Choose ticket only $65”. A customer may pay for an unwanted component because two distinct products are presented as one indivisible choice.","fairDesignPrinciple":"Show the event ticket and optional travel pass as separately priced selections before the basket changes.","reviewPrompts":["Do “Choose package $78” and “Choose ticket only $65” receive comparable prominence and explain their consequences before activation?","Capture every peer option, its default state and visual prominence; do those states support “One control has two or more separable consequences”?","What neutral rendering or comprehension result would falsify the classification, particularly in light of “Genuinely indivisible product”?"],"altText":"Side-by-side event booking interface showing “Ticket plus city travel” and the clearer alternative “Build your booking”.","provenance":"Original hypothetical event booking example created for this library; no real business, product or interface is depicted."},{"id":"bundled-options-scenario-2","title":"Support and migration locked into one plan","context":"Business software pricing","journeyStage":"Pricing","summary":"A fictional service offers a core plan only as a bundle with premium support and data migration, while implying those extras can be removed later although no controls exist.","problematic":{"label":"Complete launch bundle","layout":"pricing-card","elements":[{"id":"problematic-1-heading","type":"heading","text":"Complete launch bundle"},{"id":"problematic-2-body","type":"text","text":"Core access, support and migration appear as one unavoidable selection.","tone":"warning"},{"id":"problematic-3-price","type":"price","label":"Displayed amount","amount":"$480"},{"id":"problematic-4-link","type":"link","text":"Core plan $260/month","emphasis":"subtle"}],"annotations":[{"targetId":"problematic-2-body","text":"Why this state matters: The presentation changes what the user can notice or predict at the pricing decision. The problematic state shows: “Core access, support and migration appear as one unavoidable selection.” Its influence should be tested by comparing the consequence and usability of “$480/month” with “Core plan $260/month”. A buyer may pay for unwanted services or misunderstand which components are optional."},{"targetId":"problematic-4-link","text":"Review prompt: Do “$480/month” and “Core plan $260/month” receive comparable prominence and explain their consequences before activation?"}]},"neutral":{"label":"Build your plan","layout":"pricing-card","elements":[{"id":"neutral-1-heading","type":"heading","text":"Build your plan"},{"id":"neutral-2-body","type":"text","text":"Core access and genuinely optional services are priced separately.","tone":"default"},{"id":"neutral-3-price","type":"price","label":"Displayed amount","amount":"$260"},{"id":"neutral-4-link","type":"link","text":"$480/month","emphasis":"default"},{"id":"neutral-5-disclosure","type":"disclosure","summary":"Price, period and commitment","content":"The price and material terms associated with “Core plan $260/month” remain beside this choice.","open":true}],"annotations":[{"targetId":"neutral-2-body","text":"Fairer design: Show the core service and separable extras with individual prices and controls, or explain why a bundle cannot be split."},{"targetId":"neutral-5-disclosure","text":"Review prompt: Place the compared prices, billing periods and material terms on one evidence sheet; where does it support “Component choices or prices are absent, hidden or materially harder”?"}]},"whyItMatters":"The presentation changes what the user can notice or predict at the pricing decision. The problematic state shows: “Core access, support and migration appear as one unavoidable selection.” Its influence should be tested by comparing the consequence and usability of “$480/month” with “Core plan $260/month”. A buyer may pay for unwanted services or misunderstand which components are optional.","fairDesignPrinciple":"Show the core service and separable extras with individual prices and controls, or explain why a bundle cannot be split.","reviewPrompts":["Do “$480/month” and “Core plan $260/month” receive comparable prominence and explain their consequences before activation?","Place the compared prices, billing periods and material terms on one evidence sheet; where does it support “Component choices or prices are absent, hidden or materially harder”?","What neutral rendering or comprehension result would falsify the classification, particularly in light of “transparent bundle with equally accessible component options and prices”?"],"altText":"Side-by-side business software pricing interface showing “Complete launch bundle” and the clearer alternative “Build your plan”.","provenance":"Original hypothetical business software pricing example created for this library; no real business, product or interface is depicted."}],"fairAlternative":"Show component consequences and prices and provide granular, equally accessible choices where components are separable.","whyProblematic":"Distinct products, services, permissions or purposes are grouped under one choice so the user cannot readily understand or select them separately. Distinct products or services are packaged behind one selection even though their separate price, function or necessity matters to the choice. These harms describe a review risk, not an automatic legal conclusion. Australian section 28B commences on 1 July 2027 and requires its complete, context-specific test. Existing ACL provisions remain a separate current-law assessment.","contextFactors":["One control has two or more separable consequences.","Component choices or prices are absent, hidden or materially harder.","The bundle favours a business outcome or adds cost, data use or commitment.","Boundary to test: Genuinely indivisible product","Boundary to test: transparent bundle with equally accessible component options and prices"],"affectedTeams":["Product","Design","Engineering","Legal","Compliance"],"reviewQuestions":["Do “Choose package $78” and “Choose ticket only $65” receive comparable prominence and explain their consequences before activation?","Capture every peer option, its default state and visual prominence; do those states support “One control has two or more separable consequences”?","What neutral rendering or comprehension result would falsify the classification, particularly in light of “Genuinely indivisible product”?","Do “$480/month” and “Core plan $260/month” receive comparable prominence and explain their consequences before activation?","Place the compared prices, billing periods and material terms on one evidence sheet; where does it support “Component choices or prices are absent, hidden or materially harder”?","What neutral rendering or comprehension result would falsify the classification, particularly in light of “transparent bundle with equally accessible component options and prices”?"],"evidence":["Annotated checkout and pricing screenshots at each responsive breakpoint","The complete state sequence before, during and after the consumer decision","Design-system component, content, default and configuration records for the reviewed release","Operational records substantiating price, availability, timing and eligibility claims","Usability, accessibility, reversal, complaint and support evidence relevant to consumer impact","A dated product and legal review record identifying evidence, uncertainties and release decisions"],"related":["choice-or-information-overload","complex-or-inaccessible-language","disguised-advertisement-or-action","manipulative-choice-architecture"],"sourceIds":["gray-ontology-dark-patterns-2024","eu-behavioural-study-digital-environment-2022","au-act-2026-64"],"altText":"Side-by-side event booking interface showing “Ticket plus city travel” and the clearer alternative “Build your booking”.","provenance":"Original hypothetical interface comparisons from the shared learning library, adapted to Australian-dollar context for this portal; no real business, product or interface is depicted.","author":"Flowlane","datePublished":"2026-08-10","dateModified":"2026-09-14","lastReviewed":"2026-09-14","changeNote":"Source comparison recorded and the current status restated."},{"title":"Choice or information overload","slug":"choice-or-information-overload","preferredName":"Choice or information overload","directAnswer":"Choice or information overload is a working label for this design mechanism: The volume or organisation of options or information makes meaningful comparison impractical and channels users toward a default or business-favoured path. This is editorial implementation guidance for Australian journeys, not a finding of unlawfulness. From 1 July 2027, a similar interface is relevant to ACL section 28B only if the complete consumer-connection, manipulation or unreasonable-distortion and actual-or-likely-detriment test is met. Current ACL rules require a separate assessment.","definition":"The volume or organisation of options or information makes meaningful comparison impractical and channels users toward a default or business-favoured path. This is a design and research taxonomy for learning and evidence review, not a statutory offence label or an automatic finding that an interface is unlawful.","synonyms":["too many options","information overload","unstructured option volume","decoy-heavy comparison","dense disclosure that obscures key terms"],"category":"Interface interference","family":"Interface interference","journeyStages":["Pricing","Signup"],"jurisdiction":"Australia","status":"Editorial implementation guidance","howItWorks":"The volume or organisation of options or information makes meaningful comparison impractical and channels users toward a default or business-favoured path. Excessive, overlapping or inconsistently organised options consume comparison effort while leaving one default or recommendation much easier to select.","warningSigns":["A concrete decision contains excessive or poorly organised choices or information.","Key differences cannot be reasonably compared.","A default or favoured route benefits from the overload."],"harms":["The volume and structure can make informed comparison impractical even without one visibly preferred plan.","The apparent detail may overwhelm rather than enable a meaningful purpose-by-purpose choice."],"legitimateUses":["Complex product legitimately requiring many comparable options with effective filters and summary","mere long page without a decision link"],"legalBasis":[{"provision":"ACL section 28B, inserted by the 2026 Act","sourceIds":["au-act-2026-64"],"classification":"Possible risk indicator","explanation":"In pricing and signup journeys, the choice or information overload mechanism may warrant review where it manipulates a consumer or unreasonably distorts the decision environment and causes, or is likely to cause, detriment. The interface interference label and an interface similarity do not establish a contravention; the complete section 28B test, scope, facts and evidence must be applied from 1 July 2027."},{"provision":"Dark-pattern research taxonomy","sourceIds":["gray-ontology-dark-patterns-2024","eu-behavioural-study-digital-environment-2022"],"classification":"Editorial analysis","explanation":"The cited research sources support this working pattern within the interface interference family. It is editorial implementation guidance, not an Australian statutory category, regulator finding or legal safe harbour."}],"examples":[{"type":"Illustrative example","context":"Tariff grid prevents a workable comparison","scenario":"A fictional provider presents twenty-seven plans with inconsistent feature names, billing periods and footnote structures but offers no grouping, filters or stable comparison view.","harm":"The volume and structure can make informed comparison impractical even without one visibly preferred plan."},{"type":"Illustrative example","context":"Consent purposes fragmented into dozens of toggles","scenario":"A fictional signup consent screen lists forty overlapping purposes across five nested panels, with duplicated labels and no summary of the resulting state.","harm":"The apparent detail may overwhelm rather than enable a meaningful purpose-by-purpose choice."}],"problematicUi":{"label":"Choose from 27 plans","copy":"Choose from 27 plans Inconsistent labels, units and dense footnotes require each plan to be decoded separately. Open plan 17 Compare grouped plans","annotations":["Why this state matters: The presentation changes what the user can notice or predict at the pricing decision. The problematic state shows: “Inconsistent labels, units and dense footnotes require each plan to be decoded separately.” Its influence should be tested by comparing the consequence and usability of “Open plan 17” with “Compare grouped plans”. The volume and structure can make informed comparison impractical even without one visibly preferred plan.","Review prompt: Do “Open plan 17” and “Compare grouped plans” receive comparable prominence and explain their consequences before activation?"]},"improvedUi":{"label":"Compare four plan types","copy":"Compare four plan types Consistent price, term and exit fields make the grouped options comparable. Compare grouped plans Open plan 17 Choice consequences The consequence of selecting “Compare grouped plans” is displayed beside the option.","annotations":["Fairer design: Group genuinely distinct options, use consistent attributes and offer a neutral comparison table with relevant filters.","Review prompt: Capture every peer option, its default state and visual prominence; do those states support “A concrete decision contains excessive or poorly organised choices or information”?"]},"uiComparisons":[{"id":"choice-or-information-overload-scenario-1","title":"Tariff grid prevents a workable comparison","context":"Energy plan selection","journeyStage":"Pricing","summary":"A fictional provider presents twenty-seven plans with inconsistent feature names, billing periods and footnote structures but offers no grouping, filters or stable comparison view.","problematic":{"label":"Choose from 27 plans","layout":"choice-list","elements":[{"id":"problematic-1-heading","type":"heading","text":"Choose from 27 plans"},{"id":"problematic-2-body","type":"text","text":"Inconsistent labels, units and dense footnotes require each plan to be decoded separately.","tone":"warning"},{"id":"problematic-3-radio","type":"radio","label":"Open plan 17","checked":true},{"id":"problematic-4-radio","type":"radio","label":"Compare grouped plans","checked":false}],"annotations":[{"targetId":"problematic-2-body","text":"Why this state matters: The presentation changes what the user can notice or predict at the pricing decision. The problematic state shows: “Inconsistent labels, units and dense footnotes require each plan to be decoded separately.” Its influence should be tested by comparing the consequence and usability of “Open plan 17” with “Compare grouped plans”. The volume and structure can make informed comparison impractical even without one visibly preferred plan."},{"targetId":"problematic-4-radio","text":"Review prompt: Do “Open plan 17” and “Compare grouped plans” receive comparable prominence and explain their consequences before activation?"}]},"neutral":{"label":"Compare four plan types","layout":"choice-list","elements":[{"id":"neutral-1-heading","type":"heading","text":"Compare four plan types"},{"id":"neutral-2-body","type":"text","text":"Consistent price, term and exit fields make the grouped options comparable.","tone":"default"},{"id":"neutral-3-radio","type":"radio","label":"Compare grouped plans","checked":false},{"id":"neutral-4-radio","type":"radio","label":"Open plan 17","checked":false},{"id":"neutral-5-disclosure","type":"disclosure","summary":"Choice consequences","content":"The consequence of selecting “Compare grouped plans” is displayed beside the option.","open":true}],"annotations":[{"targetId":"neutral-2-body","text":"Fairer design: Group genuinely distinct options, use consistent attributes and offer a neutral comparison table with relevant filters."},{"targetId":"neutral-5-disclosure","text":"Review prompt: Capture every peer option, its default state and visual prominence; do those states support “A concrete decision contains excessive or poorly organised choices or information”?"}]},"whyItMatters":"The presentation changes what the user can notice or predict at the pricing decision. The problematic state shows: “Inconsistent labels, units and dense footnotes require each plan to be decoded separately.” Its influence should be tested by comparing the consequence and usability of “Open plan 17” with “Compare grouped plans”. The volume and structure can make informed comparison impractical even without one visibly preferred plan.","fairDesignPrinciple":"Group genuinely distinct options, use consistent attributes and offer a neutral comparison table with relevant filters.","reviewPrompts":["Do “Open plan 17” and “Compare grouped plans” receive comparable prominence and explain their consequences before activation?","Capture every peer option, its default state and visual prominence; do those states support “A concrete decision contains excessive or poorly organised choices or information”?","What neutral rendering or comprehension result would falsify the classification, particularly in light of “Complex product legitimately requiring many comparable options with effective filters and summary”?"],"altText":"Side-by-side energy plan selection interface showing “Choose from 27 plans” and the clearer alternative “Compare four plan types”.","provenance":"Original hypothetical energy plan selection example created for this library; no real business, product or interface is depicted."},{"id":"choice-or-information-overload-scenario-2","title":"Consent purposes fragmented into dozens of toggles","context":"Signup consent choices","journeyStage":"Signup","summary":"A fictional signup consent screen lists forty overlapping purposes across five nested panels, with duplicated labels and no summary of the resulting state.","problematic":{"label":"Manage 40 data choices","layout":"form","elements":[{"id":"problematic-1-heading","type":"heading","text":"Manage 40 data choices"},{"id":"problematic-2-body","type":"text","text":"Duplicated labels and nested toggles prevent a coherent view of what remains enabled.","tone":"warning"},{"id":"problematic-3-checkbox","type":"checkbox","label":"Audience measurement","checked":false},{"id":"problematic-4-checkbox","type":"checkbox","label":"Content measurement","checked":false},{"id":"problematic-5-checkbox","type":"checkbox","label":"Product development","checked":false},{"id":"problematic-6-checkbox","type":"checkbox","label":"Partner insights","checked":false},{"id":"problematic-7-checkbox","type":"checkbox","label":"Personalised offers","checked":false},{"id":"problematic-8-button","type":"button","text":"Open purpose 17","emphasis":"primary"}],"annotations":[{"targetId":"problematic-2-body","text":"Why this state matters: The presentation changes what the user can notice or predict at the signup decision. The problematic state shows: “Duplicated labels and nested toggles prevent a coherent view of what remains enabled.” Its influence should be tested by comparing the consequence and usability of “Open purpose 17” with “Review six purpose groups”. The apparent detail may overwhelm rather than enable a meaningful purpose-by-purpose choice."},{"targetId":"problematic-8-button","text":"Review prompt: Do “Open purpose 17” and “Review six purpose groups” receive comparable prominence and explain their consequences before activation?"}]},"neutral":{"label":"Choose optional purposes","layout":"form","elements":[{"id":"neutral-1-heading","type":"heading","text":"Choose optional purposes"},{"id":"neutral-2-body","type":"text","text":"Six distinct groups provide summaries, supporting detail and a visible final state.","tone":"default"},{"id":"neutral-3-checkbox","type":"checkbox","label":"Service analytics","checked":false},{"id":"neutral-4-checkbox","type":"checkbox","label":"Personalisation","checked":false},{"id":"neutral-5-checkbox","type":"checkbox","label":"Partner sharing","checked":false},{"id":"neutral-6-button","type":"button","text":"Review six purpose groups","emphasis":"secondary"},{"id":"neutral-7-disclosure","type":"disclosure","summary":"Purpose and refusal effect","content":"The form explains why “Review six purpose groups” is requested and what happens if it is not used.","open":true}],"annotations":[{"targetId":"neutral-2-body","text":"Fairer design: Use understandable purpose groups, progressive detail and a persistent summary of the choices made."},{"targetId":"neutral-7-disclosure","text":"Review prompt: Which fields or permissions are required, what happens on refusal, and does the resulting state support this criterion: “Key differences cannot be reasonably compared”?"}]},"whyItMatters":"The presentation changes what the user can notice or predict at the signup decision. The problematic state shows: “Duplicated labels and nested toggles prevent a coherent view of what remains enabled.” Its influence should be tested by comparing the consequence and usability of “Open purpose 17” with “Review six purpose groups”. The apparent detail may overwhelm rather than enable a meaningful purpose-by-purpose choice.","fairDesignPrinciple":"Use understandable purpose groups, progressive detail and a persistent summary of the choices made.","reviewPrompts":["Do “Open purpose 17” and “Review six purpose groups” receive comparable prominence and explain their consequences before activation?","Which fields or permissions are required, what happens on refusal, and does the resulting state support this criterion: “Key differences cannot be reasonably compared”?","What neutral rendering or comprehension result would falsify the classification, particularly in light of “mere long page without a decision link”?"],"altText":"Side-by-side signup consent choices interface showing “Manage 40 data choices” and the clearer alternative “Choose optional purposes”.","provenance":"Original hypothetical signup consent choices example created for this library; no real business, product or interface is depicted."}],"fairAlternative":"Structure choices around comparable dimensions, surface key consequences and avoid using volume to hide a default or preferred outcome.","whyProblematic":"The volume or organisation of options or information makes meaningful comparison impractical and channels users toward a default or business-favoured path. Excessive, overlapping or inconsistently organised options consume comparison effort while leaving one default or recommendation much easier to select. These harms describe a review risk, not an automatic legal conclusion. Australian section 28B commences on 1 July 2027 and requires its complete, context-specific test. Existing ACL provisions remain a separate current-law assessment.","contextFactors":["A concrete decision contains excessive or poorly organised choices or information.","Key differences cannot be reasonably compared.","A default or favoured route benefits from the overload.","Boundary to test: Complex product legitimately requiring many comparable options with effective filters and summary","Boundary to test: mere long page without a decision link"],"affectedTeams":["Product","Design","Engineering","Legal","Compliance"],"reviewQuestions":["Do “Open plan 17” and “Compare grouped plans” receive comparable prominence and explain their consequences before activation?","Capture every peer option, its default state and visual prominence; do those states support “A concrete decision contains excessive or poorly organised choices or information”?","What neutral rendering or comprehension result would falsify the classification, particularly in light of “Complex product legitimately requiring many comparable options with effective filters and summary”?","Do “Open purpose 17” and “Review six purpose groups” receive comparable prominence and explain their consequences before activation?","Which fields or permissions are required, what happens on refusal, and does the resulting state support this criterion: “Key differences cannot be reasonably compared”?","What neutral rendering or comprehension result would falsify the classification, particularly in light of “mere long page without a decision link”?"],"evidence":["Annotated pricing and signup screenshots at each responsive breakpoint","The complete state sequence before, during and after the consumer decision","Design-system component, content, default and configuration records for the reviewed release","Operational records substantiating price, availability, timing and eligibility claims","Usability, accessibility, reversal, complaint and support evidence relevant to consumer impact","A dated product and legal review record identifying evidence, uncertainties and release decisions"],"related":["bundled-options","complex-or-inaccessible-language","disguised-advertisement-or-action","manipulative-choice-architecture"],"sourceIds":["gray-ontology-dark-patterns-2024","eu-behavioural-study-digital-environment-2022","au-act-2026-64"],"altText":"Side-by-side energy plan selection interface showing “Choose from 27 plans” and the clearer alternative “Compare four plan types”.","provenance":"Original hypothetical interface comparisons from the shared learning library, adapted to Australian-dollar context for this portal; no real business, product or interface is depicted.","author":"Flowlane","datePublished":"2026-08-10","dateModified":"2026-09-14","lastReviewed":"2026-09-14","changeNote":"Source comparison recorded and the current status restated."},{"title":"Complex or inaccessible language","slug":"complex-or-inaccessible-language","preferredName":"Complex or inaccessible language","directAnswer":"Complex or inaccessible language is a working label for this design mechanism: Material guidance is presented in a language or level of complexity that makes informed choice materially harder for the target user. This is editorial implementation guidance for Australian journeys, not a finding of unlawfulness. From 1 July 2027, a similar interface is relevant to ACL section 28B only if the complete consumer-connection, manipulation or unreasonable-distortion and actual-or-likely-detriment test is met. Current ACL rules require a separate assessment.","definition":"Material guidance is presented in a language or level of complexity that makes informed choice materially harder for the target user. This is a design and research taxonomy for learning and evidence review, not a statutory offence label or an automatic finding that an interface is unlawful.","synonyms":["complex language","wrong language","language discontinuity","hidden legalese","wrong locale","unexplained jargon","unnecessarily complex sentences","language switch at material term"],"category":"Interface interference","family":"Interface interference","journeyStages":["Cancellation","Checkout"],"jurisdiction":"Australia","status":"Editorial implementation guidance","howItWorks":"Material guidance is presented in a language or level of complexity that makes informed choice materially harder for the target user. Material consequences become harder to understand through avoidable jargon, syntactic complexity or an unexpected language change at the decision point.","warningSigns":["The text is material to a decision.","Locale mismatch or avoidable complexity is evidenced.","Reduced comprehension plausibly favours a business outcome or creates detriment."],"harms":["A subscriber may not understand billing, access or data consequences at the moment of choice.","A customer may commit without understanding material terms that appear only at the last step."],"legitimateUses":["Necessary technical terminology with clear explanation","user-selected alternate language"],"legalBasis":[{"provision":"ACL section 28B, inserted by the 2026 Act","sourceIds":["au-act-2026-64"],"classification":"Possible risk indicator","explanation":"In cancellation and checkout journeys, the complex or inaccessible language mechanism may warrant review where it manipulates a consumer or unreasonably distorts the decision environment and causes, or is likely to cause, detriment. The interface interference label and an interface similarity do not establish a contravention; the complete section 28B test, scope, facts and evidence must be applied from 1 July 2027."},{"provision":"Dark-pattern research taxonomy","sourceIds":["gray-ontology-dark-patterns-2024"],"classification":"Editorial analysis","explanation":"The cited research sources support this working pattern within the interface interference family. It is editorial implementation guidance, not an Australian statutory category, regulator finding or legal safe harbour."}],"examples":[{"type":"Illustrative example","context":"Cancellation consequence written in legalese","scenario":"A fictional service describes the effect of cancellation through a 220-word clause containing undefined terms and cross-references immediately before confirmation.","harm":"A subscriber may not understand billing, access or data consequences at the moment of choice."},{"type":"Illustrative example","context":"Payment step changes language without warning","scenario":"A fictional shop presents product and basket information in English but switches mandatory fee and return text to another language on the payment screen.","harm":"A customer may commit without understanding material terms that appear only at the last step."}],"problematicUi":{"label":"Effectuation of cessation","copy":"Effectuation of cessation Undefined legal terms obscure what happens after the button is pressed. Acknowledge cessation provision End plan","annotations":["Why this state matters: The presentation changes what the user can notice or predict at the cancellation decision. The problematic state shows: “Undefined legal terms obscure what happens after the button is pressed.” Its influence should be tested by comparing the consequence and usability of “Acknowledge cessation provision” with “End plan”. A subscriber may not understand billing, access or data consequences at the moment of choice.","Review prompt: Do “Acknowledge cessation provision” and “End plan” receive comparable prominence and explain their consequences before activation?"]},"improvedUi":{"label":"Your plan ends on 30 September","copy":"Your plan ends on 30 September No further renewal; files remain available until that date. End plan Acknowledge cessation provision What happens next Activating “End plan” produces the outcome stated on the control.","annotations":["Fairer design: Summarise the effective date, final charge, remaining access and data outcome in plain language, with legal detail available separately.","Review prompt: Can the dialog be dismissed, what action does each control trigger, and what later state confirms or contradicts “The text is material to a decision”?"]},"uiComparisons":[{"id":"complex-or-inaccessible-language-scenario-1","title":"Cancellation consequence written in legalese","context":"Software account","journeyStage":"Cancellation","summary":"A fictional service describes the effect of cancellation through a 220-word clause containing undefined terms and cross-references immediately before confirmation.","problematic":{"label":"Effectuation of cessation","layout":"dialog","elements":[{"id":"problematic-1-heading","type":"heading","text":"Effectuation of cessation"},{"id":"problematic-2-body","type":"text","text":"Undefined legal terms obscure what happens after the button is pressed.","tone":"warning"},{"id":"problematic-3-button","type":"button","text":"Acknowledge cessation provision","emphasis":"primary"},{"id":"problematic-4-link","type":"link","text":"End plan","emphasis":"subtle"}],"annotations":[{"targetId":"problematic-2-body","text":"Why this state matters: The presentation changes what the user can notice or predict at the cancellation decision. The problematic state shows: “Undefined legal terms obscure what happens after the button is pressed.” Its influence should be tested by comparing the consequence and usability of “Acknowledge cessation provision” with “End plan”. A subscriber may not understand billing, access or data consequences at the moment of choice."},{"targetId":"problematic-4-link","text":"Review prompt: Do “Acknowledge cessation provision” and “End plan” receive comparable prominence and explain their consequences before activation?"}]},"neutral":{"label":"Your plan ends on 30 September","layout":"dialog","elements":[{"id":"neutral-1-heading","type":"heading","text":"Your plan ends on 30 September"},{"id":"neutral-2-body","type":"text","text":"No further renewal; files remain available until that date.","tone":"default"},{"id":"neutral-3-button","type":"button","text":"End plan","emphasis":"secondary"},{"id":"neutral-4-link","type":"link","text":"Acknowledge cessation provision","emphasis":"default"},{"id":"neutral-5-disclosure","type":"disclosure","summary":"What happens next","content":"Activating “End plan” produces the outcome stated on the control.","open":true}],"annotations":[{"targetId":"neutral-2-body","text":"Fairer design: Summarise the effective date, final charge, remaining access and data outcome in plain language, with legal detail available separately."},{"targetId":"neutral-5-disclosure","text":"Review prompt: Can the dialog be dismissed, what action does each control trigger, and what later state confirms or contradicts “The text is material to a decision”?"}]},"whyItMatters":"The presentation changes what the user can notice or predict at the cancellation decision. The problematic state shows: “Undefined legal terms obscure what happens after the button is pressed.” Its influence should be tested by comparing the consequence and usability of “Acknowledge cessation provision” with “End plan”. A subscriber may not understand billing, access or data consequences at the moment of choice.","fairDesignPrinciple":"Summarise the effective date, final charge, remaining access and data outcome in plain language, with legal detail available separately.","reviewPrompts":["Do “Acknowledge cessation provision” and “End plan” receive comparable prominence and explain their consequences before activation?","Can the dialog be dismissed, what action does each control trigger, and what later state confirms or contradicts “The text is material to a decision”?","What neutral rendering or comprehension result would falsify the classification, particularly in light of “Necessary technical terminology with clear explanation”?"],"altText":"Side-by-side software account interface showing “Effectuation of cessation” and the clearer alternative “Your plan ends on 30 September”.","provenance":"Original hypothetical software account example created for this library; no real business, product or interface is depicted."},{"id":"complex-or-inaccessible-language-scenario-2","title":"Payment step changes language without warning","context":"Cross-border checkout","journeyStage":"Checkout","summary":"A fictional shop presents product and basket information in English but switches mandatory fee and return text to another language on the payment screen.","problematic":{"label":"Complete payment","layout":"checkout-summary","elements":[{"id":"problematic-1-heading","type":"heading","text":"Complete payment"},{"id":"problematic-2-body","type":"text","text":"Mandatory charge and return conditions appear only in an unexpected language.","tone":"warning"},{"id":"problematic-3-price","type":"price","label":"Amount affected","amount":"$84"},{"id":"problematic-4-button","type":"button","text":"Pay $84","emphasis":"primary"},{"id":"problematic-5-link","type":"link","text":"Pay $84 after review","emphasis":"subtle"}],"annotations":[{"targetId":"problematic-2-body","text":"Why this state matters: The presentation changes what the user can notice or predict at the checkout decision. The problematic state shows: “Mandatory charge and return conditions appear only in an unexpected language.” Its influence should be tested by comparing the consequence and usability of “Pay $84” with “Pay $84 after review”. A customer may commit without understanding material terms that appear only at the last step."},{"targetId":"problematic-5-link","text":"Review prompt: Do “Pay $84” and “Pay $84 after review” receive comparable prominence and explain their consequences before activation?"}]},"neutral":{"label":"Order summary in English","layout":"checkout-summary","elements":[{"id":"neutral-1-heading","type":"heading","text":"Order summary in English"},{"id":"neutral-2-body","type":"text","text":"Price, charge and return conditions remain understandable at payment.","tone":"default"},{"id":"neutral-3-price","type":"price","label":"Amount affected","amount":"$84"},{"id":"neutral-4-button","type":"button","text":"Pay $84 after review","emphasis":"secondary"},{"id":"neutral-5-link","type":"link","text":"Pay $84","emphasis":"default"},{"id":"neutral-6-disclosure","type":"disclosure","summary":"Payable total and selected items","content":"The summary shows the line items and total before “Pay $84 after review” is activated.","open":true}],"annotations":[{"targetId":"neutral-2-body","text":"Fairer design: Keep material information in the user’s selected language and clearly offer any necessary language change before payment."},{"targetId":"neutral-6-disclosure","text":"Review prompt: Compare the basket before and after the action, including total and line items; does the mutation satisfy “Locale mismatch or avoidable complexity is evidenced”?"}]},"whyItMatters":"The presentation changes what the user can notice or predict at the checkout decision. The problematic state shows: “Mandatory charge and return conditions appear only in an unexpected language.” Its influence should be tested by comparing the consequence and usability of “Pay $84” with “Pay $84 after review”. A customer may commit without understanding material terms that appear only at the last step.","fairDesignPrinciple":"Keep material information in the user’s selected language and clearly offer any necessary language change before payment.","reviewPrompts":["Do “Pay $84” and “Pay $84 after review” receive comparable prominence and explain their consequences before activation?","Compare the basket before and after the action, including total and line items; does the mutation satisfy “Locale mismatch or avoidable complexity is evidenced”?","What neutral rendering or comprehension result would falsify the classification, particularly in light of “user-selected alternate language”?"],"altText":"Side-by-side cross-border checkout interface showing “Complete payment” and the clearer alternative “Order summary in English”.","provenance":"Original hypothetical cross-border checkout example created for this library; no real business, product or interface is depicted."}],"fairAlternative":"Use the user's selected language, plain structure and explained terminology for material consequences.","whyProblematic":"Material guidance is presented in a language or level of complexity that makes informed choice materially harder for the target user. Material consequences become harder to understand through avoidable jargon, syntactic complexity or an unexpected language change at the decision point. These harms describe a review risk, not an automatic legal conclusion. Australian section 28B commences on 1 July 2027 and requires its complete, context-specific test. Existing ACL provisions remain a separate current-law assessment.","contextFactors":["The text is material to a decision.","Locale mismatch or avoidable complexity is evidenced.","Reduced comprehension plausibly favours a business outcome or creates detriment.","Boundary to test: Necessary technical terminology with clear explanation","Boundary to test: user-selected alternate language"],"affectedTeams":["Product","Design","Engineering","Legal","Compliance"],"reviewQuestions":["Do “Acknowledge cessation provision” and “End plan” receive comparable prominence and explain their consequences before activation?","Can the dialog be dismissed, what action does each control trigger, and what later state confirms or contradicts “The text is material to a decision”?","What neutral rendering or comprehension result would falsify the classification, particularly in light of “Necessary technical terminology with clear explanation”?","Do “Pay $84” and “Pay $84 after review” receive comparable prominence and explain their consequences before activation?","Compare the basket before and after the action, including total and line items; does the mutation satisfy “Locale mismatch or avoidable complexity is evidenced”?","What neutral rendering or comprehension result would falsify the classification, particularly in light of “user-selected alternate language”?"],"evidence":["Annotated cancellation and checkout screenshots at each responsive breakpoint","The complete state sequence before, during and after the consumer decision","Design-system component, content, default and configuration records for the reviewed release","Operational records substantiating price, availability, timing and eligibility claims","Usability, accessibility, reversal, complaint and support evidence relevant to consumer impact","A dated product and legal review record identifying evidence, uncertainties and release decisions"],"related":["bundled-options","choice-or-information-overload","disguised-advertisement-or-action","manipulative-choice-architecture"],"sourceIds":["gray-ontology-dark-patterns-2024","au-act-2026-64"],"altText":"Side-by-side software account interface showing “Effectuation of cessation” and the clearer alternative “Your plan ends on 30 September”.","provenance":"Original hypothetical interface comparisons from the shared learning library, adapted to Australian-dollar context for this portal; no real business, product or interface is depicted.","author":"Flowlane","datePublished":"2026-08-10","dateModified":"2026-09-14","lastReviewed":"2026-09-14","changeNote":"Source comparison recorded and the current status restated."},{"title":"Disguised advertisement or action","slug":"disguised-advertisement-or-action","preferredName":"Disguised advertisement or action","directAnswer":"Disguised advertisement or action is a working label for this design mechanism: A promotional or biased action is presented as ordinary content or as a different control, causing interaction under a mistaken understanding. This is editorial implementation guidance for Australian journeys, not a finding of unlawfulness. From 1 July 2027, a similar interface is relevant to ACL section 28B only if the complete consumer-connection, manipulation or unreasonable-distortion and actual-or-likely-detriment test is met. Current ACL rules require a separate assessment.","definition":"A promotional or biased action is presented as ordinary content or as a different control, causing interaction under a mistaken understanding. This is a design and research taxonomy for learning and evidence review, not a statutory offence label or an automatic finding that an interface is unlawful.","synonyms":["disguised ad","native ad deception","fake close button","ad styled as content","advertisement styled as download","close-looking control opens promotion","sponsored result without effective label"],"category":"Interface interference","family":"Interface interference","journeyStages":["Pricing"],"jurisdiction":"Australia","status":"Editorial implementation guidance","howItWorks":"A promotional or biased action is presented as ordinary content or as a different control, causing interaction under a mistaken understanding. A commercial placement or control adopts the appearance of a different familiar element, so the user activates advertising, purchase or navigation while expecting another result.","warningSigns":["The element's commercial or actual function is not apparent before interaction.","Visual or semantic cues mimic another content or control type.","The resulting action benefits the business or advertiser."],"harms":["A shopper may treat commercial placement as an independent relevance judgment.","The user activates a commercial action while reasonably expecting to close the message."],"legitimateUses":["Effectively labelled advertisement distinguishable before interaction","ordinary external link with an accurate label"],"legalBasis":[{"provision":"ACL section 28B, inserted by the 2026 Act","sourceIds":["au-act-2026-64"],"classification":"Possible risk indicator","explanation":"In pricing journeys, the disguised advertisement or action mechanism may warrant review where it manipulates a consumer or unreasonably distorts the decision environment and causes, or is likely to cause, detriment. The interface interference label and an interface similarity do not establish a contravention; the complete section 28B test, scope, facts and evidence must be applied from 1 July 2027."},{"provision":"Dark-pattern research taxonomy","sourceIds":["oecd-dark-commercial-patterns-2022"],"classification":"Editorial analysis","explanation":"The cited research sources support this working pattern within the interface interference family. It is editorial implementation guidance, not an Australian statutory category, regulator finding or legal safe harbour."}],"examples":[{"type":"Illustrative example","context":"Sponsored result imitates an organic recommendation","scenario":"A fictional marketplace gives a paid placement the same typography and ranking treatment as organic results, with “sponsored” hidden in a tooltip.","harm":"A shopper may treat commercial placement as an independent relevance judgment."},{"type":"Illustrative example","context":"Fake close control opens another promotion","scenario":"A fictional app draws an “×” in the corner of an upgrade ad, but tapping it opens the purchase page instead of dismissing the ad.","harm":"The user activates a commercial action while reasonably expecting to close the message."}],"problematicUi":{"label":"Top match for you","copy":"Top match for you The paid placement looks identical to an organic result. View top match View sponsored offer","annotations":["Why this state matters: The presentation changes what the user can notice or predict at the pricing decision. The problematic state shows: “The paid placement looks identical to an organic result.” Its influence should be tested by comparing the consequence and usability of “View top match” with “View sponsored offer”. A shopper may treat commercial placement as an independent relevance judgment.","Review prompt: Do “View top match” and “View sponsored offer” receive comparable prominence and explain their consequences before activation?"]},"improvedUi":{"label":"Sponsored placement","copy":"Sponsored placement The commercial relationship is visible before the product claim and click. View sponsored offer View top match Price, period and commitment The price and material terms associated with “View sponsored offer” remain beside this choice.","annotations":["Fairer design: Label advertising at first exposure and keep the commercial marker visible beside the result and action.","Review prompt: Place the compared prices, billing periods and material terms on one evidence sheet; where does it support “The element's commercial or actual function is not apparent before interaction”?"]},"uiComparisons":[{"id":"disguised-advertisement-or-action-scenario-1","title":"Sponsored result imitates an organic recommendation","context":"Marketplace search","journeyStage":"Pricing","summary":"A fictional marketplace gives a paid placement the same typography and ranking treatment as organic results, with “sponsored” hidden in a tooltip.","problematic":{"label":"Top match for you","layout":"pricing-card","elements":[{"id":"problematic-1-heading","type":"heading","text":"Top match for you"},{"id":"problematic-2-body","type":"text","text":"The paid placement looks identical to an organic result.","tone":"warning"},{"id":"problematic-3-button","type":"button","text":"View top match","emphasis":"primary"},{"id":"problematic-4-link","type":"link","text":"View sponsored offer","emphasis":"subtle"}],"annotations":[{"targetId":"problematic-2-body","text":"Why this state matters: The presentation changes what the user can notice or predict at the pricing decision. The problematic state shows: “The paid placement looks identical to an organic result.” Its influence should be tested by comparing the consequence and usability of “View top match” with “View sponsored offer”. A shopper may treat commercial placement as an independent relevance judgment."},{"targetId":"problematic-4-link","text":"Review prompt: Do “View top match” and “View sponsored offer” receive comparable prominence and explain their consequences before activation?"}]},"neutral":{"label":"Sponsored placement","layout":"pricing-card","elements":[{"id":"neutral-1-heading","type":"heading","text":"Sponsored placement"},{"id":"neutral-2-body","type":"text","text":"The commercial relationship is visible before the product claim and click.","tone":"default"},{"id":"neutral-3-button","type":"button","text":"View sponsored offer","emphasis":"secondary"},{"id":"neutral-4-link","type":"link","text":"View top match","emphasis":"default"},{"id":"neutral-5-disclosure","type":"disclosure","summary":"Price, period and commitment","content":"The price and material terms associated with “View sponsored offer” remain beside this choice.","open":true}],"annotations":[{"targetId":"neutral-2-body","text":"Fairer design: Label advertising at first exposure and keep the commercial marker visible beside the result and action."},{"targetId":"neutral-5-disclosure","text":"Review prompt: Place the compared prices, billing periods and material terms on one evidence sheet; where does it support “The element's commercial or actual function is not apparent before interaction”?"}]},"whyItMatters":"The presentation changes what the user can notice or predict at the pricing decision. The problematic state shows: “The paid placement looks identical to an organic result.” Its influence should be tested by comparing the consequence and usability of “View top match” with “View sponsored offer”. A shopper may treat commercial placement as an independent relevance judgment.","fairDesignPrinciple":"Label advertising at first exposure and keep the commercial marker visible beside the result and action.","reviewPrompts":["Do “View top match” and “View sponsored offer” receive comparable prominence and explain their consequences before activation?","Place the compared prices, billing periods and material terms on one evidence sheet; where does it support “The element's commercial or actual function is not apparent before interaction”?","What neutral rendering or comprehension result would falsify the classification, particularly in light of “Effectively labelled advertisement distinguishable before interaction”?"],"altText":"Side-by-side marketplace search interface showing “Top match for you” and the clearer alternative “Sponsored placement”.","provenance":"Original hypothetical marketplace search example created for this library; no real business, product or interface is depicted."},{"id":"disguised-advertisement-or-action-scenario-2","title":"Fake close control opens another promotion","context":"Mobile upgrade interstitial","journeyStage":"Pricing","summary":"A fictional app draws an “×” in the corner of an upgrade ad, but tapping it opens the purchase page instead of dismissing the ad.","problematic":{"label":"Limited upgrade","layout":"dialog","elements":[{"id":"problematic-1-heading","type":"heading","text":"Limited upgrade"},{"id":"problematic-2-body","type":"text","text":"The familiar close symbol is wired to the upgrade route.","tone":"warning"},{"id":"problematic-3-button","type":"button","text":"×","emphasis":"primary"},{"id":"problematic-4-link","type":"link","text":"Close promotion","emphasis":"subtle"}],"annotations":[{"targetId":"problematic-2-body","text":"Why this state matters: The presentation changes what the user can notice or predict at the pricing decision. The problematic state shows: “The familiar close symbol is wired to the upgrade route.” Its influence should be tested by comparing the consequence and usability of “×” with “Close promotion”. The user activates a commercial action while reasonably expecting to close the message."},{"targetId":"problematic-4-link","text":"Review prompt: Do “×” and “Close promotion” receive comparable prominence and explain their consequences before activation?"}]},"neutral":{"label":"Optional upgrade","layout":"dialog","elements":[{"id":"neutral-1-heading","type":"heading","text":"Optional upgrade"},{"id":"neutral-2-body","type":"text","text":"Close dismisses the dialog; the upgrade button names its destination.","tone":"default"},{"id":"neutral-3-button","type":"button","text":"Close promotion","emphasis":"secondary"},{"id":"neutral-4-link","type":"link","text":"×","emphasis":"default"},{"id":"neutral-5-disclosure","type":"disclosure","summary":"What happens next","content":"Activating “Close promotion” produces the outcome stated on the control.","open":true}],"annotations":[{"targetId":"neutral-2-body","text":"Fairer design: Make the close control perform only dismissal and label any purchase action separately."},{"targetId":"neutral-5-disclosure","text":"Review prompt: Can the dialog be dismissed, what action does each control trigger, and what later state confirms or contradicts “Visual or semantic cues mimic another content or control type”?"}]},"whyItMatters":"The presentation changes what the user can notice or predict at the pricing decision. The problematic state shows: “The familiar close symbol is wired to the upgrade route.” Its influence should be tested by comparing the consequence and usability of “×” with “Close promotion”. The user activates a commercial action while reasonably expecting to close the message.","fairDesignPrinciple":"Make the close control perform only dismissal and label any purchase action separately.","reviewPrompts":["Do “×” and “Close promotion” receive comparable prominence and explain their consequences before activation?","Can the dialog be dismissed, what action does each control trigger, and what later state confirms or contradicts “Visual or semantic cues mimic another content or control type”?","What neutral rendering or comprehension result would falsify the classification, particularly in light of “ordinary external link with an accurate label”?"],"altText":"Side-by-side mobile upgrade interstitial interface showing “Limited upgrade” and the clearer alternative “Optional upgrade”.","provenance":"Original hypothetical mobile upgrade interstitial example created for this library; no real business, product or interface is depicted."}],"fairAlternative":"Label advertising and action outcomes clearly before interaction and avoid mimicking unrelated controls or editorial content.","whyProblematic":"A promotional or biased action is presented as ordinary content or as a different control, causing interaction under a mistaken understanding. A commercial placement or control adopts the appearance of a different familiar element, so the user activates advertising, purchase or navigation while expecting another result. These harms describe a review risk, not an automatic legal conclusion. Australian section 28B commences on 1 July 2027 and requires its complete, context-specific test. Existing ACL provisions remain a separate current-law assessment.","contextFactors":["The element's commercial or actual function is not apparent before interaction.","Visual or semantic cues mimic another content or control type.","The resulting action benefits the business or advertiser.","Boundary to test: Effectively labelled advertisement distinguishable before interaction","Boundary to test: ordinary external link with an accurate label"],"affectedTeams":["Product","Design","Engineering","Legal","Compliance"],"reviewQuestions":["Do “View top match” and “View sponsored offer” receive comparable prominence and explain their consequences before activation?","Place the compared prices, billing periods and material terms on one evidence sheet; where does it support “The element's commercial or actual function is not apparent before interaction”?","What neutral rendering or comprehension result would falsify the classification, particularly in light of “Effectively labelled advertisement distinguishable before interaction”?","Do “×” and “Close promotion” receive comparable prominence and explain their consequences before activation?","Can the dialog be dismissed, what action does each control trigger, and what later state confirms or contradicts “Visual or semantic cues mimic another content or control type”?","What neutral rendering or comprehension result would falsify the classification, particularly in light of “ordinary external link with an accurate label”?"],"evidence":["Annotated pricing screenshots at each responsive breakpoint","The complete state sequence before, during and after the consumer decision","Design-system component, content, default and configuration records for the reviewed release","Operational records substantiating price, availability, timing and eligibility claims","Usability, accessibility, reversal, complaint and support evidence relevant to consumer impact","A dated product and legal review record identifying evidence, uncertainties and release decisions"],"related":["bundled-options","choice-or-information-overload","complex-or-inaccessible-language","manipulative-choice-architecture"],"sourceIds":["oecd-dark-commercial-patterns-2022","au-act-2026-64"],"altText":"Side-by-side marketplace search interface showing “Top match for you” and the clearer alternative “Sponsored placement”.","provenance":"Original hypothetical interface comparisons from the shared learning library, adapted to Australian-dollar context for this portal; no real business, product or interface is depicted.","author":"Flowlane","datePublished":"2026-08-10","dateModified":"2026-09-14","lastReviewed":"2026-09-14","changeNote":"Source comparison recorded and the current status restated."},{"title":"False hierarchy","slug":"manipulative-choice-architecture","preferredName":"False hierarchy","directAnswer":"False hierarchy is a working label for this design mechanism: Parallel options are presented as if one were hierarchically primary, giving a business-favoured option materially greater visual or interactive prominence. This is editorial implementation guidance for Australian journeys, not a finding of unlawfulness. From 1 July 2027, a similar interface is relevant to ACL section 28B only if the complete consumer-connection, manipulation or unreasonable-distortion and actual-or-likely-detriment test is met. Current ACL rules require a separate assessment.","definition":"Parallel options are presented as if one were hierarchically primary, giving a business-favoured option materially greater visual or interactive prominence. This is a design and research taxonomy for learning and evidence review, not a statutory offence label or an automatic finding that an interface is unlawful.","synonyms":["visual interference","visual prominence","misdirection","primary button versus text link","size or contrast asymmetry","interactive affordance asymmetry","distracting competing element","manipulative interface","dark pattern","deceptive design","choice distortion","obstructive design","Manipulative choice architecture"],"category":"Interface interference","family":"Interface interference","journeyStages":["Signup","Subscription"],"jurisdiction":"Australia","status":"Commences 1 July 2027","howItWorks":"Parallel options are presented as if one were hierarchically primary, giving a business-favoured option materially greater visual or interactive prominence. Parallel outcomes receive unequal size, contrast, position or affordance, making the favoured route feel like the primary action rather than one substantive option among peers.","warningSigns":["Two or more options address the same decision.","The business-favoured option is identified with evidence.","Measured prominence differs across at least two independent visual or affordance signals."],"harms":["People may overlook a genuine lower-data option because the visual hierarchy favours acceptance.","A subscriber may enter a longer commitment without noticing the viable monthly alternative."],"legitimateUses":["Primary progress versus back navigation that does not represent parallel substantive outcomes","visual difference with no identifiable business-favoured consequence"],"legalBasis":[{"provision":"ACL section 28B(1) to (2), inserted by the 2026 Act","sourceIds":["au-act-2026-64"],"classification":"Express rule","explanation":"Prohibits the practice only where consumer connection, manipulation or unreasonable distortion, and likely detriment are all present."},{"provision":"ACL section 28B(6)(d), inserted by the 2026 Act","sourceIds":["au-act-2026-64"],"classification":"Possible risk indicator","explanation":"Provides a non-exhaustive, non-per-se example concerning pressure or obstruction in a decision environment, including digital design."}],"examples":[{"type":"Illustrative example","context":"Consent choices with unequal prominence","scenario":"A fictional service displays a full-width coloured “Accept all” button while “Use necessary data only” is a faint text link after several paragraphs.","harm":"People may overlook a genuine lower-data option because the visual hierarchy favours acceptance."},{"type":"Illustrative example","context":"Annual upgrade dominates monthly continuation","scenario":"A fictional software trial uses a large highlighted annual-upgrade card and places the existing monthly option as low-contrast text beneath testimonials.","harm":"A subscriber may enter a longer commitment without noticing the viable monthly alternative."}],"problematicUi":{"label":"Choose your privacy settings","copy":"Choose your privacy settings Acceptance dominates the panel and the lower-data route is visually detached. Accept all Use necessary data only","annotations":["Why this state matters: The presentation changes what the user can notice or predict at the signup decision. The problematic state shows: “Acceptance dominates the panel and the lower-data route is visually detached.” Its influence should be tested by comparing the consequence and usability of “Accept all” with “Use necessary data only”. People may overlook a genuine lower-data option because the visual hierarchy favours acceptance.","Review prompt: Do “Accept all” and “Use necessary data only” receive comparable prominence and explain their consequences before activation?"]},"improvedUi":{"label":"Choose your privacy settings","copy":"Choose your privacy settings Necessary-only and optional choices are visible together with equal clarity. Use necessary data only Accept all Choice consequences The consequence of selecting “Use necessary data only” is displayed beside the option.","annotations":["Fairer design: Give materially different privacy choices stable labels, comparable prominence and concise consequences.","Review prompt: Capture every peer option, its default state and visual prominence; do those states support “Two or more options address the same decision”?"]},"uiComparisons":[{"id":"false-hierarchy-scenario-1","title":"Consent choices with unequal prominence","context":"Privacy choice","journeyStage":"Signup","summary":"A fictional service displays a full-width coloured “Accept all” button while “Use necessary data only” is a faint text link after several paragraphs.","problematic":{"label":"Choose your privacy settings","layout":"choice-list","elements":[{"id":"problematic-1-heading","type":"heading","text":"Choose your privacy settings"},{"id":"problematic-2-body","type":"text","text":"Acceptance dominates the panel and the lower-data route is visually detached.","tone":"warning"},{"id":"problematic-3-radio","type":"radio","label":"Accept all","checked":true},{"id":"problematic-4-radio","type":"radio","label":"Use necessary data only","checked":false}],"annotations":[{"targetId":"problematic-2-body","text":"Why this state matters: The presentation changes what the user can notice or predict at the signup decision. The problematic state shows: “Acceptance dominates the panel and the lower-data route is visually detached.” Its influence should be tested by comparing the consequence and usability of “Accept all” with “Use necessary data only”. People may overlook a genuine lower-data option because the visual hierarchy favours acceptance."},{"targetId":"problematic-4-radio","text":"Review prompt: Do “Accept all” and “Use necessary data only” receive comparable prominence and explain their consequences before activation?"}]},"neutral":{"label":"Choose your privacy settings","layout":"choice-list","elements":[{"id":"neutral-1-heading","type":"heading","text":"Choose your privacy settings"},{"id":"neutral-2-body","type":"text","text":"Necessary-only and optional choices are visible together with equal clarity.","tone":"default"},{"id":"neutral-3-radio","type":"radio","label":"Use necessary data only","checked":false},{"id":"neutral-4-radio","type":"radio","label":"Accept all","checked":false},{"id":"neutral-5-disclosure","type":"disclosure","summary":"Choice consequences","content":"The consequence of selecting “Use necessary data only” is displayed beside the option.","open":true}],"annotations":[{"targetId":"neutral-2-body","text":"Fairer design: Give materially different privacy choices stable labels, comparable prominence and concise consequences."},{"targetId":"neutral-5-disclosure","text":"Review prompt: Capture every peer option, its default state and visual prominence; do those states support “Two or more options address the same decision”?"}]},"whyItMatters":"The presentation changes what the user can notice or predict at the signup decision. The problematic state shows: “Acceptance dominates the panel and the lower-data route is visually detached.” Its influence should be tested by comparing the consequence and usability of “Accept all” with “Use necessary data only”. People may overlook a genuine lower-data option because the visual hierarchy favours acceptance.","fairDesignPrinciple":"Give materially different privacy choices stable labels, comparable prominence and concise consequences.","reviewPrompts":["Do “Accept all” and “Use necessary data only” receive comparable prominence and explain their consequences before activation?","Capture every peer option, its default state and visual prominence; do those states support “Two or more options address the same decision”?","What neutral rendering or comprehension result would falsify the classification, particularly in light of “Primary progress versus back navigation that does not represent parallel substantive outcomes”?"],"altText":"Side-by-side privacy choice interface showing “Choose your privacy settings” and the clearer alternative “Choose your privacy settings”.","provenance":"Original hypothetical privacy choice example created for this library; no real business, product or interface is depicted."},{"id":"false-hierarchy-scenario-2","title":"Annual upgrade dominates monthly continuation","context":"Software trial","journeyStage":"Subscription","summary":"A fictional software trial uses a large highlighted annual-upgrade card and places the existing monthly option as low-contrast text beneath testimonials.","problematic":{"label":"Recommended annual plan","layout":"pricing-card","elements":[{"id":"problematic-1-heading","type":"heading","text":"Recommended annual plan"},{"id":"problematic-2-body","type":"text","text":"The existing monthly path is separated and de-emphasised.","tone":"warning"},{"id":"problematic-3-price","type":"price","label":"Displayed amount","amount":"$240"},{"id":"problematic-4-link","type":"link","text":"Choose monthly or annual","emphasis":"subtle"}],"annotations":[{"targetId":"problematic-2-body","text":"Why this state matters: The presentation changes what the user can notice or predict at the subscription decision. The problematic state shows: “The existing monthly path is separated and de-emphasised.” Its influence should be tested by comparing the consequence and usability of “$240 billed now” with “Choose monthly or annual”. A subscriber may enter a longer commitment without noticing the viable monthly alternative."},{"targetId":"problematic-4-link","text":"Review prompt: Do “$240 billed now” and “Choose monthly or annual” receive comparable prominence and explain their consequences before activation?"}]},"neutral":{"label":"Compare billing options","layout":"pricing-card","elements":[{"id":"neutral-1-heading","type":"heading","text":"Compare billing options"},{"id":"neutral-2-body","type":"text","text":"Annual and monthly prices, commitments and controls receive comparable treatment.","tone":"default"},{"id":"neutral-3-button","type":"button","text":"Choose monthly or annual","emphasis":"secondary"},{"id":"neutral-4-link","type":"link","text":"$240 billed now","emphasis":"default"},{"id":"neutral-5-disclosure","type":"disclosure","summary":"Price, period and commitment","content":"The price and material terms associated with “Choose monthly or annual” remain beside this choice.","open":true}],"annotations":[{"targetId":"neutral-2-body","text":"Fairer design: Show annual and monthly options together with total price, billing period and equivalent controls."},{"targetId":"neutral-5-disclosure","text":"Review prompt: Place the compared prices, billing periods and material terms on one evidence sheet; where does it support “The business-favoured option is identified with evidence”?"}]},"whyItMatters":"The presentation changes what the user can notice or predict at the subscription decision. The problematic state shows: “The existing monthly path is separated and de-emphasised.” Its influence should be tested by comparing the consequence and usability of “$240 billed now” with “Choose monthly or annual”. A subscriber may enter a longer commitment without noticing the viable monthly alternative.","fairDesignPrinciple":"Show annual and monthly options together with total price, billing period and equivalent controls.","reviewPrompts":["Do “$240 billed now” and “Choose monthly or annual” receive comparable prominence and explain their consequences before activation?","Place the compared prices, billing periods and material terms on one evidence sheet; where does it support “The business-favoured option is identified with evidence”?","What neutral rendering or comprehension result would falsify the classification, particularly in light of “visual difference with no identifiable business-favoured consequence”?"],"altText":"Side-by-side software trial interface showing “Recommended annual plan” and the clearer alternative “Compare billing options”.","provenance":"Original hypothetical software trial example created for this library; no real business, product or interface is depicted."}],"fairAlternative":"Present parallel choices with comparable visual weight, affordance and accessibility, especially where outcomes differ in cost, privacy or commitment.","whyProblematic":"Parallel options are presented as if one were hierarchically primary, giving a business-favoured option materially greater visual or interactive prominence. Parallel outcomes receive unequal size, contrast, position or affordance, making the favoured route feel like the primary action rather than one substantive option among peers. Section 28B(2) contains the operative, cumulative test. The final Act does not place \"unreasonably\" before \"manipulate\"; it qualifies only the distortion limb. Section 28B(6)(d) says that creating an environment, including through design elements, that places unreasonable pressure on a consumer or unreasonably obstructs a decision is an example of conduct that may satisfy the prohibition. Before commencement, misleading or deceptive conduct, false representations and other existing ACL provisions may already apply to particular designs. An ACCC enforcement priority is not an early commencement of section 28B. Dedicated ACCC implementation guidance had not been identified by the review date.","contextFactors":["Two or more options address the same decision.","The business-favoured option is identified with evidence.","Measured prominence differs across at least two independent visual or affordance signals.","Boundary to test: Primary progress versus back navigation that does not represent parallel substantive outcomes","Boundary to test: visual difference with no identifiable business-favoured consequence","What decision is the consumer being asked to make?","Does visual hierarchy, sequence, repetition or friction steer toward the trader's preferred result?","Can the consumer identify and choose a neutral alternative without disproportionate effort?","Is pressure real and time-limited, or manufactured by the interface?","What financial, time, privacy or other detriment could result?","Would mobile, accessibility or language constraints intensify the effect?"],"affectedTeams":["Product","Design","Engineering","Marketing","Legal","Customer Support"],"reviewQuestions":["Do “Accept all” and “Use necessary data only” receive comparable prominence and explain their consequences before activation?","Capture every peer option, its default state and visual prominence; do those states support “Two or more options address the same decision”?","What neutral rendering or comprehension result would falsify the classification, particularly in light of “Primary progress versus back navigation that does not represent parallel substantive outcomes”?","Do “$240 billed now” and “Choose monthly or annual” receive comparable prominence and explain their consequences before activation?","Place the compared prices, billing periods and material terms on one evidence sheet; where does it support “The business-favoured option is identified with evidence”?","What neutral rendering or comprehension result would falsify the classification, particularly in light of “visual difference with no identifiable business-favoured consequence”?","What neutral option would a consumer reasonably expect here, and can they find it?","Does any pressure claim reflect a real operational constraint?","Do interaction logs reveal repeated backtracking, accidental selection or immediate reversal?","Could the journey cause detriment even if the price disclosure is literally accurate?","Has the mobile and assistive-technology experience been reviewed?"],"evidence":["annotated screenshots for each responsive breakpoint","design-system component states and copy variants","inventory or reservation logic supporting urgency claims","usability-test protocol and findings","funnel, reversal and complaint data","approval record linking design choices to reviewed risks","Annotated signup and subscription screenshots at each responsive breakpoint","The complete state sequence before, during and after the consumer decision","Design-system component, content, default and configuration records for the reviewed release","Operational records substantiating price, availability, timing and eligibility claims","Usability, accessibility, reversal, complaint and support evidence relevant to consumer impact","A dated product and legal review record identifying evidence, uncertainties and release decisions"],"related":["bundled-options","choice-or-information-overload","complex-or-inaccessible-language","disguised-advertisement-or-action"],"sourceIds":["oecd-dark-commercial-patterns-2022","au-act-2026-64","au-acl-2010","au-accc-priorities-2026","au-treasury-announcement-2026"],"altText":"Side-by-side privacy choice interface showing “Choose your privacy settings” and the clearer alternative “Choose your privacy settings”.","provenance":"Original hypothetical interface comparisons from the shared learning library, adapted to Australian-dollar context for this portal; no real business, product or interface is depicted.","author":"Flowlane","datePublished":"2026-08-09","dateModified":"2026-09-14","lastReviewed":"2026-09-14","changeNote":"Source comparison recorded and the current status restated."},{"title":"Feedforward ambiguity","slug":"feedforward-ambiguity","preferredName":"Feedforward ambiguity","directAnswer":"Feedforward ambiguity is a working label for this design mechanism: A control does not let the user reasonably predict its material outcome before activation. This is editorial implementation guidance for Australian journeys, not a finding of unlawfulness. From 1 July 2027, a similar interface is relevant to ACL section 28B only if the complete consumer-connection, manipulation or unreasonable-distortion and actual-or-likely-detriment test is met. Current ACL rules require a separate assessment.","definition":"A control does not let the user reasonably predict its material outcome before activation. This is a design and research taxonomy for learning and evidence review, not a statutory offence label or an automatic finding that an interface is unlawful.","synonyms":["ambiguous action","misleading action","ambiguous CTA","generic continue label hides commitment","icon outcome unclear","label describes process but not consequence"],"category":"Interface interference","family":"Interface interference","journeyStages":["Checkout","Account Management"],"jurisdiction":"Australia","status":"Editorial implementation guidance","howItWorks":"A control does not let the user reasonably predict its material outcome before activation. The control fails to predict the action or state change it triggers, leaving the user unable to distinguish continuation, submission, payment or publication before activation.","warningSigns":["The action has a material outcome.","Label and nearby explanation fail to communicate that outcome.","Execution evidence shows a consequence that a reasonable interpretation would not predict."],"harms":["A shopper cannot predict that the next action creates a payment obligation.","A person may expose account activity while believing they restricted it."],"legitimateUses":["Conventional navigation with no material commitment","clearly disclosed intermediate step before any consequence"],"legalBasis":[{"provision":"ACL section 28B, inserted by the 2026 Act","sourceIds":["au-act-2026-64"],"classification":"Possible risk indicator","explanation":"In checkout and account management journeys, the feedforward ambiguity mechanism may warrant review where it manipulates a consumer or unreasonably distorts the decision environment and causes, or is likely to cause, detriment. The interface interference label and an interface similarity do not establish a contravention; the complete section 28B test, scope, facts and evidence must be applied from 1 July 2027."},{"provision":"Dark-pattern research taxonomy","sourceIds":["gray-ontology-dark-patterns-2024"],"classification":"Editorial analysis","explanation":"The cited research sources support this working pattern within the interface interference family. It is editorial implementation guidance, not an Australian statutory category, regulator finding or legal safe harbour."}],"examples":[{"type":"Illustrative example","context":"“Continue” places a paid order","scenario":"A fictional checkout ends with a button labelled only “Continue”, although activating it immediately places the $86 order.","harm":"A shopper cannot predict that the next action creates a payment obligation."},{"type":"Illustrative example","context":"Sharing toggle has no visible state meaning","scenario":"A fictional profile uses a switch labelled “Visibility” without saying whether the current position makes activity public or private.","harm":"A person may expose account activity while believing they restricted it."}],"problematicUi":{"label":"Review complete","copy":"Review complete The final control gives no indication that it submits payment. Continue Place order and pay $86","annotations":["Why this state matters: The presentation changes what the user can notice or predict at the checkout decision. The problematic state shows: “The final control gives no indication that it submits payment.” Its influence should be tested by comparing the consequence and usability of “Continue” with “Place order and pay $86”. A shopper cannot predict that the next action creates a payment obligation.","Review prompt: Do “Continue” and “Place order and pay $86” receive comparable prominence and explain their consequences before activation?"]},"improvedUi":{"label":"Ready to place order","copy":"Ready to place order The action states the purchase outcome and amount. Amount affected $86 Place order and pay $86 Continue Payable total and selected items The summary shows the line items and total before “Place order and pay $86” is activated.","annotations":["Fairer design: Name the material outcome and payable total directly on the final control, before activation creates the order.","Review prompt: Compare the basket before and after the action, including total and line items; does the mutation satisfy “The action has a material outcome”?"]},"uiComparisons":[{"id":"feedforward-ambiguity-scenario-1","title":"“Continue” places a paid order","context":"One-page checkout","journeyStage":"Checkout","summary":"A fictional checkout ends with a button labelled only “Continue”, although activating it immediately places the $86 order.","problematic":{"label":"Review complete","layout":"checkout-summary","elements":[{"id":"problematic-1-heading","type":"heading","text":"Review complete"},{"id":"problematic-2-body","type":"text","text":"The final control gives no indication that it submits payment.","tone":"warning"},{"id":"problematic-3-button","type":"button","text":"Continue","emphasis":"primary"},{"id":"problematic-4-link","type":"link","text":"Place order and pay $86","emphasis":"subtle"}],"annotations":[{"targetId":"problematic-2-body","text":"Why this state matters: The presentation changes what the user can notice or predict at the checkout decision. The problematic state shows: “The final control gives no indication that it submits payment.” Its influence should be tested by comparing the consequence and usability of “Continue” with “Place order and pay $86”. A shopper cannot predict that the next action creates a payment obligation."},{"targetId":"problematic-4-link","text":"Review prompt: Do “Continue” and “Place order and pay $86” receive comparable prominence and explain their consequences before activation?"}]},"neutral":{"label":"Ready to place order","layout":"checkout-summary","elements":[{"id":"neutral-1-heading","type":"heading","text":"Ready to place order"},{"id":"neutral-2-body","type":"text","text":"The action states the purchase outcome and amount.","tone":"default"},{"id":"neutral-3-price","type":"price","label":"Amount affected","amount":"$86"},{"id":"neutral-4-button","type":"button","text":"Place order and pay $86","emphasis":"secondary"},{"id":"neutral-5-link","type":"link","text":"Continue","emphasis":"default"},{"id":"neutral-6-disclosure","type":"disclosure","summary":"Payable total and selected items","content":"The summary shows the line items and total before “Place order and pay $86” is activated.","open":true}],"annotations":[{"targetId":"neutral-2-body","text":"Fairer design: Name the material outcome and payable total directly on the final control, before activation creates the order."},{"targetId":"neutral-6-disclosure","text":"Review prompt: Compare the basket before and after the action, including total and line items; does the mutation satisfy “The action has a material outcome”?"}]},"whyItMatters":"The presentation changes what the user can notice or predict at the checkout decision. The problematic state shows: “The final control gives no indication that it submits payment.” Its influence should be tested by comparing the consequence and usability of “Continue” with “Place order and pay $86”. A shopper cannot predict that the next action creates a payment obligation.","fairDesignPrinciple":"Name the material outcome and payable total directly on the final control, before activation creates the order.","reviewPrompts":["Do “Continue” and “Place order and pay $86” receive comparable prominence and explain their consequences before activation?","Compare the basket before and after the action, including total and line items; does the mutation satisfy “The action has a material outcome”?","What neutral rendering or comprehension result would falsify the classification, particularly in light of “Conventional navigation with no material commitment”?"],"altText":"Side-by-side one-page checkout interface showing “Review complete” and the clearer alternative “Ready to place order”.","provenance":"Original hypothetical one-page checkout example created for this library; no real business, product or interface is depicted."},{"id":"feedforward-ambiguity-scenario-2","title":"Sharing toggle has no visible state meaning","context":"Profile privacy","journeyStage":"Account Management","summary":"A fictional profile uses a switch labelled “Visibility” without saying whether the current position makes activity public or private.","problematic":{"label":"Visibility","layout":"account-panel","elements":[{"id":"problematic-1-heading","type":"heading","text":"Visibility"},{"id":"problematic-2-body","type":"text","text":"The switch position has no explanatory state or audience.","tone":"warning"},{"id":"problematic-3-link","type":"link","text":"On","emphasis":"subtle"},{"id":"problematic-4-badge","type":"badge","text":"Unconfirmed state: On","tone":"warning"}],"annotations":[{"targetId":"problematic-2-body","text":"Why this state matters: The presentation changes what the user can notice or predict at the account management decision. The problematic state shows: “The switch position has no explanatory state or audience.” Its influence should be tested by comparing the consequence and usability of “On” with “Change to public”. A person may expose account activity while believing they restricted it."},{"targetId":"problematic-4-badge","text":"Review prompt: Do “On” and “Change to public” receive comparable prominence and explain their consequences before activation?"}]},"neutral":{"label":"Activity visibility · Private","layout":"account-panel","elements":[{"id":"neutral-1-heading","type":"heading","text":"Activity visibility · Private"},{"id":"neutral-2-body","type":"text","text":"The control names the current audience and the alternative outcome.","tone":"default"},{"id":"neutral-3-link","type":"link","text":"Change to public","emphasis":"default"},{"id":"neutral-4-badge","type":"badge","text":"Saved state: Change to public","tone":"default"},{"id":"neutral-5-disclosure","type":"disclosure","summary":"Persisted account state","content":"The saved state behind “Change to public” remains consistent after refresh and across supported channels.","open":true}],"annotations":[{"targetId":"neutral-2-body","text":"Fairer design: State the current audience and the effect of changing the control before saving."},{"targetId":"neutral-5-disclosure","text":"Review prompt: Test the control across refresh, device and account states; is “Label and nearby explanation fail to communicate that outcome” still observable after persistence is considered?"}]},"whyItMatters":"The presentation changes what the user can notice or predict at the account management decision. The problematic state shows: “The switch position has no explanatory state or audience.” Its influence should be tested by comparing the consequence and usability of “On” with “Change to public”. A person may expose account activity while believing they restricted it.","fairDesignPrinciple":"State the current audience and the effect of changing the control before saving.","reviewPrompts":["Do “On” and “Change to public” receive comparable prominence and explain their consequences before activation?","Test the control across refresh, device and account states; is “Label and nearby explanation fail to communicate that outcome” still observable after persistence is considered?","What neutral rendering or comprehension result would falsify the classification, particularly in light of “clearly disclosed intermediate step before any consequence”?"],"altText":"Side-by-side profile privacy interface showing “Visibility” and the clearer alternative “Activity visibility · Private”.","provenance":"Original hypothetical profile privacy example created for this library; no real business, product or interface is depicted."}],"fairAlternative":"Name the material consequence in the action label or immediately adjacent disclosure before activation.","whyProblematic":"A control does not let the user reasonably predict its material outcome before activation. The control fails to predict the action or state change it triggers, leaving the user unable to distinguish continuation, submission, payment or publication before activation. These harms describe a review risk, not an automatic legal conclusion. Australian section 28B commences on 1 July 2027 and requires its complete, context-specific test. Existing ACL provisions remain a separate current-law assessment.","contextFactors":["The action has a material outcome.","Label and nearby explanation fail to communicate that outcome.","Execution evidence shows a consequence that a reasonable interpretation would not predict.","Boundary to test: Conventional navigation with no material commitment","Boundary to test: clearly disclosed intermediate step before any consequence"],"affectedTeams":["Product","Design","Engineering","Legal","Compliance"],"reviewQuestions":["Do “Continue” and “Place order and pay $86” receive comparable prominence and explain their consequences before activation?","Compare the basket before and after the action, including total and line items; does the mutation satisfy “The action has a material outcome”?","What neutral rendering or comprehension result would falsify the classification, particularly in light of “Conventional navigation with no material commitment”?","Do “On” and “Change to public” receive comparable prominence and explain their consequences before activation?","Test the control across refresh, device and account states; is “Label and nearby explanation fail to communicate that outcome” still observable after persistence is considered?","What neutral rendering or comprehension result would falsify the classification, particularly in light of “clearly disclosed intermediate step before any consequence”?"],"evidence":["Annotated checkout and account management screenshots at each responsive breakpoint","The complete state sequence before, during and after the consumer decision","Design-system component, content, default and configuration records for the reviewed release","Operational records substantiating price, availability, timing and eligibility claims","Usability, accessibility, reversal, complaint and support evidence relevant to consumer impact","A dated product and legal review record identifying evidence, uncertainties and release decisions"],"related":["bundled-options","choice-or-information-overload","complex-or-inaccessible-language","disguised-advertisement-or-action"],"sourceIds":["gray-ontology-dark-patterns-2024","au-act-2026-64"],"altText":"Side-by-side one-page checkout interface showing “Review complete” and the clearer alternative “Ready to place order”.","provenance":"Original hypothetical interface comparisons from the shared learning library, adapted to Australian-dollar context for this portal; no real business, product or interface is depicted.","author":"Flowlane","datePublished":"2026-08-10","dateModified":"2026-09-14","lastReviewed":"2026-09-14","changeNote":"Source comparison recorded and the current status restated."},{"title":"Hidden or ineffective material information","slug":"hidden-or-ineffective-material-information","preferredName":"Hidden or ineffective material information","directAnswer":"The final Act identifies failure to disclose material information, and disclosure that is complex, ineffective, unclear, unintelligible, ambiguous, untimely or overwhelming, as examples of conduct that may be an unfair trading practice. From 1 July 2027 the full section 28B test still applies. Existing misleading-conduct law can already apply to omissions and overall impressions in context.","definition":"Information relevant to the decision is absent or presented so ineffectively that it is unlikely to inform the user at the decision point. This is a design and research taxonomy for learning and evidence review, not a statutory offence label or an automatic finding that an interface is unlawful.","synonyms":["hidden information","hidden in plain sight","low salience material information","missing","visually hidden","low salience","collapsed","unclear","ambiguous","untimely","overwhelming","buried disclosure","ambiguous disclosure","late disclosure","information overload","Hidden or low-salience material information"],"category":"Interface interference","family":"Interface interference","journeyStages":["Pricing"],"jurisdiction":"Australia","status":"Commences 1 July 2027","howItWorks":"Information relevant to the decision is absent or presented so ineffectively that it is unlikely to inform the user at the decision point. A consequence that could change the decision is moved out of the comparison or commitment view, reduced in salience or split across remote disclosures.","warningSigns":["The information is plausibly material to a concrete decision.","It is missing, hidden, low-salience, unclear, inaccessible, untimely or overwhelming.","The deficiency is tied to a likely influence mechanism or detriment."],"harms":["A traveller may select an unsuitable fare because a material restriction is absent from the comparison decision.","A customer may buy unsuitable cover because a material limitation cannot inform the decision."],"legitimateUses":["Purely optional detail with no plausible decision relevance","late mandatory charge or subscription term already classified under the more specific sneaking pattern for the same evidence"],"legalBasis":[{"provision":"ACL section 28B(6)(b), inserted by the 2026 Act","sourceIds":["au-act-2026-64"],"classification":"Possible risk indicator","explanation":"Failure to disclose material information is a non-exhaustive example that may be an unfair trading practice."},{"provision":"ACL section 28B(6)(c), inserted by the 2026 Act","sourceIds":["au-act-2026-64"],"classification":"Possible risk indicator","explanation":"Complex, ineffective, unclear, unintelligible, ambiguous, untimely or overwhelming disclosure is another non-exhaustive example."},{"provision":"ACL sections 18 and 29","sourceIds":["au-acl-2010"],"classification":"Current law","explanation":"Existing provisions may already address an omission or presentation that creates a misleading overall impression or false representation."}],"examples":[{"type":"Illustrative example","context":"Non-refundable condition appears after fare selection","scenario":"A fictional rail booking page labels a fare “Flexible Saver” but places the fact that it is non-refundable inside a collapsed section reached only after passenger details.","harm":"A traveller may select an unsuitable fare because a material restriction is absent from the comparison decision."},{"type":"Illustrative example","context":"Major exclusion dispersed across tabs","scenario":"A fictional repair plan headlines “Every appliance covered” but splits an exclusion for boilers across three collapsed help tabs reached only after booking.","harm":"A customer may buy unsuitable cover because a material limitation cannot inform the decision."},{"type":"Illustrative example","context":"Renewal term below the commit button","scenario":"A learning app promotes a seven-day free trial. The annual charge and automatic renewal appear only below the fixed mobile purchase button and are never brought into view.","harm":"The renewal liability is likely material, and its placement may make the disclosure ineffective or untimely. Subscription-specific disclosure rules will also need to be checked once they commence."},{"type":"Illustrative example","context":"Critical exclusion dispersed across tabs","scenario":"A home-services offer headlines 'all repairs included' but divides a major appliance exclusion across several collapsed help-centre tabs reached only after booking.","harm":"The overall impression and inaccessible correction may be misleading now and may become relevant to sections 28B(6)(b) to (c) from commencement."},{"type":"Enforcement example","context":"eDreams subscription pricing","scenario":"The ACCC said a headline monthly Prime price did not adequately convey total annual cost. Procedural posture: Infringement notices and undertaking; the undertaking contains admissions, while notice payment alone is not an admission.","harm":"This is verified current-ACL context, not enforcement of provisions commencing in 2027.","sourceIds":["au-accc-edreams-2026"]},{"type":"Enforcement example","context":"JustAnswer pricing representations","scenario":"A prominent one-off amount was contrasted with a materially larger recurring subscription charge. Procedural posture: Federal Court orders following admissions.","harm":"This is verified current-ACL context, not enforcement of provisions commencing in 2027.","sourceIds":["au-accc-justanswer-2026"]}],"problematicUi":{"label":"Flexible Saver · $64","copy":"Flexible Saver · $64 The non-refundable condition is absent from the fare card and comparison table. Displayed amount $64 Choose $64 fare Review fare conditions","annotations":["Why this state matters: The presentation changes what the user can notice or predict at the pricing decision. The problematic state shows: “The non-refundable condition is absent from the fare card and comparison table.” Its influence should be tested by comparing the consequence and usability of “Choose $64 fare” with “Review fare conditions”. A traveller may select an unsuitable fare because a material restriction is absent from the comparison decision.","Review prompt: Do “Choose $64 fare” and “Review fare conditions” receive comparable prominence and explain their consequences before activation?"]},"improvedUi":{"label":"Saver · $64 · non-refundable","copy":"Saver · $64 · non-refundable Price and the material restriction appear together before selection. Review fare conditions Choose $64 fare Price, period and commitment The price and material terms associated with “Review fare conditions” remain beside this choice.","annotations":["Fairer design: Place refundability, change conditions and any material restriction beside each fare before selection.","Review prompt: Place the compared prices, billing periods and material terms on one evidence sheet; where does it support “The information is plausibly material to a concrete decision”?"]},"uiComparisons":[{"id":"hidden-or-low-salience-material-information-scenario-1","title":"Non-refundable condition appears after fare selection","context":"Rail fare comparison","journeyStage":"Pricing","summary":"A fictional rail booking page labels a fare “Flexible Saver” but places the fact that it is non-refundable inside a collapsed section reached only after passenger details.","problematic":{"label":"Flexible Saver · $64","layout":"pricing-card","elements":[{"id":"problematic-1-heading","type":"heading","text":"Flexible Saver · $64"},{"id":"problematic-2-body","type":"text","text":"The non-refundable condition is absent from the fare card and comparison table.","tone":"warning"},{"id":"problematic-3-price","type":"price","label":"Displayed amount","amount":"$64"},{"id":"problematic-4-button","type":"button","text":"Choose $64 fare","emphasis":"primary"},{"id":"problematic-5-link","type":"link","text":"Review fare conditions","emphasis":"subtle"}],"annotations":[{"targetId":"problematic-2-body","text":"Why this state matters: The presentation changes what the user can notice or predict at the pricing decision. The problematic state shows: “The non-refundable condition is absent from the fare card and comparison table.” Its influence should be tested by comparing the consequence and usability of “Choose $64 fare” with “Review fare conditions”. A traveller may select an unsuitable fare because a material restriction is absent from the comparison decision."},{"targetId":"problematic-5-link","text":"Review prompt: Do “Choose $64 fare” and “Review fare conditions” receive comparable prominence and explain their consequences before activation?"}]},"neutral":{"label":"Saver · $64 · non-refundable","layout":"pricing-card","elements":[{"id":"neutral-1-heading","type":"heading","text":"Saver · $64 · non-refundable"},{"id":"neutral-2-body","type":"text","text":"Price and the material restriction appear together before selection.","tone":"default"},{"id":"neutral-3-button","type":"button","text":"Review fare conditions","emphasis":"secondary"},{"id":"neutral-4-link","type":"link","text":"Choose $64 fare","emphasis":"default"},{"id":"neutral-5-disclosure","type":"disclosure","summary":"Price, period and commitment","content":"The price and material terms associated with “Review fare conditions” remain beside this choice.","open":true}],"annotations":[{"targetId":"neutral-2-body","text":"Fairer design: Place refundability, change conditions and any material restriction beside each fare before selection."},{"targetId":"neutral-5-disclosure","text":"Review prompt: Place the compared prices, billing periods and material terms on one evidence sheet; where does it support “The information is plausibly material to a concrete decision”?"}]},"whyItMatters":"The presentation changes what the user can notice or predict at the pricing decision. The problematic state shows: “The non-refundable condition is absent from the fare card and comparison table.” Its influence should be tested by comparing the consequence and usability of “Choose $64 fare” with “Review fare conditions”. A traveller may select an unsuitable fare because a material restriction is absent from the comparison decision.","fairDesignPrinciple":"Place refundability, change conditions and any material restriction beside each fare before selection.","reviewPrompts":["Do “Choose $64 fare” and “Review fare conditions” receive comparable prominence and explain their consequences before activation?","Place the compared prices, billing periods and material terms on one evidence sheet; where does it support “The information is plausibly material to a concrete decision”?","What neutral rendering or comprehension result would falsify the classification, particularly in light of “Purely optional detail with no plausible decision relevance”?"],"altText":"Side-by-side rail fare comparison interface showing “Flexible Saver · $64” and the clearer alternative “Saver · $64 · non-refundable”.","provenance":"Original hypothetical rail fare comparison example created for this library; no real business, product or interface is depicted."},{"id":"hidden-or-low-salience-material-information-scenario-2","title":"Major exclusion dispersed across tabs","context":"Home-services plan","journeyStage":"Pricing","summary":"A fictional repair plan headlines “Every appliance covered” but splits an exclusion for boilers across three collapsed help tabs reached only after booking.","problematic":{"label":"Every appliance covered","layout":"form","elements":[{"id":"problematic-1-heading","type":"heading","text":"Every appliance covered"},{"id":"problematic-2-body","type":"text","text":"The boiler exclusion appears only across several remote help tabs.","tone":"warning"},{"id":"problematic-3-disclosure","type":"disclosure","summary":"See full terms","content":"See full terms","open":false},{"id":"problematic-4-link","type":"link","text":"Review coverage","emphasis":"subtle"}],"annotations":[{"targetId":"problematic-2-body","text":"Why this state matters: The presentation changes what the user can notice or predict at the pricing decision. The problematic state shows: “The boiler exclusion appears only across several remote help tabs.” Its influence should be tested by comparing the consequence and usability of “See full terms” with “Review coverage”. A customer may buy unsuitable cover because a material limitation cannot inform the decision."},{"targetId":"problematic-4-link","text":"Review prompt: Do “See full terms” and “Review coverage” receive comparable prominence and explain their consequences before activation?"}]},"neutral":{"label":"Core coverage and exclusions","layout":"form","elements":[{"id":"neutral-1-heading","type":"heading","text":"Core coverage and exclusions"},{"id":"neutral-2-body","type":"text","text":"Boilers are not covered; the limitation appears beside the plan summary.","tone":"default"},{"id":"neutral-3-disclosure","type":"disclosure","summary":"Review coverage","content":"Review coverage","open":true},{"id":"neutral-4-link","type":"link","text":"See full terms","emphasis":"default"},{"id":"neutral-5-badge","type":"badge","text":"Material term visible before choice: Review coverage","tone":"default"}],"annotations":[{"targetId":"neutral-2-body","text":"Fairer design: State the major exclusion in the offer summary and use supporting detail to explain, not reverse, the headline."},{"targetId":"neutral-5-badge","text":"Review prompt: Capture the collapsed and expanded states plus the associated decision control; is “It is missing, hidden, low-salience, unclear, inaccessible, untimely or overwhelming” visible at the right time?"}]},"whyItMatters":"The presentation changes what the user can notice or predict at the pricing decision. The problematic state shows: “The boiler exclusion appears only across several remote help tabs.” Its influence should be tested by comparing the consequence and usability of “See full terms” with “Review coverage”. A customer may buy unsuitable cover because a material limitation cannot inform the decision.","fairDesignPrinciple":"State the major exclusion in the offer summary and use supporting detail to explain, not reverse, the headline.","reviewPrompts":["Do “See full terms” and “Review coverage” receive comparable prominence and explain their consequences before activation?","Capture the collapsed and expanded states plus the associated decision control; is “It is missing, hidden, low-salience, unclear, inaccessible, untimely or overwhelming” visible at the right time?","What neutral rendering or comprehension result would falsify the classification, particularly in light of “late mandatory charge or subscription term already classified under the more specific sneaking pattern for the same evidence”?"],"altText":"Side-by-side home-services plan interface showing “Every appliance covered” and the clearer alternative “Core coverage and exclusions”.","provenance":"Original hypothetical home-services plan example created for this library; no real business, product or interface is depicted."}],"fairAlternative":"Present material information clearly, prominently and at the point where it can affect the decision; do not rely on optional expansion or late disclosure.","whyProblematic":"Information relevant to the decision is absent or presented so ineffectively that it is unlikely to inform the user at the decision point. A consequence that could change the decision is moved out of the comparison or commitment view, reduced in salience or split across remote disclosures. Sections 28B(6)(b) and (c) expressly identify non-disclosure and ineffective disclosure of material information. The word \"may\" matters: materiality, consumer context, manipulation or unreasonable distortion and likely detriment must be assessed rather than presumed. The new prohibition has not commenced, but existing ACL disclosure, misleading-conduct, price and contract rules may apply now. No final ACCC section 28B materiality or disclosure guide had been identified by the review date.","contextFactors":["The information is plausibly material to a concrete decision.","It is missing, hidden, low-salience, unclear, inaccessible, untimely or overwhelming.","The deficiency is tied to a likely influence mechanism or detriment.","Boundary to test: Purely optional detail with no plausible decision relevance","Boundary to test: late mandatory charge or subscription term already classified under the more specific sneaking pattern for the same evidence","Would the information affect price, duration, renewal, use, eligibility, cancellation or risk?","Is it visible before the consumer becomes committed?","Does the mobile view preserve prominence and meaning?","Are headline claims corrected only by remote or contradictory fine print?","Is the amount and structure of information usable rather than merely complete?"],"affectedTeams":["Product","Design","Content Design","Marketing","Legal","Customer Support"],"reviewQuestions":["Do “Choose $64 fare” and “Review fare conditions” receive comparable prominence and explain their consequences before activation?","Place the compared prices, billing periods and material terms on one evidence sheet; where does it support “The information is plausibly material to a concrete decision”?","What neutral rendering or comprehension result would falsify the classification, particularly in light of “Purely optional detail with no plausible decision relevance”?","Do “See full terms” and “Review coverage” receive comparable prominence and explain their consequences before activation?","Capture the collapsed and expanded states plus the associated decision control; is “It is missing, hidden, low-salience, unclear, inaccessible, untimely or overwhelming” visible at the right time?","What neutral rendering or comprehension result would falsify the classification, particularly in light of “late mandatory charge or subscription term already classified under the more specific sneaking pattern for the same evidence”?","Which facts would make a reasonable consumer choose differently?","Can the consumer encounter each material fact before the associated decision?","Does the headline remain accurate without relying on fine print?","Are disclosures understandable at ordinary zoom and on a small screen?","Do complaints or refunds indicate a recurring misunderstanding?"],"evidence":["material-information inventory","annotated journey showing disclosure timing","responsive screenshots and accessibility checks","copy and legal approval history","complaint, cancellation and refund themes","user-comprehension test results","Annotated pricing screenshots at each responsive breakpoint","The complete state sequence before, during and after the consumer decision","Design-system component, content, default and configuration records for the reviewed release","Operational records substantiating price, availability, timing and eligibility claims","Usability, accessibility, reversal, complaint and support evidence relevant to consumer impact","A dated product and legal review record identifying evidence, uncertainties and release decisions"],"related":["bundled-options","choice-or-information-overload","complex-or-inaccessible-language","disguised-advertisement-or-action"],"sourceIds":["oecd-dark-commercial-patterns-2022","au-act-2026-64","au-acl-2010","au-accc-edreams-2026","au-accc-justanswer-2026"],"altText":"Side-by-side rail fare comparison interface showing “Flexible Saver · $64” and the clearer alternative “Saver · $64 · non-refundable”.","provenance":"Original hypothetical interface comparisons from the shared learning library, adapted to Australian-dollar context for this portal; no real business, product or interface is depicted.","author":"Flowlane","datePublished":"2026-08-09","dateModified":"2026-09-14","lastReviewed":"2026-09-14","changeNote":"Source comparison recorded and the current status restated."},{"title":"Confirmshaming and emotional pressure","slug":"confirmshaming-and-emotional-pressure","preferredName":"Confirmshaming and emotional pressure","directAnswer":"Confirmshaming is design terminology, not a named offence in the final Act. Loaded language may nevertheless manipulate a consumer or contribute to unreasonable pressure or distortion under section 28B from 1 July 2027, where likely financial or other detriment also exists. Tone alone is not enough; placement, repetition, choice structure and consequence matter.","definition":"Option labels use shame, guilt, fear or asymmetric emotional framing to move the user away from the outcome they would otherwise choose. This is a design and research taxonomy for learning and evidence review, not a statutory offence label or an automatic finding that an interface is unlawful.","synonyms":["confirmshaming","toying with emotion","emotional steering","positive or negative framing","shaming decline","fear-based acceptance","morally loaded option","asymmetric benefit/loss framing","guilt language","loaded choice","emotional manipulation","shaming decline copy","Manipulative choice wording"],"category":"Interface interference","family":"Interface interference","journeyStages":["Checkout","Cancellation"],"jurisdiction":"Australia","status":"Commences 1 July 2027","howItWorks":"Option labels use shame, guilt, fear or asymmetric emotional framing to move the user away from the outcome they would otherwise choose. One option is framed with guilt, fear or judgment, shifting attention from the commercial consequence to an emotional claim about the person choosing.","warningSigns":["The language is attached to a concrete choice.","Emotion or judgement is materially asymmetric between options.","The framing favours a business outcome and has a plausible detrimental consequence."],"harms":["Guilt-laden wording may pressure a shopper to buy rather than evaluate the product.","Repeated social guilt may deter or delay an intended cancellation."],"legitimateUses":["General brand tone not linked to a decision","neutral explanation of a real consequence"],"legalBasis":[{"provision":"ACL section 28B(2), inserted by the 2026 Act","sourceIds":["au-act-2026-64"],"classification":"Possible risk indicator","explanation":"Potentially applies where the language manipulates or unreasonably distorts the decision environment and causes or is likely to cause detriment."},{"provision":"ACL section 28B(6)(d), inserted by the 2026 Act","sourceIds":["au-act-2026-64"],"classification":"Possible risk indicator","explanation":"Identifies unreasonable pressure in a decision environment as a non-exhaustive example."}],"examples":[{"type":"Illustrative example","context":"Decline copy shames a safety choice","scenario":"A fictional checkout labels an $18 protection purchase “Protect my family” and the refusal “No, I do not care if they are at risk”.","harm":"Guilt-laden wording may pressure a shopper to buy rather than evaluate the product."},{"type":"Illustrative example","context":"Cancellation message frames departure as betrayal","scenario":"A fictional service tells a subscriber that leaving will “let the whole community down” before each of three confirmation steps.","harm":"Repeated social guilt may deter or delay an intended cancellation."},{"type":"Illustrative example","context":"Shaming decline on a paid add-on","scenario":"At checkout, the add-on button says 'Protect my family for $18' while the only decline says 'No, I do not care if they are at risk'.","harm":"The loaded decline may exert emotional pressure toward a paid selection. Likely detriment and the whole interface context determine section 28B risk."},{"type":"Illustrative example","context":"Guilt loop during cancellation","scenario":"A cancellation flow repeatedly says the consumer is 'letting the community down' and requires three confirmations framed as personal failures.","harm":"Repeated guilt language combined with exit friction may manipulate or unreasonably pressure a consumer and obstruct the decision to end. Section 48F may also apply for a covered subscription."}],"problematicUi":{"label":"Add protection","copy":"Add protection The decline labels the shopper as uncaring. No, I accept the risk Continue without protection","annotations":["Why this state matters: The presentation changes what the user can notice or predict at the checkout decision. The problematic state shows: “The decline labels the shopper as uncaring.” Its influence should be tested by comparing the consequence and usability of “No, I accept the risk” with “Continue without protection”. Guilt-laden wording may pressure a shopper to buy rather than evaluate the product.","Review prompt: Do “No, I accept the risk” and “Continue without protection” receive comparable prominence and explain their consequences before activation?"]},"improvedUi":{"label":"Optional protection · $18","copy":"Optional protection · $18 Both controls state the commercial outcome in neutral language. Continue without protection No, I accept the risk Choice consequences The consequence of selecting “Continue without protection” is displayed beside the option.","annotations":["Fairer design: Describe acceptance and refusal accurately without judging the person making the choice.","Review prompt: Capture every peer option, its default state and visual prominence; do those states support “The language is attached to a concrete choice”?"]},"uiComparisons":[{"id":"manipulative-choice-wording-scenario-1","title":"Decline copy shames a safety choice","context":"Checkout add-on","journeyStage":"Checkout","summary":"A fictional checkout labels an $18 protection purchase “Protect my family” and the refusal “No, I do not care if they are at risk”.","problematic":{"label":"Add protection","layout":"choice-list","elements":[{"id":"problematic-1-heading","type":"heading","text":"Add protection"},{"id":"problematic-2-body","type":"text","text":"The decline labels the shopper as uncaring.","tone":"warning"},{"id":"problematic-3-radio","type":"radio","label":"No, I accept the risk","checked":true},{"id":"problematic-4-radio","type":"radio","label":"Continue without protection","checked":false}],"annotations":[{"targetId":"problematic-2-body","text":"Why this state matters: The presentation changes what the user can notice or predict at the checkout decision. The problematic state shows: “The decline labels the shopper as uncaring.” Its influence should be tested by comparing the consequence and usability of “No, I accept the risk” with “Continue without protection”. Guilt-laden wording may pressure a shopper to buy rather than evaluate the product."},{"targetId":"problematic-4-radio","text":"Review prompt: Do “No, I accept the risk” and “Continue without protection” receive comparable prominence and explain their consequences before activation?"}]},"neutral":{"label":"Optional protection · $18","layout":"choice-list","elements":[{"id":"neutral-1-heading","type":"heading","text":"Optional protection · $18"},{"id":"neutral-2-body","type":"text","text":"Both controls state the commercial outcome in neutral language.","tone":"default"},{"id":"neutral-3-radio","type":"radio","label":"Continue without protection","checked":false},{"id":"neutral-4-radio","type":"radio","label":"No, I accept the risk","checked":false},{"id":"neutral-5-disclosure","type":"disclosure","summary":"Choice consequences","content":"The consequence of selecting “Continue without protection” is displayed beside the option.","open":true}],"annotations":[{"targetId":"neutral-2-body","text":"Fairer design: Describe acceptance and refusal accurately without judging the person making the choice."},{"targetId":"neutral-5-disclosure","text":"Review prompt: Capture every peer option, its default state and visual prominence; do those states support “The language is attached to a concrete choice”?"}]},"whyItMatters":"The presentation changes what the user can notice or predict at the checkout decision. The problematic state shows: “The decline labels the shopper as uncaring.” Its influence should be tested by comparing the consequence and usability of “No, I accept the risk” with “Continue without protection”. Guilt-laden wording may pressure a shopper to buy rather than evaluate the product.","fairDesignPrinciple":"Describe acceptance and refusal accurately without judging the person making the choice.","reviewPrompts":["Do “No, I accept the risk” and “Continue without protection” receive comparable prominence and explain their consequences before activation?","Capture every peer option, its default state and visual prominence; do those states support “The language is attached to a concrete choice”?","What neutral rendering or comprehension result would falsify the classification, particularly in light of “General brand tone not linked to a decision”?"],"altText":"Side-by-side checkout add-on interface showing “Add protection” and the clearer alternative “Optional protection · $18”.","provenance":"Original hypothetical checkout add-on example created for this library; no real business, product or interface is depicted."},{"id":"manipulative-choice-wording-scenario-2","title":"Cancellation message frames departure as betrayal","context":"Community subscription","journeyStage":"Cancellation","summary":"A fictional service tells a subscriber that leaving will “let the whole community down” before each of three confirmation steps.","problematic":{"label":"Do not abandon your community","layout":"cancellation-flow","elements":[{"id":"problematic-1-heading","type":"heading","text":"Do not abandon your community"},{"id":"problematic-2-body","type":"text","text":"Each exit step frames cancellation as a personal failure.","tone":"warning"},{"id":"problematic-3-step","type":"step","label":"Blocking step"},{"id":"problematic-4-step","type":"step","label":"Obscured outcome"}],"annotations":[{"targetId":"problematic-2-body","text":"Why this state matters: The presentation changes what the user can notice or predict at the cancellation decision. The problematic state shows: “Each exit step frames cancellation as a personal failure.” Its influence should be tested by comparing the consequence and usability of “Stay and support everyone” with “Confirm cancellation”. Repeated social guilt may deter or delay an intended cancellation."},{"targetId":"problematic-4-step","text":"Review prompt: Do “Stay and support everyone” and “Confirm cancellation” receive comparable prominence and explain their consequences before activation?"}]},"neutral":{"label":"End community plan","layout":"cancellation-flow","elements":[{"id":"neutral-1-heading","type":"heading","text":"End community plan"},{"id":"neutral-2-body","type":"text","text":"The effective date and access consequences are stated without shame.","tone":"default"},{"id":"neutral-3-step","type":"step","label":"Completion step"},{"id":"neutral-4-step","type":"step","label":"Recorded outcome"},{"id":"neutral-5-badge","type":"badge","text":"Request recorded: Confirm cancellation","tone":"default"}],"annotations":[{"targetId":"neutral-2-body","text":"Fairer design: Use factual consequences and a direct confirmation without moral judgment or repeated emotional prompts."},{"targetId":"neutral-5-badge","text":"Review prompt: Count steps, waits, offers and channel changes through final confirmation; where does the route meet “Emotion or judgement is materially asymmetric between options”?"}]},"whyItMatters":"The presentation changes what the user can notice or predict at the cancellation decision. The problematic state shows: “Each exit step frames cancellation as a personal failure.” Its influence should be tested by comparing the consequence and usability of “Stay and support everyone” with “Confirm cancellation”. Repeated social guilt may deter or delay an intended cancellation.","fairDesignPrinciple":"Use factual consequences and a direct confirmation without moral judgment or repeated emotional prompts.","reviewPrompts":["Do “Stay and support everyone” and “Confirm cancellation” receive comparable prominence and explain their consequences before activation?","Count steps, waits, offers and channel changes through final confirmation; where does the route meet “Emotion or judgement is materially asymmetric between options”?","What neutral rendering or comprehension result would falsify the classification, particularly in light of “neutral explanation of a real consequence”?"],"altText":"Side-by-side community subscription interface showing “Do not abandon your community” and the clearer alternative “End community plan”.","provenance":"Original hypothetical community subscription example created for this library; no real business, product or interface is depicted."}],"fairAlternative":"Use neutral, consequence-based labels and avoid shame, fear or moral judgement in decline or alternative actions.","whyProblematic":"Option labels use shame, guilt, fear or asymmetric emotional framing to move the user away from the outcome they would otherwise choose. One option is framed with guilt, fear or judgment, shifting attention from the commercial consequence to an emotional claim about the person choosing. Apply section 28B(2)'s complete test. Section 28B(6)(d) expressly recognises an environment, including digital design elements, that places a consumer under unreasonable pressure as an example that may satisfy the prohibition. It does not name confirmshaming or make every emotionally framed message unlawful. A message that also makes a false claim may engage existing ACL provisions now; this record does not treat mere unpleasant tone as a current statutory breach. Final regulator guidance and Australian case law applying section 28B were unavailable at the review date.","contextFactors":["The language is attached to a concrete choice.","Emotion or judgement is materially asymmetric between options.","The framing favours a business outcome and has a plausible detrimental consequence.","Boundary to test: General brand tone not linked to a decision","Boundary to test: neutral explanation of a real consequence","Does the wording shame a consumer for declining or leaving?","Is it attached to a material payment, data, renewal or cancellation decision?","Does the neutral option remain accurate and usable?","Is the message repeated until the consumer accepts?","Could age, distress or vulnerability amplify the pressure?","What financial or other detriment is likely if the consumer yields?"],"affectedTeams":["Content Design","Marketing","Product","Design","Customer Support","Retention","Legal"],"reviewQuestions":["Do “No, I accept the risk” and “Continue without protection” receive comparable prominence and explain their consequences before activation?","Capture every peer option, its default state and visual prominence; do those states support “The language is attached to a concrete choice”?","What neutral rendering or comprehension result would falsify the classification, particularly in light of “General brand tone not linked to a decision”?","Do “Stay and support everyone” and “Confirm cancellation” receive comparable prominence and explain their consequences before activation?","Count steps, waits, offers and channel changes through final confirmation; where does the route meet “Emotion or judgement is materially asymmetric between options”?","What neutral rendering or comprehension result would falsify the classification, particularly in light of “neutral explanation of a real consequence”?","Would both option labels remain accurate if read without the surrounding campaign?","Does the decline text judge the consumer rather than describe the outcome?","How often is the prompt repeated?","Is a paid or recurring choice involved?","Could the wording deter cancellation, complaint or exercise of a legal right?","Has the copy been tested with potentially vulnerable users?"],"evidence":["interface-copy inventory","content-design principles and approval history","screenshots of each choice state","vulnerable-user and accessibility review","cancellation and decline-path test results","complaints and verbatim user feedback","Annotated checkout and cancellation screenshots at each responsive breakpoint","The complete state sequence before, during and after the consumer decision","Design-system component, content, default and configuration records for the reviewed release","Operational records substantiating price, availability, timing and eligibility claims","Usability, accessibility, reversal, complaint and support evidence relevant to consumer impact","A dated product and legal review record identifying evidence, uncertainties and release decisions"],"related":["bundled-options","choice-or-information-overload","complex-or-inaccessible-language","disguised-advertisement-or-action"],"sourceIds":["oecd-dark-commercial-patterns-2022","au-act-2026-64","au-acl-2010","au-accc-priorities-2026"],"altText":"Side-by-side checkout add-on interface showing “Add protection” and the clearer alternative “Optional protection · $18”.","provenance":"Original hypothetical interface comparisons from the shared learning library, adapted to Australian-dollar context for this portal; no real business, product or interface is depicted.","author":"Flowlane","datePublished":"2026-08-09","dateModified":"2026-09-14","lastReviewed":"2026-09-14","changeNote":"Source comparison recorded and the current status restated."},{"title":"Misleading reference pricing","slug":"misleading-reference-pricing","preferredName":"Misleading reference pricing","directAnswer":"Misleading reference pricing is a working label for this design mechanism: A comparison or prior price creates an inaccurate or insufficiently explained impression of savings. This is editorial implementation guidance for Australian journeys, not a finding of unlawfulness. From 1 July 2027, a similar interface is relevant to ACL section 28B only if the complete consumer-connection, manipulation or unreasonable-distortion and actual-or-likely-detriment test is met. Current ACL rules require a separate assessment.","definition":"A comparison or prior price creates an inaccurate or insufficiently explained impression of savings. This is a design and research taxonomy for learning and evidence review, not a statutory offence label or an automatic finding that an interface is unlawful.","synonyms":["fake discount","false was price","reference-price anchoring","inaccurate struck-through price","unrepresentative prior price","arithmetically inconsistent discount","unclear comparison basis"],"category":"Interface interference","family":"Interface interference","journeyStages":["Pricing"],"jurisdiction":"Australia","status":"Editorial implementation guidance","howItWorks":"A comparison or prior price creates an inaccurate or insufficiently explained impression of savings. A current price is evaluated against an unsupported or non-equivalent comparator, manufacturing a saving that can distort value and timing judgments.","warningSigns":["A current price is framed against a reference or discount claim.","Arithmetic, comparison basis or external history is inconsistent, inaccurate or unverified.","The anchor plausibly affects perceived value."],"harms":["The reference can create an unsupported impression of exceptional savings and rush comparison.","Travellers may overvalue membership because the compared offers are not meaningfully equivalent."],"legitimateUses":["Accurate, representative and clearly explained reference price","mere display of two genuinely different product prices"],"legalBasis":[{"provision":"ACL section 28B, inserted by the 2026 Act","sourceIds":["au-act-2026-64"],"classification":"Possible risk indicator","explanation":"In pricing journeys, the misleading reference pricing mechanism may warrant review where it manipulates a consumer or unreasonably distorts the decision environment and causes, or is likely to cause, detriment. The interface interference label and an interface similarity do not establish a contravention; the complete section 28B test, scope, facts and evidence must be applied from 1 July 2027."},{"provision":"Dark-pattern research taxonomy","sourceIds":["oecd-dark-commercial-patterns-2022"],"classification":"Editorial analysis","explanation":"The cited research sources support this working pattern within the interface interference family. It is editorial implementation guidance, not an Australian statutory category, regulator finding or legal safe harbour."}],"examples":[{"type":"Illustrative example","context":"Permanent sale uses an invented “was” price","scenario":"A fictional store shows “Was $180, now $79” even though the jacket has never been offered for $180 and sells at $79 throughout the season.","harm":"The reference can create an unsupported impression of exceptional savings and rush comparison."},{"type":"Illustrative example","context":"Member discount compares with unavailable tier","scenario":"A fictional booking service calls $90 a “40% member saving” by comparing it with a $150 flexible fare that is not offered for the same dates or conditions.","harm":"Travellers may overvalue membership because the compared offers are not meaningfully equivalent."}],"problematicUi":{"label":"Weekend saving","copy":"Weekend saving An unsubstantiated former price makes the current price appear exceptional. Displayed amount $180 $79","annotations":["Why this state matters: The presentation changes what the user can notice or predict at the pricing decision. The problematic state shows: “An unsubstantiated former price makes the current price appear exceptional.” Its influence should be tested by comparing the consequence and usability of “Was $180 · now $79” with “$79”. The reference can create an unsupported impression of exceptional savings and rush comparison.","Review prompt: Do “Was $180 · now $79” and “$79” receive comparable prominence and explain their consequences before activation?"]},"improvedUi":{"label":"Current price","copy":"Current price The product is $79; any comparison states its verified basis and period. Displayed amount $79 Was $180 · now $79 Price, period and commitment The price and material terms associated with “$79” remain beside this choice.","annotations":["Fairer design: Use a substantiated comparison basis, identify the period or comparator and remove savings claims that cannot be evidenced.","Review prompt: Place the compared prices, billing periods and material terms on one evidence sheet; where does it support “A current price is framed against a reference or discount claim”?"]},"uiComparisons":[{"id":"misleading-reference-pricing-scenario-1","title":"Permanent sale uses an invented “was” price","context":"Fashion product page","journeyStage":"Pricing","summary":"A fictional store shows “Was $180, now $79” even though the jacket has never been offered for $180 and sells at $79 throughout the season.","problematic":{"label":"Weekend saving","layout":"pricing-card","elements":[{"id":"problematic-1-heading","type":"heading","text":"Weekend saving"},{"id":"problematic-2-body","type":"text","text":"An unsubstantiated former price makes the current price appear exceptional.","tone":"warning"},{"id":"problematic-3-price","type":"price","label":"Displayed amount","amount":"$180"},{"id":"problematic-4-link","type":"link","text":"$79","emphasis":"subtle"}],"annotations":[{"targetId":"problematic-2-body","text":"Why this state matters: The presentation changes what the user can notice or predict at the pricing decision. The problematic state shows: “An unsubstantiated former price makes the current price appear exceptional.” Its influence should be tested by comparing the consequence and usability of “Was $180 · now $79” with “$79”. The reference can create an unsupported impression of exceptional savings and rush comparison."},{"targetId":"problematic-4-link","text":"Review prompt: Do “Was $180 · now $79” and “$79” receive comparable prominence and explain their consequences before activation?"}]},"neutral":{"label":"Current price","layout":"pricing-card","elements":[{"id":"neutral-1-heading","type":"heading","text":"Current price"},{"id":"neutral-2-body","type":"text","text":"The product is $79; any comparison states its verified basis and period.","tone":"default"},{"id":"neutral-3-price","type":"price","label":"Displayed amount","amount":"$79"},{"id":"neutral-4-link","type":"link","text":"Was $180 · now $79","emphasis":"default"},{"id":"neutral-5-disclosure","type":"disclosure","summary":"Price, period and commitment","content":"The price and material terms associated with “$79” remain beside this choice.","open":true}],"annotations":[{"targetId":"neutral-2-body","text":"Fairer design: Use a substantiated comparison basis, identify the period or comparator and remove savings claims that cannot be evidenced."},{"targetId":"neutral-5-disclosure","text":"Review prompt: Place the compared prices, billing periods and material terms on one evidence sheet; where does it support “A current price is framed against a reference or discount claim”?"}]},"whyItMatters":"The presentation changes what the user can notice or predict at the pricing decision. The problematic state shows: “An unsubstantiated former price makes the current price appear exceptional.” Its influence should be tested by comparing the consequence and usability of “Was $180 · now $79” with “$79”. The reference can create an unsupported impression of exceptional savings and rush comparison.","fairDesignPrinciple":"Use a substantiated comparison basis, identify the period or comparator and remove savings claims that cannot be evidenced.","reviewPrompts":["Do “Was $180 · now $79” and “$79” receive comparable prominence and explain their consequences before activation?","Place the compared prices, billing periods and material terms on one evidence sheet; where does it support “A current price is framed against a reference or discount claim”?","What neutral rendering or comprehension result would falsify the classification, particularly in light of “Accurate, representative and clearly explained reference price”?"],"altText":"Side-by-side fashion product page interface showing “Weekend saving” and the clearer alternative “Current price”.","provenance":"Original hypothetical fashion product page example created for this library; no real business, product or interface is depicted."},{"id":"misleading-reference-pricing-scenario-2","title":"Member discount compares with unavailable tier","context":"Travel membership offer","journeyStage":"Pricing","summary":"A fictional booking service calls $90 a “40% member saving” by comparing it with a $150 flexible fare that is not offered for the same dates or conditions.","problematic":{"label":"Members save 40%","layout":"pricing-card","elements":[{"id":"problematic-1-heading","type":"heading","text":"Members save 40%"},{"id":"problematic-2-body","type":"text","text":"The comparator has different dates and conditions and is not purchasable in this search.","tone":"warning"},{"id":"problematic-3-price","type":"price","label":"Displayed amount","amount":"$90"},{"id":"problematic-4-link","type":"link","text":"Member $90 · public $105","emphasis":"subtle"}],"annotations":[{"targetId":"problematic-2-body","text":"Why this state matters: The presentation changes what the user can notice or predict at the pricing decision. The problematic state shows: “The comparator has different dates and conditions and is not purchasable in this search.” Its influence should be tested by comparing the consequence and usability of “$90 vs $150” with “Member $90 · public $105”. Travellers may overvalue membership because the compared offers are not meaningfully equivalent."},{"targetId":"problematic-4-link","text":"Review prompt: Do “$90 vs $150” and “Member $90 · public $105” receive comparable prominence and explain their consequences before activation?"}]},"neutral":{"label":"Like-for-like price comparison","layout":"pricing-card","elements":[{"id":"neutral-1-heading","type":"heading","text":"Like-for-like price comparison"},{"id":"neutral-2-body","type":"text","text":"The member and public fares share the same dates, room and cancellation terms.","tone":"default"},{"id":"neutral-3-price","type":"price","label":"Displayed amount","amount":"$90"},{"id":"neutral-4-link","type":"link","text":"$90 vs $150","emphasis":"default"},{"id":"neutral-5-disclosure","type":"disclosure","summary":"Price, period and commitment","content":"The price and material terms associated with “Member $90 · public $105” remain beside this choice.","open":true}],"annotations":[{"targetId":"neutral-2-body","text":"Fairer design: Compare like-for-like offers and state the fare conditions, date and audience behind any saving."},{"targetId":"neutral-5-disclosure","text":"Review prompt: Place the compared prices, billing periods and material terms on one evidence sheet; where does it support “Arithmetic, comparison basis or external history is inconsistent, inaccurate or unverified”?"}]},"whyItMatters":"The presentation changes what the user can notice or predict at the pricing decision. The problematic state shows: “The comparator has different dates and conditions and is not purchasable in this search.” Its influence should be tested by comparing the consequence and usability of “$90 vs $150” with “Member $90 · public $105”. Travellers may overvalue membership because the compared offers are not meaningfully equivalent.","fairDesignPrinciple":"Compare like-for-like offers and state the fare conditions, date and audience behind any saving.","reviewPrompts":["Do “$90 vs $150” and “Member $90 · public $105” receive comparable prominence and explain their consequences before activation?","Place the compared prices, billing periods and material terms on one evidence sheet; where does it support “Arithmetic, comparison basis or external history is inconsistent, inaccurate or unverified”?","What neutral rendering or comprehension result would falsify the classification, particularly in light of “mere display of two genuinely different product prices”?"],"altText":"Side-by-side travel membership offer interface showing “Members save 40%” and the clearer alternative “Like-for-like price comparison”.","provenance":"Original hypothetical travel membership offer example created for this library; no real business, product or interface is depicted."}],"fairAlternative":"Use a truthful, representative comparison basis and explain the reference period or basis close to the claim.","whyProblematic":"A comparison or prior price creates an inaccurate or insufficiently explained impression of savings. A current price is evaluated against an unsupported or non-equivalent comparator, manufacturing a saving that can distort value and timing judgments. These harms describe a review risk, not an automatic legal conclusion. Australian section 28B commences on 1 July 2027 and requires its complete, context-specific test. Existing ACL provisions remain a separate current-law assessment.","contextFactors":["A current price is framed against a reference or discount claim.","Arithmetic, comparison basis or external history is inconsistent, inaccurate or unverified.","The anchor plausibly affects perceived value.","Boundary to test: Accurate, representative and clearly explained reference price","Boundary to test: mere display of two genuinely different product prices"],"affectedTeams":["Product","Design","Engineering","Legal","Compliance"],"reviewQuestions":["Do “Was $180 · now $79” and “$79” receive comparable prominence and explain their consequences before activation?","Place the compared prices, billing periods and material terms on one evidence sheet; where does it support “A current price is framed against a reference or discount claim”?","What neutral rendering or comprehension result would falsify the classification, particularly in light of “Accurate, representative and clearly explained reference price”?","Do “$90 vs $150” and “Member $90 · public $105” receive comparable prominence and explain their consequences before activation?","Place the compared prices, billing periods and material terms on one evidence sheet; where does it support “Arithmetic, comparison basis or external history is inconsistent, inaccurate or unverified”?","What neutral rendering or comprehension result would falsify the classification, particularly in light of “mere display of two genuinely different product prices”?"],"evidence":["Annotated pricing screenshots at each responsive breakpoint","The complete state sequence before, during and after the consumer decision","Design-system component, content, default and configuration records for the reviewed release","Operational records substantiating price, availability, timing and eligibility claims","Usability, accessibility, reversal, complaint and support evidence relevant to consumer impact","A dated product and legal review record identifying evidence, uncertainties and release decisions"],"related":["bundled-options","choice-or-information-overload","complex-or-inaccessible-language","disguised-advertisement-or-action"],"sourceIds":["oecd-dark-commercial-patterns-2022","au-act-2026-64"],"altText":"Side-by-side fashion product page interface showing “Weekend saving” and the clearer alternative “Current price”.","provenance":"Original hypothetical interface comparisons from the shared learning library, adapted to Australian-dollar context for this portal; no real business, product or interface is depicted.","author":"Flowlane","datePublished":"2026-08-10","dateModified":"2026-09-14","lastReviewed":"2026-09-14","changeNote":"Source comparison recorded and the current status restated."},{"title":"Preselection and biased defaults","slug":"preselection-and-biased-defaults","preferredName":"Preselection and biased defaults","directAnswer":"The final Act does not prohibit every preselected option as a standalone category. A default can, however, contribute to manipulation or unreasonable distortion under section 28B where the complete test and likely detriment are present. Other rules can apply now, including price, misleading-conduct, consent or sector-specific requirements, depending on the option.","definition":"A business-favoured option with a plausible adverse consequence is active before a deliberate user choice. This is a design and research taxonomy for learning and evidence review, not a statutory offence label or an automatic finding that an interface is unlawful.","synonyms":["bad defaults","default add-on","deceptive snugness","prechecked marketing","preselected paid add-on","default privacy-invasive setting","preselected higher-cost plan","pre-ticked option","default bias","preselection","opt-out default","Preselection or bad default"],"category":"Interface interference","family":"Interface interference","journeyStages":["Checkout","Subscription"],"jurisdiction":"Australia","status":"Commences 1 July 2027","howItWorks":"A business-favoured option with a plausible adverse consequence is active before a deliberate user choice. The system chooses a consequential option before the user acts, allowing inattention or momentum to preserve a paid, data-sharing or longer-term state.","warningSigns":["The state is selected at first relevant presentation.","The default benefits the business or increases cost, data use, tracking or commitment.","The user must act to avoid the consequence."],"harms":["The shopper may pay for an add-on through inattention rather than active agreement.","A user may commit to a larger upfront payment without making an active billing-period choice."],"legitimateUses":["Consumer-protective or neutral default","state restored from a prior explicit user choice"],"legalBasis":[{"provision":"ACL section 28B(2), inserted by the 2026 Act","sourceIds":["au-act-2026-64"],"classification":"Possible risk indicator","explanation":"Supplies the complete contextual test from commencement."},{"provision":"ACL section 28B(6)(c) to (d), inserted by the 2026 Act","sourceIds":["au-act-2026-64"],"classification":"Possible risk indicator","explanation":"Ineffective material disclosure and pressure or obstruction through design may be relevant non-exhaustive examples."}],"examples":[{"type":"Illustrative example","context":"Paid protection preselected in basket","scenario":"A fictional retailer preselects a $12 protection plan and includes it in the total before the shopper has made a distinct choice.","harm":"The shopper may pay for an add-on through inattention rather than active agreement."},{"type":"Illustrative example","context":"Annual plan active by default","scenario":"A fictional streaming service opens with the annual plan selected and highlights a monthly-equivalent figure while the payable annual total is smaller.","harm":"A user may commit to a larger upfront payment without making an active billing-period choice."},{"type":"Illustrative example","context":"Preselected paid protection","scenario":"A retailer pre-ticks a $12 product-protection add-on and includes it in the checkout total without a distinct confirmation.","harm":"The default creates a direct financial consequence and may exploit inattention. Section 28B and current price or misleading-conduct rules require contextual analysis."},{"type":"Illustrative example","context":"Annual plan selected over monthly plan","scenario":"A service preselects a prepaid annual plan, displays its monthly equivalent most prominently and places the payable annual total in smaller text.","harm":"The combination of default and price hierarchy may cause a consumer to accept a larger commitment than understood."}],"problematicUi":{"label":"Order total · $211","copy":"Order total · $211 A $12 protection plan is already active in the basket. Protection included Add protection for $12","annotations":["Why this state matters: The presentation changes what the user can notice or predict at the checkout decision. The problematic state shows: “A $12 protection plan is already active in the basket.” Its influence should be tested by comparing the consequence and usability of “Protection included” with “Add protection for $12”. The shopper may pay for an add-on through inattention rather than active agreement.","Review prompt: Do “Protection included” and “Add protection for $12” receive comparable prominence and explain their consequences before activation?"]},"improvedUi":{"label":"Order total · $199","copy":"Order total · $199 Protection is optional, unselected and priced beside its control. Amount affected $12 Add protection for $12 Protection included Payable total and selected items The summary shows the line items and total before “Add protection for $12” is activated.","annotations":["Fairer design: Leave paid extras unselected, describe their price and require a deliberate choice before adding them.","Review prompt: Compare the basket before and after the action, including total and line items; does the mutation satisfy “The state is selected at first relevant presentation”?"]},"uiComparisons":[{"id":"preselection-or-bad-default-scenario-1","title":"Paid protection preselected in basket","context":"Electronics checkout","journeyStage":"Checkout","summary":"A fictional retailer preselects a $12 protection plan and includes it in the total before the shopper has made a distinct choice.","problematic":{"label":"Order total · $211","layout":"checkout-summary","elements":[{"id":"problematic-1-heading","type":"heading","text":"Order total · $211"},{"id":"problematic-2-body","type":"text","text":"A $12 protection plan is already active in the basket.","tone":"warning"},{"id":"problematic-3-badge","type":"badge","text":"Protection included","tone":"warning"},{"id":"problematic-4-link","type":"link","text":"Add protection for $12","emphasis":"subtle"}],"annotations":[{"targetId":"problematic-2-body","text":"Why this state matters: The presentation changes what the user can notice or predict at the checkout decision. The problematic state shows: “A $12 protection plan is already active in the basket.” Its influence should be tested by comparing the consequence and usability of “Protection included” with “Add protection for $12”. The shopper may pay for an add-on through inattention rather than active agreement."},{"targetId":"problematic-4-link","text":"Review prompt: Do “Protection included” and “Add protection for $12” receive comparable prominence and explain their consequences before activation?"}]},"neutral":{"label":"Order total · $199","layout":"checkout-summary","elements":[{"id":"neutral-1-heading","type":"heading","text":"Order total · $199"},{"id":"neutral-2-body","type":"text","text":"Protection is optional, unselected and priced beside its control.","tone":"default"},{"id":"neutral-3-price","type":"price","label":"Amount affected","amount":"$12"},{"id":"neutral-4-button","type":"button","text":"Add protection for $12","emphasis":"secondary"},{"id":"neutral-5-link","type":"link","text":"Protection included","emphasis":"default"},{"id":"neutral-6-disclosure","type":"disclosure","summary":"Payable total and selected items","content":"The summary shows the line items and total before “Add protection for $12” is activated.","open":true}],"annotations":[{"targetId":"neutral-2-body","text":"Fairer design: Leave paid extras unselected, describe their price and require a deliberate choice before adding them."},{"targetId":"neutral-6-disclosure","text":"Review prompt: Compare the basket before and after the action, including total and line items; does the mutation satisfy “The state is selected at first relevant presentation”?"}]},"whyItMatters":"The presentation changes what the user can notice or predict at the checkout decision. The problematic state shows: “A $12 protection plan is already active in the basket.” Its influence should be tested by comparing the consequence and usability of “Protection included” with “Add protection for $12”. The shopper may pay for an add-on through inattention rather than active agreement.","fairDesignPrinciple":"Leave paid extras unselected, describe their price and require a deliberate choice before adding them.","reviewPrompts":["Do “Protection included” and “Add protection for $12” receive comparable prominence and explain their consequences before activation?","Compare the basket before and after the action, including total and line items; does the mutation satisfy “The state is selected at first relevant presentation”?","What neutral rendering or comprehension result would falsify the classification, particularly in light of “Consumer-protective or neutral default”?"],"altText":"Side-by-side electronics checkout interface showing “Order total · $211” and the clearer alternative “Order total · $199”.","provenance":"Original hypothetical electronics checkout example created for this library; no real business, product or interface is depicted."},{"id":"preselection-or-bad-default-scenario-2","title":"Annual plan active by default","context":"Streaming plan selection","journeyStage":"Subscription","summary":"A fictional streaming service opens with the annual plan selected and highlights a monthly-equivalent figure while the payable annual total is smaller.","problematic":{"label":"Choose your plan","layout":"choice-list","elements":[{"id":"problematic-1-heading","type":"heading","text":"Choose your plan"},{"id":"problematic-2-body","type":"text","text":"Annual billing is active before the user chooses and its total is visually secondary.","tone":"warning"},{"id":"problematic-3-radio","type":"radio","label":"Annual selected","checked":true},{"id":"problematic-4-radio","type":"radio","label":"Select monthly or annual","checked":false}],"annotations":[{"targetId":"problematic-2-body","text":"Why this state matters: The presentation changes what the user can notice or predict at the subscription decision. The problematic state shows: “Annual billing is active before the user chooses and its total is visually secondary.” Its influence should be tested by comparing the consequence and usability of “Annual selected” with “Select monthly or annual”. A user may commit to a larger upfront payment without making an active billing-period choice."},{"targetId":"problematic-4-radio","text":"Review prompt: Do “Annual selected” and “Select monthly or annual” receive comparable prominence and explain their consequences before activation?"}]},"neutral":{"label":"Choose a billing period","layout":"choice-list","elements":[{"id":"neutral-1-heading","type":"heading","text":"Choose a billing period"},{"id":"neutral-2-body","type":"text","text":"No option is preselected; monthly and annual totals appear beside each radio control.","tone":"default"},{"id":"neutral-3-radio","type":"radio","label":"Select monthly or annual","checked":false},{"id":"neutral-4-radio","type":"radio","label":"Annual selected","checked":false},{"id":"neutral-5-disclosure","type":"disclosure","summary":"Choice consequences","content":"The consequence of selecting “Select monthly or annual” is displayed beside the option.","open":true}],"annotations":[{"targetId":"neutral-2-body","text":"Fairer design: Start with no paid plan selected and show both payable totals and billing periods consistently."},{"targetId":"neutral-5-disclosure","text":"Review prompt: Capture every peer option, its default state and visual prominence; do those states support “The default benefits the business or increases cost, data use, tracking or commitment”?"}]},"whyItMatters":"The presentation changes what the user can notice or predict at the subscription decision. The problematic state shows: “Annual billing is active before the user chooses and its total is visually secondary.” Its influence should be tested by comparing the consequence and usability of “Annual selected” with “Select monthly or annual”. A user may commit to a larger upfront payment without making an active billing-period choice.","fairDesignPrinciple":"Start with no paid plan selected and show both payable totals and billing periods consistently.","reviewPrompts":["Do “Annual selected” and “Select monthly or annual” receive comparable prominence and explain their consequences before activation?","Capture every peer option, its default state and visual prominence; do those states support “The default benefits the business or increases cost, data use, tracking or commitment”?","What neutral rendering or comprehension result would falsify the classification, particularly in light of “state restored from a prior explicit user choice”?"],"altText":"Side-by-side streaming plan selection interface showing “Choose your plan” and the clearer alternative “Choose a billing period”.","provenance":"Original hypothetical streaming plan selection example created for this library; no real business, product or interface is depicted."}],"fairAlternative":"Use a neutral or consumer-protective default and require affirmative selection for added cost, data use, tracking or commitment.","whyProblematic":"A business-favoured option with a plausible adverse consequence is active before a deliberate user choice. The system chooses a consequential option before the user acts, allowing inattention or momentum to preserve a paid, data-sharing or longer-term state. Preselection is a UX taxonomy term, not a named section 28B example. Analyse whether the default, surrounding disclosure, visual hierarchy and reversal path manipulate the consumer or unreasonably distort the decision environment, and whether financial or other detriment is caused or likely. Existing ACL pricing and misleading-conduct provisions may apply now where a default adds cost or creates a false overall impression. No final Australian regulator safe harbour for default design had been identified by the review date.","contextFactors":["The state is selected at first relevant presentation.","The default benefits the business or increases cost, data use, tracking or commitment.","The user must act to avoid the consequence.","Boundary to test: Consumer-protective or neutral default","Boundary to test: state restored from a prior explicit user choice","Does the default add price, commitment, data use or another material consequence?","Is the default clearly visible and explained before commitment?","Would the consumer reasonably expect no selection until they act?","How easy is it to change or reverse the selection?","Is the default justified by consumer benefit or primarily trader conversion?","Does the design exploit inattention or accessibility constraints?"],"affectedTeams":["Product","Design","Engineering","Ecommerce","Legal","Privacy"],"reviewQuestions":["Do “Protection included” and “Add protection for $12” receive comparable prominence and explain their consequences before activation?","Compare the basket before and after the action, including total and line items; does the mutation satisfy “The state is selected at first relevant presentation”?","What neutral rendering or comprehension result would falsify the classification, particularly in light of “Consumer-protective or neutral default”?","Do “Annual selected” and “Select monthly or annual” receive comparable prominence and explain their consequences before activation?","Capture every peer option, its default state and visual prominence; do those states support “The default benefits the business or increases cost, data use, tracking or commitment”?","What neutral rendering or comprehension result would falsify the classification, particularly in light of “state restored from a prior explicit user choice”?","What changes if the consumer takes no action?","Does a default add cost or commitment?","Can the consumer identify the selected state and reverse it before purchase?","Are actual billing amount and period at least as clear as an equivalent-rate claim?","What evidence shows the default benefits rather than surprises users?"],"evidence":["default-state inventory","decision record for each material default","screenshots before and after selection","price and billing copy approvals","removal, refund and complaint data","accessibility interaction tests","Annotated checkout and subscription screenshots at each responsive breakpoint","The complete state sequence before, during and after the consumer decision","Design-system component, content, default and configuration records for the reviewed release","Operational records substantiating price, availability, timing and eligibility claims","Usability, accessibility, reversal, complaint and support evidence relevant to consumer impact","A dated product and legal review record identifying evidence, uncertainties and release decisions"],"related":["bundled-options","choice-or-information-overload","complex-or-inaccessible-language","disguised-advertisement-or-action"],"sourceIds":["oecd-dark-commercial-patterns-2022","au-act-2026-64","au-acl-2010","au-accc-priorities-2026"],"altText":"Side-by-side electronics checkout interface showing “Order total · $211” and the clearer alternative “Order total · $199”.","provenance":"Original hypothetical interface comparisons from the shared learning library, adapted to Australian-dollar context for this portal; no real business, product or interface is depicted.","author":"Flowlane","datePublished":"2026-08-09","dateModified":"2026-09-14","lastReviewed":"2026-09-14","changeNote":"Source comparison recorded and the current status restated."},{"title":"Pressured upselling","slug":"pressured-upselling","preferredName":"Pressured upselling","directAnswer":"Pressured upselling is a working label for this design mechanism: A more expensive or profitable option is made the practical focal choice through preselection, visual prominence or obscured lower-cost alternatives. This is editorial implementation guidance for Australian journeys, not a finding of unlawfulness. From 1 July 2027, a similar interface is relevant to ACL section 28B only if the complete consumer-connection, manipulation or unreasonable-distortion and actual-or-likely-detriment test is met. Current ACL rules require a separate assessment.","definition":"A more expensive or profitable option is made the practical focal choice through preselection, visual prominence or obscured lower-cost alternatives. This is a design and research taxonomy for learning and evidence review, not a statutory offence label or an automatic finding that an interface is unlawful.","synonyms":["pressured selling","preselected expensive option","decoy upsell","higher-price plan visually privileged","cheaper option obscured","upgrade preselected","repeated upgrade gate"],"category":"Interface interference","family":"Interface interference","journeyStages":["Subscription","Checkout"],"jurisdiction":"Australia","status":"Editorial implementation guidance","howItWorks":"A more expensive or profitable option is made the practical focal choice through preselection, visual prominence or obscured lower-cost alternatives. Repeated prompts, unsupported risk framing or decoy value claims make keeping the existing or basic option feel unsafe, wasteful or incomplete.","warningSigns":["A lower-cost or less committed alternative exists.","The higher-value option is preselected, materially more prominent or easier.","The difference is not justified solely by the user's stated goal."],"harms":["Unsupported fear framing may push a subscriber toward a costlier plan they do not need.","Repeated loss framing may pressure a traveller to add services they did not seek."],"legitimateUses":["Transparent recommendation based on declared needs with equal access to alternatives","ordinary plan hierarchy with comparable presentation"],"legalBasis":[{"provision":"ACL section 28B, inserted by the 2026 Act","sourceIds":["au-act-2026-64"],"classification":"Possible risk indicator","explanation":"In subscription and checkout journeys, the pressured upselling mechanism may warrant review where it manipulates a consumer or unreasonably distorts the decision environment and causes, or is likely to cause, detriment. The interface interference label and an interface similarity do not establish a contravention; the complete section 28B test, scope, facts and evidence must be applied from 1 July 2027."},{"provision":"Dark-pattern research taxonomy","sourceIds":["gray-ontology-dark-patterns-2024","mathur-dark-patterns-at-scale-2019"],"classification":"Editorial analysis","explanation":"The cited research sources support this working pattern within the interface interference family. It is editorial implementation guidance, not an Australian statutory category, regulator finding or legal safe harbour."}],"examples":[{"type":"Illustrative example","context":"Current plan framed as unsafe","scenario":"A fictional renewal screen repeatedly warns that keeping the current tier will leave files “unsafe”, although the security controls are identical across tiers.","harm":"Unsupported fear framing may push a subscriber toward a costlier plan they do not need."},{"type":"Illustrative example","context":"Repeated upgrade framing around room-only booking","scenario":"A fictional booking flow places three sequential upgrade panels before room-only continuation and describes the basic booking as “missing the complete trip”.","harm":"Repeated loss framing may pressure a traveller to add services they did not seek."}],"problematicUi":{"label":"Protect every file now","copy":"Protect every file now Repeated warnings imply a security loss that the plan comparison does not support. Displayed amount $29 Upgrade for $29/month Keep current $12 plan","annotations":["Why this state matters: The presentation changes what the user can notice or predict at the subscription decision. The problematic state shows: “Repeated warnings imply a security loss that the plan comparison does not support.” Its influence should be tested by comparing the consequence and usability of “Upgrade for $29/month” with “Keep current $12 plan”. Unsupported fear framing may push a subscriber toward a costlier plan they do not need.","Review prompt: Do “Upgrade for $29/month” and “Keep current $12 plan” receive comparable prominence and explain their consequences before activation?"]},"improvedUi":{"label":"Compare storage plans","copy":"Compare storage plans Security is described accurately and the current plan remains an equal option. Displayed amount $12 Keep current $12 plan Upgrade for $29/month Price, period and commitment The price and material terms associated with “Keep current $12 plan” remain beside this choice.","annotations":["Fairer design: Compare factual capacity and feature differences, keep the current plan equally usable and let the subscriber deliberately choose any upgrade.","Review prompt: Place the compared prices, billing periods and material terms on one evidence sheet; where does it support “A lower-cost or less committed alternative exists”?"]},"uiComparisons":[{"id":"pressured-upselling-scenario-1","title":"Current plan framed as unsafe","context":"Cloud storage renewal","journeyStage":"Subscription","summary":"A fictional renewal screen repeatedly warns that keeping the current tier will leave files “unsafe”, although the security controls are identical across tiers.","problematic":{"label":"Protect every file now","layout":"pricing-card","elements":[{"id":"problematic-1-heading","type":"heading","text":"Protect every file now"},{"id":"problematic-2-body","type":"text","text":"Repeated warnings imply a security loss that the plan comparison does not support.","tone":"warning"},{"id":"problematic-3-price","type":"price","label":"Displayed amount","amount":"$29"},{"id":"problematic-4-button","type":"button","text":"Upgrade for $29/month","emphasis":"primary"},{"id":"problematic-5-link","type":"link","text":"Keep current $12 plan","emphasis":"subtle"}],"annotations":[{"targetId":"problematic-2-body","text":"Why this state matters: The presentation changes what the user can notice or predict at the subscription decision. The problematic state shows: “Repeated warnings imply a security loss that the plan comparison does not support.” Its influence should be tested by comparing the consequence and usability of “Upgrade for $29/month” with “Keep current $12 plan”. Unsupported fear framing may push a subscriber toward a costlier plan they do not need."},{"targetId":"problematic-5-link","text":"Review prompt: Do “Upgrade for $29/month” and “Keep current $12 plan” receive comparable prominence and explain their consequences before activation?"}]},"neutral":{"label":"Compare storage plans","layout":"pricing-card","elements":[{"id":"neutral-1-heading","type":"heading","text":"Compare storage plans"},{"id":"neutral-2-body","type":"text","text":"Security is described accurately and the current plan remains an equal option.","tone":"default"},{"id":"neutral-3-price","type":"price","label":"Displayed amount","amount":"$12"},{"id":"neutral-4-button","type":"button","text":"Keep current $12 plan","emphasis":"secondary"},{"id":"neutral-5-link","type":"link","text":"Upgrade for $29/month","emphasis":"default"},{"id":"neutral-6-disclosure","type":"disclosure","summary":"Price, period and commitment","content":"The price and material terms associated with “Keep current $12 plan” remain beside this choice.","open":true}],"annotations":[{"targetId":"neutral-2-body","text":"Fairer design: Compare factual capacity and feature differences, keep the current plan equally usable and let the subscriber deliberately choose any upgrade."},{"targetId":"neutral-6-disclosure","text":"Review prompt: Place the compared prices, billing periods and material terms on one evidence sheet; where does it support “A lower-cost or less committed alternative exists”?"}]},"whyItMatters":"The presentation changes what the user can notice or predict at the subscription decision. The problematic state shows: “Repeated warnings imply a security loss that the plan comparison does not support.” Its influence should be tested by comparing the consequence and usability of “Upgrade for $29/month” with “Keep current $12 plan”. Unsupported fear framing may push a subscriber toward a costlier plan they do not need.","fairDesignPrinciple":"Compare factual capacity and feature differences, keep the current plan equally usable and let the subscriber deliberately choose any upgrade.","reviewPrompts":["Do “Upgrade for $29/month” and “Keep current $12 plan” receive comparable prominence and explain their consequences before activation?","Place the compared prices, billing periods and material terms on one evidence sheet; where does it support “A lower-cost or less committed alternative exists”?","What neutral rendering or comprehension result would falsify the classification, particularly in light of “Transparent recommendation based on declared needs with equal access to alternatives”?"],"altText":"Side-by-side cloud storage renewal interface showing “Protect every file now” and the clearer alternative “Compare storage plans”.","provenance":"Original hypothetical cloud storage renewal example created for this library; no real business, product or interface is depicted."},{"id":"pressured-upselling-scenario-2","title":"Repeated upgrade framing around room-only booking","context":"Accommodation checkout","journeyStage":"Checkout","summary":"A fictional booking flow places three sequential upgrade panels before room-only continuation and describes the basic booking as “missing the complete trip”.","problematic":{"label":"Complete your trip","layout":"checkout-summary","elements":[{"id":"problematic-1-heading","type":"heading","text":"Complete your trip"},{"id":"problematic-2-body","type":"text","text":"Three separate panels frame room-only booking as an incomplete choice.","tone":"warning"},{"id":"problematic-3-price","type":"price","label":"Amount affected","amount":"$95"},{"id":"problematic-4-button","type":"button","text":"Add extras package $95","emphasis":"primary"},{"id":"problematic-5-link","type":"link","text":"Continue room-only","emphasis":"subtle"}],"annotations":[{"targetId":"problematic-2-body","text":"Why this state matters: The presentation changes what the user can notice or predict at the checkout decision. The problematic state shows: “Three separate panels frame room-only booking as an incomplete choice.” Its influence should be tested by comparing the consequence and usability of “Add extras package $95” with “Continue room-only”. Repeated loss framing may pressure a traveller to add services they did not seek."},{"targetId":"problematic-5-link","text":"Review prompt: Do “Add extras package $95” and “Continue room-only” receive comparable prominence and explain their consequences before activation?"}]},"neutral":{"label":"Choose optional extras once","layout":"checkout-summary","elements":[{"id":"neutral-1-heading","type":"heading","text":"Choose optional extras once"},{"id":"neutral-2-body","type":"text","text":"Room-only remains visible and each add-on can be reviewed without loss framing.","tone":"default"},{"id":"neutral-3-button","type":"button","text":"Continue room-only","emphasis":"secondary"},{"id":"neutral-4-link","type":"link","text":"Add extras package $95","emphasis":"default"},{"id":"neutral-5-disclosure","type":"disclosure","summary":"Payable total and selected items","content":"The summary shows the line items and total before “Continue room-only” is activated.","open":true}],"annotations":[{"targetId":"neutral-2-body","text":"Fairer design: Present room-only continuation beside optional extras, describe each product factually and avoid repeating a declined offer."},{"targetId":"neutral-5-disclosure","text":"Review prompt: Compare the basket before and after the action, including total and line items; does the mutation satisfy “The higher-value option is preselected, materially more prominent or easier”?"}]},"whyItMatters":"The presentation changes what the user can notice or predict at the checkout decision. The problematic state shows: “Three separate panels frame room-only booking as an incomplete choice.” Its influence should be tested by comparing the consequence and usability of “Add extras package $95” with “Continue room-only”. Repeated loss framing may pressure a traveller to add services they did not seek.","fairDesignPrinciple":"Present room-only continuation beside optional extras, describe each product factually and avoid repeating a declined offer.","reviewPrompts":["Do “Add extras package $95” and “Continue room-only” receive comparable prominence and explain their consequences before activation?","Compare the basket before and after the action, including total and line items; does the mutation satisfy “The higher-value option is preselected, materially more prominent or easier”?","What neutral rendering or comprehension result would falsify the classification, particularly in light of “ordinary plan hierarchy with comparable presentation”?"],"altText":"Side-by-side accommodation checkout interface showing “Complete your trip” and the clearer alternative “Choose optional extras once”.","provenance":"Original hypothetical accommodation checkout example created for this library; no real business, product or interface is depicted."}],"fairAlternative":"Present price and commitment alternatives comparably and avoid preselecting or obscuring the more expensive outcome.","whyProblematic":"A more expensive or profitable option is made the practical focal choice through preselection, visual prominence or obscured lower-cost alternatives. Repeated prompts, unsupported risk framing or decoy value claims make keeping the existing or basic option feel unsafe, wasteful or incomplete. These harms describe a review risk, not an automatic legal conclusion. Australian section 28B commences on 1 July 2027 and requires its complete, context-specific test. Existing ACL provisions remain a separate current-law assessment.","contextFactors":["A lower-cost or less committed alternative exists.","The higher-value option is preselected, materially more prominent or easier.","The difference is not justified solely by the user's stated goal.","Boundary to test: Transparent recommendation based on declared needs with equal access to alternatives","Boundary to test: ordinary plan hierarchy with comparable presentation"],"affectedTeams":["Product","Design","Engineering","Legal","Compliance"],"reviewQuestions":["Do “Upgrade for $29/month” and “Keep current $12 plan” receive comparable prominence and explain their consequences before activation?","Place the compared prices, billing periods and material terms on one evidence sheet; where does it support “A lower-cost or less committed alternative exists”?","What neutral rendering or comprehension result would falsify the classification, particularly in light of “Transparent recommendation based on declared needs with equal access to alternatives”?","Do “Add extras package $95” and “Continue room-only” receive comparable prominence and explain their consequences before activation?","Compare the basket before and after the action, including total and line items; does the mutation satisfy “The higher-value option is preselected, materially more prominent or easier”?","What neutral rendering or comprehension result would falsify the classification, particularly in light of “ordinary plan hierarchy with comparable presentation”?"],"evidence":["Annotated subscription and checkout screenshots at each responsive breakpoint","The complete state sequence before, during and after the consumer decision","Design-system component, content, default and configuration records for the reviewed release","Operational records substantiating price, availability, timing and eligibility claims","Usability, accessibility, reversal, complaint and support evidence relevant to consumer impact","A dated product and legal review record identifying evidence, uncertainties and release decisions"],"related":["bundled-options","choice-or-information-overload","complex-or-inaccessible-language","disguised-advertisement-or-action"],"sourceIds":["gray-ontology-dark-patterns-2024","mathur-dark-patterns-at-scale-2019","au-act-2026-64"],"altText":"Side-by-side cloud storage renewal interface showing “Protect every file now” and the clearer alternative “Compare storage plans”.","provenance":"Original hypothetical interface comparisons from the shared learning library, adapted to Australian-dollar context for this portal; no real business, product or interface is depicted.","author":"Flowlane","datePublished":"2026-08-10","dateModified":"2026-09-14","lastReviewed":"2026-09-14","changeNote":"Source comparison recorded and the current status restated."},{"title":"Trick question","slug":"trick-question","preferredName":"Trick question","directAnswer":"Trick question is a working label for this design mechanism: A question or control uses confusing, reversed or leading semantics so the user's likely interpretation may not match the resulting choice. This is editorial implementation guidance for Australian journeys, not a finding of unlawfulness. From 1 July 2027, a similar interface is relevant to ACL section 28B only if the complete consumer-connection, manipulation or unreasonable-distortion and actual-or-likely-detriment test is met. Current ACL rules require a separate assessment.","definition":"A question or control uses confusing, reversed or leading semantics so the user's likely interpretation may not match the resulting choice. This is a design and research taxonomy for learning and evidence review, not a statutory offence label or an automatic finding that an interface is unlawful.","synonyms":["trick wording","double negative","reversed checkbox meaning","inconsistent yes/no semantics","leading question"],"category":"Interface interference","family":"Interface interference","journeyStages":["Signup","Cancellation"],"jurisdiction":"Australia","status":"Editorial implementation guidance","howItWorks":"A question or control uses confusing, reversed or leading semantics so the user's likely interpretation may not match the resulting choice. Negation, reversal or answer-label ambiguity breaks the link between the user’s response and the state that response will create.","warningSigns":["A response control has a predictable semantic interpretation.","Negation, label structure or inconsistent conventions make that interpretation materially ambiguous.","The ambiguity favours a business outcome or creates plausible detriment."],"harms":["A user may subscribe to promotions while believing they refused them.","The subscriber may preserve the plan accidentally because neither answer has a predictable consequence."],"legitimateUses":["Unavoidable technical distinction clearly explained","minor stylistic awkwardness with unambiguous outcome"],"legalBasis":[{"provision":"ACL section 28B, inserted by the 2026 Act","sourceIds":["au-act-2026-64"],"classification":"Possible risk indicator","explanation":"In signup and cancellation journeys, the trick question mechanism may warrant review where it manipulates a consumer or unreasonably distorts the decision environment and causes, or is likely to cause, detriment. The interface interference label and an interface similarity do not establish a contravention; the complete section 28B test, scope, facts and evidence must be applied from 1 July 2027."},{"provision":"Dark-pattern research taxonomy","sourceIds":["oecd-dark-commercial-patterns-2022"],"classification":"Editorial analysis","explanation":"The cited research sources support this working pattern within the interface interference family. It is editorial implementation guidance, not an Australian statutory category, regulator finding or legal safe harbour."}],"examples":[{"type":"Illustrative example","context":"Double negative controls marketing","scenario":"A fictional signup asks users to tick “Do not untick if you do not want to miss offers”, making the resulting marketing choice hard to predict.","harm":"A user may subscribe to promotions while believing they refused them."},{"type":"Illustrative example","context":"Reversed wording in cancellation survey","scenario":"A fictional cancellation dialog asks “Are you sure you don’t want us not to keep your plan active?” before displaying yes and no buttons.","harm":"The subscriber may preserve the plan accidentally because neither answer has a predictable consequence."}],"problematicUi":{"label":"Communication preferences","copy":"Communication preferences The checkbox uses two negatives and an unclear default. Do not untick to opt out Continue with selected choices","annotations":["Why this state matters: The presentation changes what the user can notice or predict at the signup decision. The problematic state shows: “The checkbox uses two negatives and an unclear default.” Its influence should be tested by comparing the consequence and usability of “Do not untick to opt out” with “Send me optional email offers”. A user may subscribe to promotions while believing they refused them.","Review prompt: Do “Do not untick to opt out” and “Send me optional email offers” receive comparable prominence and explain their consequences before activation?"]},"improvedUi":{"label":"Email offers","copy":"Email offers The optional choice states exactly what checking it does. Send me optional email offers Save these choices Purpose and refusal effect The form explains why “Send me optional email offers” is requested and what happens if it is not used.","annotations":["Fairer design: Use one positive proposition, an unticked control and a direct explanation of the resulting state.","Review prompt: Which fields or permissions are required, what happens on refusal, and does the resulting state support this criterion: “A response control has a predictable semantic interpretation”?"]},"uiComparisons":[{"id":"trick-question-scenario-1","title":"Double negative controls marketing","context":"Account signup","journeyStage":"Signup","summary":"A fictional signup asks users to tick “Do not untick if you do not want to miss offers”, making the resulting marketing choice hard to predict.","problematic":{"label":"Communication preferences","layout":"form","elements":[{"id":"problematic-1-heading","type":"heading","text":"Communication preferences"},{"id":"problematic-2-body","type":"text","text":"The checkbox uses two negatives and an unclear default.","tone":"warning"},{"id":"problematic-3-checkbox","type":"checkbox","label":"Do not untick to opt out","checked":true},{"id":"problematic-4-button","type":"button","text":"Continue with selected choices","emphasis":"primary"}],"annotations":[{"targetId":"problematic-2-body","text":"Why this state matters: The presentation changes what the user can notice or predict at the signup decision. The problematic state shows: “The checkbox uses two negatives and an unclear default.” Its influence should be tested by comparing the consequence and usability of “Do not untick to opt out” with “Send me optional email offers”. A user may subscribe to promotions while believing they refused them."},{"targetId":"problematic-4-button","text":"Review prompt: Do “Do not untick to opt out” and “Send me optional email offers” receive comparable prominence and explain their consequences before activation?"}]},"neutral":{"label":"Email offers","layout":"form","elements":[{"id":"neutral-1-heading","type":"heading","text":"Email offers"},{"id":"neutral-2-body","type":"text","text":"The optional choice states exactly what checking it does.","tone":"default"},{"id":"neutral-3-checkbox","type":"checkbox","label":"Send me optional email offers","checked":false},{"id":"neutral-4-button","type":"button","text":"Save these choices","emphasis":"secondary"},{"id":"neutral-5-disclosure","type":"disclosure","summary":"Purpose and refusal effect","content":"The form explains why “Send me optional email offers” is requested and what happens if it is not used.","open":true}],"annotations":[{"targetId":"neutral-2-body","text":"Fairer design: Use one positive proposition, an unticked control and a direct explanation of the resulting state."},{"targetId":"neutral-5-disclosure","text":"Review prompt: Which fields or permissions are required, what happens on refusal, and does the resulting state support this criterion: “A response control has a predictable semantic interpretation”?"}]},"whyItMatters":"The presentation changes what the user can notice or predict at the signup decision. The problematic state shows: “The checkbox uses two negatives and an unclear default.” Its influence should be tested by comparing the consequence and usability of “Do not untick to opt out” with “Send me optional email offers”. A user may subscribe to promotions while believing they refused them.","fairDesignPrinciple":"Use one positive proposition, an unticked control and a direct explanation of the resulting state.","reviewPrompts":["Do “Do not untick to opt out” and “Send me optional email offers” receive comparable prominence and explain their consequences before activation?","Which fields or permissions are required, what happens on refusal, and does the resulting state support this criterion: “A response control has a predictable semantic interpretation”?","What neutral rendering or comprehension result would falsify the classification, particularly in light of “Unavoidable technical distinction clearly explained”?"],"altText":"Side-by-side account signup interface showing “Communication preferences” and the clearer alternative “Email offers”.","provenance":"Original hypothetical account signup example created for this library; no real business, product or interface is depicted."},{"id":"trick-question-scenario-2","title":"Reversed wording in cancellation survey","context":"Membership cancellation","journeyStage":"Cancellation","summary":"A fictional cancellation dialog asks “Are you sure you don’t want us not to keep your plan active?” before displaying yes and no buttons.","problematic":{"label":"One last question","layout":"dialog","elements":[{"id":"problematic-1-heading","type":"heading","text":"One last question"},{"id":"problematic-2-body","type":"text","text":"A double negative separates the button labels from their actual outcomes.","tone":"warning"},{"id":"problematic-3-button","type":"button","text":"Yes / No","emphasis":"primary"},{"id":"problematic-4-link","type":"link","text":"End plan on 30 September","emphasis":"subtle"}],"annotations":[{"targetId":"problematic-2-body","text":"Why this state matters: The presentation changes what the user can notice or predict at the cancellation decision. The problematic state shows: “A double negative separates the button labels from their actual outcomes.” Its influence should be tested by comparing the consequence and usability of “Yes / No” with “End plan on 30 September”. The subscriber may preserve the plan accidentally because neither answer has a predictable consequence."},{"targetId":"problematic-4-link","text":"Review prompt: Do “Yes / No” and “End plan on 30 September” receive comparable prominence and explain their consequences before activation?"}]},"neutral":{"label":"Choose the account outcome","layout":"dialog","elements":[{"id":"neutral-1-heading","type":"heading","text":"Choose the account outcome"},{"id":"neutral-2-body","type":"text","text":"Each action names the result and effective date.","tone":"default"},{"id":"neutral-3-button","type":"button","text":"End plan on 30 September","emphasis":"secondary"},{"id":"neutral-4-link","type":"link","text":"Yes / No","emphasis":"default"},{"id":"neutral-5-disclosure","type":"disclosure","summary":"What happens next","content":"Activating “End plan on 30 September” produces the outcome stated on the control.","open":true}],"annotations":[{"targetId":"neutral-2-body","text":"Fairer design: Replace yes/no answers with explicit actions that state whether the plan ends or continues."},{"targetId":"neutral-5-disclosure","text":"Review prompt: Can the dialog be dismissed, what action does each control trigger, and what later state confirms or contradicts “Negation, label structure or inconsistent conventions make that interpretation materially ambiguous”?"}]},"whyItMatters":"The presentation changes what the user can notice or predict at the cancellation decision. The problematic state shows: “A double negative separates the button labels from their actual outcomes.” Its influence should be tested by comparing the consequence and usability of “Yes / No” with “End plan on 30 September”. The subscriber may preserve the plan accidentally because neither answer has a predictable consequence.","fairDesignPrinciple":"Replace yes/no answers with explicit actions that state whether the plan ends or continues.","reviewPrompts":["Do “Yes / No” and “End plan on 30 September” receive comparable prominence and explain their consequences before activation?","Can the dialog be dismissed, what action does each control trigger, and what later state confirms or contradicts “Negation, label structure or inconsistent conventions make that interpretation materially ambiguous”?","What neutral rendering or comprehension result would falsify the classification, particularly in light of “minor stylistic awkwardness with unambiguous outcome”?"],"altText":"Side-by-side membership cancellation interface showing “One last question” and the clearer alternative “Choose the account outcome”.","provenance":"Original hypothetical membership cancellation example created for this library; no real business, product or interface is depicted."}],"fairAlternative":"Use explicit action labels that name the resulting state, remove double negatives and verify that each response produces the consequence a user can reasonably predict.","whyProblematic":"A question or control uses confusing, reversed or leading semantics so the user's likely interpretation may not match the resulting choice. Negation, reversal or answer-label ambiguity breaks the link between the user’s response and the state that response will create. These harms describe a review risk, not an automatic legal conclusion. Australian section 28B commences on 1 July 2027 and requires its complete, context-specific test. Existing ACL provisions remain a separate current-law assessment.","contextFactors":["A response control has a predictable semantic interpretation.","Negation, label structure or inconsistent conventions make that interpretation materially ambiguous.","The ambiguity favours a business outcome or creates plausible detriment.","Boundary to test: Unavoidable technical distinction clearly explained","Boundary to test: minor stylistic awkwardness with unambiguous outcome"],"affectedTeams":["Product","Design","Engineering","Legal","Compliance"],"reviewQuestions":["Do “Do not untick to opt out” and “Send me optional email offers” receive comparable prominence and explain their consequences before activation?","Which fields or permissions are required, what happens on refusal, and does the resulting state support this criterion: “A response control has a predictable semantic interpretation”?","What neutral rendering or comprehension result would falsify the classification, particularly in light of “Unavoidable technical distinction clearly explained”?","Do “Yes / No” and “End plan on 30 September” receive comparable prominence and explain their consequences before activation?","Can the dialog be dismissed, what action does each control trigger, and what later state confirms or contradicts “Negation, label structure or inconsistent conventions make that interpretation materially ambiguous”?","What neutral rendering or comprehension result would falsify the classification, particularly in light of “minor stylistic awkwardness with unambiguous outcome”?"],"evidence":["Annotated signup and cancellation screenshots at each responsive breakpoint","The complete state sequence before, during and after the consumer decision","Design-system component, content, default and configuration records for the reviewed release","Operational records substantiating price, availability, timing and eligibility claims","Usability, accessibility, reversal, complaint and support evidence relevant to consumer impact","A dated product and legal review record identifying evidence, uncertainties and release decisions"],"related":["bundled-options","choice-or-information-overload","complex-or-inaccessible-language","disguised-advertisement-or-action"],"sourceIds":["oecd-dark-commercial-patterns-2022","au-act-2026-64"],"altText":"Side-by-side account signup interface showing “Communication preferences” and the clearer alternative “Email offers”.","provenance":"Original hypothetical interface comparisons from the shared learning library, adapted to Australian-dollar context for this portal; no real business, product or interface is depicted.","author":"Flowlane","datePublished":"2026-08-10","dateModified":"2026-09-14","lastReviewed":"2026-09-14","changeNote":"Source comparison recorded and the current status restated."},{"title":"Repeated prompting","slug":"repeated-prompting","preferredName":"Repeated prompting","directAnswer":"Repeated prompting is a working label for this design mechanism: A business-favoured request repeatedly interrupts the user after decline, dismissal or non-response without a durable way to stop it. This is editorial implementation guidance for Australian journeys, not a finding of unlawfulness. From 1 July 2027, a similar interface is relevant to ACL section 28B only if the complete consumer-connection, manipulation or unreasonable-distortion and actual-or-likely-detriment test is met. Current ACL rules require a separate assessment.","definition":"A business-favoured request repeatedly interrupts the user after decline, dismissal or non-response without a durable way to stop it. This is a design and research taxonomy for learning and evidence review, not a statutory offence label or an automatic finding that an interface is unlawful.","synonyms":["nagging","continuous prompting","non-persistent dismissal","permission request returns after decline","upgrade popup returns after dismissal","rating or notification prompt interrupts repeatedly"],"category":"Nagging","family":"Nagging","journeyStages":["Signup","Checkout"],"jurisdiction":"Australia","status":"Editorial implementation guidance","howItWorks":"A business-favoured request repeatedly interrupts the user after decline, dismissal or non-response without a durable way to stop it. Refusal is stored only briefly while acceptance would be durable, allowing repeated interruption costs to wear down a choice already made.","warningSigns":["The prompt purpose is materially the same across occurrences.","The user previously declined, dismissed or ignored it.","Recurrence exceeds a configured reasonable observation rule and creates plausible pressure or time cost."],"harms":["Repeated interruption can wear down a refusal and prevent ordinary use of the service.","A traveller may accept simply to stop repeated interruptions or may believe the earlier refusal was ineffective."],"legitimateUses":["Required safety or legal notice","materially changed request triggered by a new user action","one reminder after a long and relevant interval"],"legalBasis":[{"provision":"ACL section 28B, inserted by the 2026 Act","sourceIds":["au-act-2026-64"],"classification":"Possible risk indicator","explanation":"In signup and checkout journeys, the repeated prompting mechanism may warrant review where it manipulates a consumer or unreasonably distorts the decision environment and causes, or is likely to cause, detriment. The nagging label and an interface similarity do not establish a contravention; the complete section 28B test, scope, facts and evidence must be applied from 1 July 2027."},{"provision":"Dark-pattern research taxonomy","sourceIds":["oecd-dark-commercial-patterns-2022"],"classification":"Editorial analysis","explanation":"The cited research sources support this working pattern within the nagging family. It is editorial implementation guidance, not an Australian statutory category, regulator finding or legal safe harbour."}],"examples":[{"type":"Illustrative example","context":"Notification request returns on every screen","scenario":"A fictional app shows the same full-screen notification request after the user declines, then repeats it on each of the next four screens.","harm":"Repeated interruption can wear down a refusal and prevent ordinary use of the service."},{"type":"Illustrative example","context":"Declined add-on repeatedly reappears","scenario":"A fictional booking journey restores a previously declined insurance offer at passenger details, payment and final confirmation.","harm":"A traveller may accept simply to stop repeated interruptions or may believe the earlier refusal was ineffective."}],"problematicUi":{"label":"Turn on notifications","copy":"Turn on notifications The request returns immediately after every decline. Not now Continue without notifications","annotations":["Why this state matters: The user’s earlier refusal loses effect while the request keeps interrupting the signup journey. The practical influence comes from recurrence, not from one isolated prompt: “The request returns immediately after every decline.” Repeated interruption can wear down a refusal and prevent ordinary use of the service.","Review prompt: Which event causes “Not now” to return after refusal, and how long does the product persist that refusal?"]},"improvedUi":{"label":"Notifications remain off","copy":"Notifications remain off The app records the refusal and explains where the setting can be changed later. Continue without notifications Not now What happens next Activating “Continue without notifications” produces the outcome stated on the control.","annotations":["Fairer design: Respect the decision for a meaningful period and keep any later change available in settings.","Review prompt: Can the dialog be dismissed, what action does each control trigger, and what later state confirms or contradicts “The prompt purpose is materially the same across occurrences”?"]},"uiComparisons":[{"id":"repeated-prompting-scenario-1","title":"Notification request returns on every screen","context":"Mobile app onboarding","journeyStage":"Signup","summary":"A fictional app shows the same full-screen notification request after the user declines, then repeats it on each of the next four screens.","problematic":{"label":"Turn on notifications","layout":"dialog","elements":[{"id":"problematic-1-heading","type":"heading","text":"Turn on notifications"},{"id":"problematic-2-body","type":"text","text":"The request returns immediately after every decline.","tone":"warning"},{"id":"problematic-3-button","type":"button","text":"Not now","emphasis":"primary"},{"id":"problematic-4-link","type":"link","text":"Continue without notifications","emphasis":"subtle"}],"annotations":[{"targetId":"problematic-2-body","text":"Why this state matters: The user’s earlier refusal loses effect while the request keeps interrupting the signup journey. The practical influence comes from recurrence, not from one isolated prompt: “The request returns immediately after every decline.” Repeated interruption can wear down a refusal and prevent ordinary use of the service."},{"targetId":"problematic-4-link","text":"Review prompt: Which event causes “Not now” to return after refusal, and how long does the product persist that refusal?"}]},"neutral":{"label":"Notifications remain off","layout":"dialog","elements":[{"id":"neutral-1-heading","type":"heading","text":"Notifications remain off"},{"id":"neutral-2-body","type":"text","text":"The app records the refusal and explains where the setting can be changed later.","tone":"default"},{"id":"neutral-3-button","type":"button","text":"Continue without notifications","emphasis":"secondary"},{"id":"neutral-4-link","type":"link","text":"Not now","emphasis":"default"},{"id":"neutral-5-disclosure","type":"disclosure","summary":"What happens next","content":"Activating “Continue without notifications” produces the outcome stated on the control.","open":true}],"annotations":[{"targetId":"neutral-2-body","text":"Fairer design: Respect the decision for a meaningful period and keep any later change available in settings."},{"targetId":"neutral-5-disclosure","text":"Review prompt: Can the dialog be dismissed, what action does each control trigger, and what later state confirms or contradicts “The prompt purpose is materially the same across occurrences”?"}]},"whyItMatters":"The user’s earlier refusal loses effect while the request keeps interrupting the signup journey. The practical influence comes from recurrence, not from one isolated prompt: “The request returns immediately after every decline.” Repeated interruption can wear down a refusal and prevent ordinary use of the service.","fairDesignPrinciple":"Respect the decision for a meaningful period and keep any later change available in settings.","reviewPrompts":["Which event causes “Not now” to return after refusal, and how long does the product persist that refusal?","Can the dialog be dismissed, what action does each control trigger, and what later state confirms or contradicts “The prompt purpose is materially the same across occurrences”?","After an explicit refusal, when may the prompt legitimately return, and how would that changed context remain distinct from “Required safety or legal notice”?"],"altText":"Side-by-side mobile app onboarding interface showing “Turn on notifications” and the clearer alternative “Notifications remain off”.","provenance":"Original hypothetical mobile app onboarding example created for this library; no real business, product or interface is depicted."},{"id":"repeated-prompting-scenario-2","title":"Declined add-on repeatedly reappears","context":"Travel checkout","journeyStage":"Checkout","summary":"A fictional booking journey restores a previously declined insurance offer at passenger details, payment and final confirmation.","problematic":{"label":"Add insurance before continuing","layout":"checkout-summary","elements":[{"id":"problematic-1-heading","type":"heading","text":"Add insurance before continuing"},{"id":"problematic-2-body","type":"text","text":"The same rejected extra blocks three later checkout steps.","tone":"warning"},{"id":"problematic-3-price","type":"price","label":"Amount affected","amount":"$24"},{"id":"problematic-4-button","type":"button","text":"Add $24 insurance","emphasis":"primary"},{"id":"problematic-5-link","type":"link","text":"Continue to payment","emphasis":"subtle"}],"annotations":[{"targetId":"problematic-2-body","text":"Why this state matters: The user’s earlier refusal loses effect while the request keeps interrupting the checkout journey. The practical influence comes from recurrence, not from one isolated prompt: “The same rejected extra blocks three later checkout steps.” A traveller may accept simply to stop repeated interruptions or may believe the earlier refusal was ineffective."},{"targetId":"problematic-5-link","text":"Review prompt: Which event causes “Add $24 insurance” to return after refusal, and how long does the product persist that refusal?"}]},"neutral":{"label":"Insurance declined","layout":"checkout-summary","elements":[{"id":"neutral-1-heading","type":"heading","text":"Insurance declined"},{"id":"neutral-2-body","type":"text","text":"The decision persists and checkout continues without another blocking prompt.","tone":"default"},{"id":"neutral-3-button","type":"button","text":"Continue to payment","emphasis":"secondary"},{"id":"neutral-4-link","type":"link","text":"Add $24 insurance","emphasis":"default"},{"id":"neutral-5-disclosure","type":"disclosure","summary":"Payable total and selected items","content":"The summary shows the line items and total before “Continue to payment” is activated.","open":true}],"annotations":[{"targetId":"neutral-2-body","text":"Fairer design: Persist the refusal throughout the transaction and provide one optional, non-blocking way to reconsider."},{"targetId":"neutral-5-disclosure","text":"Review prompt: Compare the basket before and after the action, including total and line items; does the mutation satisfy “The user previously declined, dismissed or ignored it”?"}]},"whyItMatters":"The user’s earlier refusal loses effect while the request keeps interrupting the checkout journey. The practical influence comes from recurrence, not from one isolated prompt: “The same rejected extra blocks three later checkout steps.” A traveller may accept simply to stop repeated interruptions or may believe the earlier refusal was ineffective.","fairDesignPrinciple":"Persist the refusal throughout the transaction and provide one optional, non-blocking way to reconsider.","reviewPrompts":["Which event causes “Add $24 insurance” to return after refusal, and how long does the product persist that refusal?","Compare the basket before and after the action, including total and line items; does the mutation satisfy “The user previously declined, dismissed or ignored it”?","After an explicit refusal, when may the prompt legitimately return, and how would that changed context remain distinct from “materially changed request triggered by a new user action”?"],"altText":"Side-by-side travel checkout interface showing “Add insurance before continuing” and the clearer alternative “Insurance declined”.","provenance":"Original hypothetical travel checkout example created for this library; no real business, product or interface is depicted."}],"fairAlternative":"Respect decline and dismissal, provide a durable preference, and limit reminders to justified, transparent intervals.","whyProblematic":"A business-favoured request repeatedly interrupts the user after decline, dismissal or non-response without a durable way to stop it. Refusal is stored only briefly while acceptance would be durable, allowing repeated interruption costs to wear down a choice already made. These harms describe a review risk, not an automatic legal conclusion. Australian section 28B commences on 1 July 2027 and requires its complete, context-specific test. Existing ACL provisions remain a separate current-law assessment.","contextFactors":["The prompt purpose is materially the same across occurrences.","The user previously declined, dismissed or ignored it.","Recurrence exceeds a configured reasonable observation rule and creates plausible pressure or time cost.","Boundary to test: Required safety or legal notice","Boundary to test: materially changed request triggered by a new user action","Boundary to test: one reminder after a long and relevant interval"],"affectedTeams":["Product","Design","Engineering","Legal","Compliance"],"reviewQuestions":["Which event causes “Not now” to return after refusal, and how long does the product persist that refusal?","Can the dialog be dismissed, what action does each control trigger, and what later state confirms or contradicts “The prompt purpose is materially the same across occurrences”?","After an explicit refusal, when may the prompt legitimately return, and how would that changed context remain distinct from “Required safety or legal notice”?","Which event causes “Add $24 insurance” to return after refusal, and how long does the product persist that refusal?","Compare the basket before and after the action, including total and line items; does the mutation satisfy “The user previously declined, dismissed or ignored it”?","After an explicit refusal, when may the prompt legitimately return, and how would that changed context remain distinct from “materially changed request triggered by a new user action”?"],"evidence":["Annotated signup and checkout screenshots at each responsive breakpoint","The complete state sequence before, during and after the consumer decision","Design-system component, content, default and configuration records for the reviewed release","Operational records substantiating price, availability, timing and eligibility claims","Usability, accessibility, reversal, complaint and support evidence relevant to consumer impact","A dated product and legal review record identifying evidence, uncertainties and release decisions"],"related":["bait-and-switch","bundled-options","choice-or-information-overload","complex-or-inaccessible-language"],"sourceIds":["oecd-dark-commercial-patterns-2022","au-act-2026-64"],"altText":"Side-by-side mobile app onboarding interface showing “Turn on notifications” and the clearer alternative “Notifications remain off”.","provenance":"Original hypothetical interface comparisons from the shared learning library, adapted to Australian-dollar context for this portal; no real business, product or interface is depicted.","author":"Flowlane","datePublished":"2026-08-10","dateModified":"2026-09-14","lastReviewed":"2026-09-14","changeNote":"Source comparison recorded and the current status restated."},{"title":"Account deletion obstruction","slug":"account-deletion-obstruction","preferredName":"Account deletion obstruction","directAnswer":"Account deletion obstruction is a working label for this design mechanism: Deleting an account is unavailable, disguised as another outcome or burdened by unnecessary barriers. This is editorial implementation guidance for Australian journeys, not a finding of unlawfulness. From 1 July 2027, a similar interface is relevant to ACL section 28B only if the complete consumer-connection, manipulation or unreasonable-distortion and actual-or-likely-detriment test is met. Current ACL rules require a separate assessment.","definition":"Deleting an account is unavailable, disguised as another outcome or burdened by unnecessary barriers. This is a design and research taxonomy for learning and evidence review, not a statutory offence label or an automatic finding that an interface is unlawful.","synonyms":["immortal account","undeletable account","deactivation offered instead of deletion","deletion request loops","unnecessary support contact","deletion control absent while creation is self-service"],"category":"Obstruction","family":"Obstruction","journeyStages":["Account Management"],"jurisdiction":"Australia","status":"Editorial implementation guidance","howItWorks":"Deleting an account is unavailable, disguised as another outcome or burdened by unnecessary barriers. The deletion route is hidden, delayed or conditioned on unnecessary information even after the user has authenticated and stated the irreversible account outcome.","warningSigns":["The user seeks permanent account deletion.","The observed route is missing, materially harder than account creation or produces only deactivation without clear disclosure.","The account persists after apparent completion or the journey cannot complete."],"harms":["A person may reasonably believe the account and associated data were deleted when only visibility changed.","People may be unable to exercise the represented account control because of irrelevant information and route barriers."],"legitimateUses":["Legally required record retention clearly distinguished from account access","reasonable authentication","temporary technical outage with a documented recovery path"],"legalBasis":[{"provision":"ACL section 28B, inserted by the 2026 Act","sourceIds":["au-act-2026-64"],"classification":"Possible risk indicator","explanation":"In account management journeys, the account deletion obstruction mechanism may warrant review where it manipulates a consumer or unreasonably distorts the decision environment and causes, or is likely to cause, detriment. The obstruction label and an interface similarity do not establish a contravention; the complete section 28B test, scope, facts and evidence must be applied from 1 July 2027."},{"provision":"Dark-pattern research taxonomy","sourceIds":["oecd-dark-commercial-patterns-2022"],"classification":"Editorial analysis","explanation":"The cited research sources support this working pattern within the obstruction family. It is editorial implementation guidance, not an Australian statutory category, regulator finding or legal safe harbour."}],"examples":[{"type":"Illustrative example","context":"Deactivation presented as deletion","scenario":"A fictional platform labels a control “Delete account”, but the confirmation only hides the profile and leaves data and reactivation available indefinitely.","harm":"A person may reasonably believe the account and associated data were deleted when only visibility changed."},{"type":"Illustrative example","context":"Deletion buried behind an unsupported ticket","scenario":"A fictional retailer places account deletion behind six help pages and requires a support ticket containing an order number even for users who never ordered.","harm":"People may be unable to exercise the represented account control because of irrelevant information and route barriers."}],"problematicUi":{"label":"Delete account","copy":"Delete account The resulting state is only temporary deactivation, disclosed after the action. Delete now Unconfirmed state: Delete now","annotations":["Why this state matters: The route adds avoidable effort between the user’s stated intention and completion. In this social account settings example, the obstacle is: “The resulting state is only temporary deactivation, disclosed after the action.” Evidence should show whether the alternative remains usable and whether “Permanently delete account” reaches the represented state. A person may reasonably believe the account and associated data were deleted when only visibility changed.","Review prompt: How many steps, waits and channel changes separate “Delete now” from the completed social account settings outcome?"]},"improvedUi":{"label":"Choose deactivation or deletion","copy":"Choose deactivation or deletion Each option states what remains, for how long and whether recovery is possible. Permanently delete account Saved state: Permanently delete account Persisted account state The saved state behind “Permanently delete account” remains consistent after refresh and across supported channels.","annotations":["Fairer design: Separate deactivation from deletion and state retention, timing, recovery and consequences before confirmation.","Review prompt: Test the control across refresh, device and account states; is “The user seeks permanent account deletion” still observable after persistence is considered?"]},"uiComparisons":[{"id":"account-deletion-obstruction-scenario-1","title":"Deactivation presented as deletion","context":"Social account settings","journeyStage":"Account Management","summary":"A fictional platform labels a control “Delete account”, but the confirmation only hides the profile and leaves data and reactivation available indefinitely.","problematic":{"label":"Delete account","layout":"account-panel","elements":[{"id":"problematic-1-heading","type":"heading","text":"Delete account"},{"id":"problematic-2-body","type":"text","text":"The resulting state is only temporary deactivation, disclosed after the action.","tone":"warning"},{"id":"problematic-3-link","type":"link","text":"Delete now","emphasis":"subtle"},{"id":"problematic-4-badge","type":"badge","text":"Unconfirmed state: Delete now","tone":"warning"}],"annotations":[{"targetId":"problematic-2-body","text":"Why this state matters: The route adds avoidable effort between the user’s stated intention and completion. In this social account settings example, the obstacle is: “The resulting state is only temporary deactivation, disclosed after the action.” Evidence should show whether the alternative remains usable and whether “Permanently delete account” reaches the represented state. A person may reasonably believe the account and associated data were deleted when only visibility changed."},{"targetId":"problematic-4-badge","text":"Review prompt: How many steps, waits and channel changes separate “Delete now” from the completed social account settings outcome?"}]},"neutral":{"label":"Choose deactivation or deletion","layout":"account-panel","elements":[{"id":"neutral-1-heading","type":"heading","text":"Choose deactivation or deletion"},{"id":"neutral-2-body","type":"text","text":"Each option states what remains, for how long and whether recovery is possible.","tone":"default"},{"id":"neutral-3-link","type":"link","text":"Permanently delete account","emphasis":"default"},{"id":"neutral-4-badge","type":"badge","text":"Saved state: Permanently delete account","tone":"default"},{"id":"neutral-5-disclosure","type":"disclosure","summary":"Persisted account state","content":"The saved state behind “Permanently delete account” remains consistent after refresh and across supported channels.","open":true}],"annotations":[{"targetId":"neutral-2-body","text":"Fairer design: Separate deactivation from deletion and state retention, timing, recovery and consequences before confirmation."},{"targetId":"neutral-5-disclosure","text":"Review prompt: Test the control across refresh, device and account states; is “The user seeks permanent account deletion” still observable after persistence is considered?"}]},"whyItMatters":"The route adds avoidable effort between the user’s stated intention and completion. In this social account settings example, the obstacle is: “The resulting state is only temporary deactivation, disclosed after the action.” Evidence should show whether the alternative remains usable and whether “Permanently delete account” reaches the represented state. A person may reasonably believe the account and associated data were deleted when only visibility changed.","fairDesignPrinciple":"Separate deactivation from deletion and state retention, timing, recovery and consequences before confirmation.","reviewPrompts":["How many steps, waits and channel changes separate “Delete now” from the completed social account settings outcome?","Test the control across refresh, device and account states; is “The user seeks permanent account deletion” still observable after persistence is considered?","Measure the same task through the clearest available route: does the effort difference persist once “Legally required record retention clearly distinguished from account access” is accounted for?"],"altText":"Side-by-side social account settings interface showing “Delete account” and the clearer alternative “Choose deactivation or deletion”.","provenance":"Original hypothetical social account settings example created for this library; no real business, product or interface is depicted."},{"id":"account-deletion-obstruction-scenario-2","title":"Deletion buried behind an unsupported ticket","context":"Shopping account","journeyStage":"Account Management","summary":"A fictional retailer places account deletion behind six help pages and requires a support ticket containing an order number even for users who never ordered.","problematic":{"label":"Contact support to delete","layout":"cancellation-flow","elements":[{"id":"problematic-1-heading","type":"heading","text":"Contact support to delete"},{"id":"problematic-2-body","type":"text","text":"The form rejects users without an order number and links back to the same help article.","tone":"warning"},{"id":"problematic-3-step","type":"step","label":"Blocking step"},{"id":"problematic-4-step","type":"step","label":"Obscured outcome"}],"annotations":[{"targetId":"problematic-2-body","text":"Why this state matters: The route adds avoidable effort between the user’s stated intention and completion. In this shopping account example, the obstacle is: “The form rejects users without an order number and links back to the same help article.” Evidence should show whether the alternative remains usable and whether “Request deletion” reaches the represented state. People may be unable to exercise the represented account control because of irrelevant information and route barriers."},{"targetId":"problematic-4-step","text":"Review prompt: How many steps, waits and channel changes separate “Enter order number” from the completed shopping account outcome?"}]},"neutral":{"label":"Delete your account","layout":"cancellation-flow","elements":[{"id":"neutral-1-heading","type":"heading","text":"Delete your account"},{"id":"neutral-2-body","type":"text","text":"A direct settings route uses account authentication and explains completion timing.","tone":"default"},{"id":"neutral-3-step","type":"step","label":"Completion step"},{"id":"neutral-4-step","type":"step","label":"Recorded outcome"},{"id":"neutral-5-badge","type":"badge","text":"Request recorded: Request deletion","tone":"default"}],"annotations":[{"targetId":"neutral-2-body","text":"Fairer design: Put deletion in normal settings, require only necessary verification and offer a usable fallback for inaccessible accounts."},{"targetId":"neutral-5-badge","text":"Review prompt: Count steps, waits, offers and channel changes through final confirmation; where does the route meet “The observed route is missing, materially harder than account creation or produces only deactivation without clear disclosure”?"}]},"whyItMatters":"The route adds avoidable effort between the user’s stated intention and completion. In this shopping account example, the obstacle is: “The form rejects users without an order number and links back to the same help article.” Evidence should show whether the alternative remains usable and whether “Request deletion” reaches the represented state. People may be unable to exercise the represented account control because of irrelevant information and route barriers.","fairDesignPrinciple":"Put deletion in normal settings, require only necessary verification and offer a usable fallback for inaccessible accounts.","reviewPrompts":["How many steps, waits and channel changes separate “Enter order number” from the completed shopping account outcome?","Count steps, waits, offers and channel changes through final confirmation; where does the route meet “The observed route is missing, materially harder than account creation or produces only deactivation without clear disclosure”?","Measure the same task through the clearest available route: does the effort difference persist once “reasonable authentication” is accounted for?"],"altText":"Side-by-side shopping account interface showing “Contact support to delete” and the clearer alternative “Delete your account”.","provenance":"Original hypothetical shopping account example created for this library; no real business, product or interface is depicted."}],"fairAlternative":"Offer a clear self-service deletion route, distinguish deletion from deactivation, and confirm the resulting state.","whyProblematic":"Deleting an account is unavailable, disguised as another outcome or burdened by unnecessary barriers. The deletion route is hidden, delayed or conditioned on unnecessary information even after the user has authenticated and stated the irreversible account outcome. These harms describe a review risk, not an automatic legal conclusion. Australian section 28B commences on 1 July 2027 and requires its complete, context-specific test. Existing ACL provisions remain a separate current-law assessment.","contextFactors":["The user seeks permanent account deletion.","The observed route is missing, materially harder than account creation or produces only deactivation without clear disclosure.","The account persists after apparent completion or the journey cannot complete.","Boundary to test: Legally required record retention clearly distinguished from account access","Boundary to test: reasonable authentication","Boundary to test: temporary technical outage with a documented recovery path"],"affectedTeams":["Product","Design","Engineering","Legal","Compliance"],"reviewQuestions":["How many steps, waits and channel changes separate “Delete now” from the completed social account settings outcome?","Test the control across refresh, device and account states; is “The user seeks permanent account deletion” still observable after persistence is considered?","Measure the same task through the clearest available route: does the effort difference persist once “Legally required record retention clearly distinguished from account access” is accounted for?","How many steps, waits and channel changes separate “Enter order number” from the completed shopping account outcome?","Count steps, waits, offers and channel changes through final confirmation; where does the route meet “The observed route is missing, materially harder than account creation or produces only deactivation without clear disclosure”?","Measure the same task through the clearest available route: does the effort difference persist once “reasonable authentication” is accounted for?"],"evidence":["Annotated account management screenshots at each responsive breakpoint","The complete state sequence before, during and after the consumer decision","Design-system component, content, default and configuration records for the reviewed release","Operational records substantiating price, availability, timing and eligibility claims","Usability, accessibility, reversal, complaint and support evidence relevant to consumer impact","A dated product and legal review record identifying evidence, uncertainties and release decisions"],"related":["comparison-prevention","customer-support-obstruction","dead-end","cancellation-friction"],"sourceIds":["oecd-dark-commercial-patterns-2022","au-act-2026-64"],"altText":"Side-by-side social account settings interface showing “Delete account” and the clearer alternative “Choose deactivation or deletion”.","provenance":"Original hypothetical interface comparisons from the shared learning library, adapted to Australian-dollar context for this portal; no real business, product or interface is depicted.","author":"Flowlane","datePublished":"2026-08-10","dateModified":"2026-09-14","lastReviewed":"2026-09-14","changeNote":"Source comparison recorded and the current status restated."},{"title":"Comparison prevention","slug":"comparison-prevention","preferredName":"Comparison prevention","directAnswer":"Comparison prevention is a working label for this design mechanism: Information needed to compare products, plans or consequences is presented in inconsistent, fragmented or unusable form. This is editorial implementation guidance for Australian journeys, not a finding of unlawfulness. From 1 July 2027, a similar interface is relevant to ACL section 28B only if the complete consumer-connection, manipulation or unreasonable-distortion and actual-or-likely-detriment test is met. Current ACL rules require a separate assessment.","definition":"Information needed to compare products, plans or consequences is presented in inconsistent, fragmented or unusable form. This is a design and research taxonomy for learning and evidence review, not a statutory offence label or an automatic finding that an interface is unlawful.","synonyms":["hard-to-compare","attribute fragmentation","inconsistent units","features split across tabs","total price omitted from comparison","plan names changed between steps"],"category":"Obstruction","family":"Obstruction","journeyStages":["Pricing"],"jurisdiction":"Australia","status":"Editorial implementation guidance","howItWorks":"Information needed to compare products, plans or consequences is presented in inconsistent, fragmented or unusable form. Material attributes use incompatible units, labels, ordering or one-at-a-time views, forcing avoidable transformation and memory work before alternatives can be compared.","warningSigns":["Two or more realistic alternatives are presented.","At least one material attribute cannot be compared without avoidable transformation or navigation.","The structure favours a particular option, default or abandonment of comparison."],"harms":["Customers cannot make a meaningful like-for-like comparison and may select a plan with a higher real cost.","A shopper may be unable to compare material dimensions and may default to the plan the interface opens last."],"legitimateUses":["Inherent differences that cannot be expressed on a shared basis","optional advanced detail with a complete comparable summary","minor cosmetic inconsistency"],"legalBasis":[{"provision":"ACL section 28B, inserted by the 2026 Act","sourceIds":["au-act-2026-64"],"classification":"Possible risk indicator","explanation":"In pricing journeys, the comparison prevention mechanism may warrant review where it manipulates a consumer or unreasonably distorts the decision environment and causes, or is likely to cause, detriment. The obstruction label and an interface similarity do not establish a contravention; the complete section 28B test, scope, facts and evidence must be applied from 1 July 2027."},{"provision":"Dark-pattern research taxonomy","sourceIds":["oecd-dark-commercial-patterns-2022"],"classification":"Editorial analysis","explanation":"The cited research sources support this working pattern within the obstruction family. It is editorial implementation guidance, not an Australian statutory category, regulator finding or legal safe harbour."}],"examples":[{"type":"Illustrative example","context":"Plans use incompatible pricing units","scenario":"A fictional provider shows one plan per week, another per four weeks and a third per gigabyte, without a consistent total or usage assumption.","harm":"Customers cannot make a meaningful like-for-like comparison and may select a plan with a higher real cost."},{"type":"Illustrative example","context":"Plan details cannot be retained side by side","scenario":"A fictional quote tool reveals one plan at a time, clears the previous plan whenever another is opened and provides no stable summary of limits, excess or exclusions.","harm":"A shopper may be unable to compare material dimensions and may default to the plan the interface opens last."}],"problematicUi":{"label":"Three ways to save","copy":"Three ways to save Prices use weekly, four-week and usage units with no common baseline. Displayed amount $8 Open comparison table","annotations":["Why this state matters: The route adds avoidable effort between the user’s stated intention and completion. In this telecom comparison example, the obstacle is: “Prices use weekly, four-week and usage units with no common baseline.” Evidence should show whether the alternative remains usable and whether “Open comparison table” reaches the represented state. Customers cannot make a meaningful like-for-like comparison and may select a plan with a higher real cost.","Review prompt: How many steps, waits and channel changes separate “From $8” from the completed telecom comparison outcome?"]},"improvedUi":{"label":"Compare monthly cost","copy":"Compare monthly cost Every plan shows the same monthly basis, data allowance, term and total. Open comparison table From $8 Price, period and commitment The price and material terms associated with “Open comparison table” remain beside this choice.","annotations":["Fairer design: Add a consistent billing-period total, usage basis and sortable comparison while preserving original terms.","Review prompt: Place the compared prices, billing periods and material terms on one evidence sheet; where does it support “Two or more realistic alternatives are presented”?"]},"uiComparisons":[{"id":"comparison-prevention-scenario-1","title":"Plans use incompatible pricing units","context":"Telecom comparison","journeyStage":"Pricing","summary":"A fictional provider shows one plan per week, another per four weeks and a third per gigabyte, without a consistent total or usage assumption.","problematic":{"label":"Three ways to save","layout":"pricing-card","elements":[{"id":"problematic-1-heading","type":"heading","text":"Three ways to save"},{"id":"problematic-2-body","type":"text","text":"Prices use weekly, four-week and usage units with no common baseline.","tone":"warning"},{"id":"problematic-3-price","type":"price","label":"Displayed amount","amount":"$8"},{"id":"problematic-4-link","type":"link","text":"Open comparison table","emphasis":"subtle"}],"annotations":[{"targetId":"problematic-2-body","text":"Why this state matters: The route adds avoidable effort between the user’s stated intention and completion. In this telecom comparison example, the obstacle is: “Prices use weekly, four-week and usage units with no common baseline.” Evidence should show whether the alternative remains usable and whether “Open comparison table” reaches the represented state. Customers cannot make a meaningful like-for-like comparison and may select a plan with a higher real cost."},{"targetId":"problematic-4-link","text":"Review prompt: How many steps, waits and channel changes separate “From $8” from the completed telecom comparison outcome?"}]},"neutral":{"label":"Compare monthly cost","layout":"pricing-card","elements":[{"id":"neutral-1-heading","type":"heading","text":"Compare monthly cost"},{"id":"neutral-2-body","type":"text","text":"Every plan shows the same monthly basis, data allowance, term and total.","tone":"default"},{"id":"neutral-3-button","type":"button","text":"Open comparison table","emphasis":"secondary"},{"id":"neutral-4-link","type":"link","text":"From $8","emphasis":"default"},{"id":"neutral-5-disclosure","type":"disclosure","summary":"Price, period and commitment","content":"The price and material terms associated with “Open comparison table” remain beside this choice.","open":true}],"annotations":[{"targetId":"neutral-2-body","text":"Fairer design: Add a consistent billing-period total, usage basis and sortable comparison while preserving original terms."},{"targetId":"neutral-5-disclosure","text":"Review prompt: Place the compared prices, billing periods and material terms on one evidence sheet; where does it support “Two or more realistic alternatives are presented”?"}]},"whyItMatters":"The route adds avoidable effort between the user’s stated intention and completion. In this telecom comparison example, the obstacle is: “Prices use weekly, four-week and usage units with no common baseline.” Evidence should show whether the alternative remains usable and whether “Open comparison table” reaches the represented state. Customers cannot make a meaningful like-for-like comparison and may select a plan with a higher real cost.","fairDesignPrinciple":"Add a consistent billing-period total, usage basis and sortable comparison while preserving original terms.","reviewPrompts":["How many steps, waits and channel changes separate “From $8” from the completed telecom comparison outcome?","Place the compared prices, billing periods and material terms on one evidence sheet; where does it support “Two or more realistic alternatives are presented”?","Measure the same task through the clearest available route: does the effort difference persist once “Inherent differences that cannot be expressed on a shared basis” is accounted for?"],"altText":"Side-by-side telecom comparison interface showing “Three ways to save” and the clearer alternative “Compare monthly cost”.","provenance":"Original hypothetical telecom comparison example created for this library; no real business, product or interface is depicted."},{"id":"comparison-prevention-scenario-2","title":"Plan details cannot be retained side by side","context":"Insurance quote comparison","journeyStage":"Pricing","summary":"A fictional quote tool reveals one plan at a time, clears the previous plan whenever another is opened and provides no stable summary of limits, excess or exclusions.","problematic":{"label":"Review one plan","layout":"pricing-card","elements":[{"id":"problematic-1-heading","type":"heading","text":"Review one plan"},{"id":"problematic-2-body","type":"text","text":"Opening another quote removes the earlier plan and changes the order of attributes.","tone":"warning"},{"id":"problematic-3-button","type":"button","text":"Open next quote","emphasis":"primary"},{"id":"problematic-4-link","type":"link","text":"Open comparison table","emphasis":"subtle"}],"annotations":[{"targetId":"problematic-2-body","text":"Why this state matters: The route adds avoidable effort between the user’s stated intention and completion. In this insurance quote comparison example, the obstacle is: “Opening another quote removes the earlier plan and changes the order of attributes.” Evidence should show whether the alternative remains usable and whether “Open comparison table” reaches the represented state. A shopper may be unable to compare material dimensions and may default to the plan the interface opens last."},{"targetId":"problematic-4-link","text":"Review prompt: How many steps, waits and channel changes separate “Open next quote” from the completed insurance quote comparison outcome?"}]},"neutral":{"label":"Compare three quotes","layout":"pricing-card","elements":[{"id":"neutral-1-heading","type":"heading","text":"Compare three quotes"},{"id":"neutral-2-body","type":"text","text":"Selected plans remain visible in one consistent table.","tone":"default"},{"id":"neutral-3-button","type":"button","text":"Open comparison table","emphasis":"secondary"},{"id":"neutral-4-link","type":"link","text":"Open next quote","emphasis":"default"},{"id":"neutral-5-disclosure","type":"disclosure","summary":"Price, period and commitment","content":"The price and material terms associated with “Open comparison table” remain beside this choice.","open":true}],"annotations":[{"targetId":"neutral-2-body","text":"Fairer design: Provide a durable side-by-side table with consistent price, limit, excess and exclusion fields, while keeping source detail available."},{"targetId":"neutral-5-disclosure","text":"Review prompt: Place the compared prices, billing periods and material terms on one evidence sheet; where does it support “At least one material attribute cannot be compared without avoidable transformation or navigation”?"}]},"whyItMatters":"The route adds avoidable effort between the user’s stated intention and completion. In this insurance quote comparison example, the obstacle is: “Opening another quote removes the earlier plan and changes the order of attributes.” Evidence should show whether the alternative remains usable and whether “Open comparison table” reaches the represented state. A shopper may be unable to compare material dimensions and may default to the plan the interface opens last.","fairDesignPrinciple":"Provide a durable side-by-side table with consistent price, limit, excess and exclusion fields, while keeping source detail available.","reviewPrompts":["How many steps, waits and channel changes separate “Open next quote” from the completed insurance quote comparison outcome?","Place the compared prices, billing periods and material terms on one evidence sheet; where does it support “At least one material attribute cannot be compared without avoidable transformation or navigation”?","Measure the same task through the clearest available route: does the effort difference persist once “optional advanced detail with a complete comparable summary” is accounted for?"],"altText":"Side-by-side insurance quote comparison interface showing “Review one plan” and the clearer alternative “Compare three quotes”.","provenance":"Original hypothetical insurance quote comparison example created for this library; no real business, product or interface is depicted."}],"fairAlternative":"Use consistent units, terminology and side-by-side material totals with accessible supporting detail.","whyProblematic":"Information needed to compare products, plans or consequences is presented in inconsistent, fragmented or unusable form. Material attributes use incompatible units, labels, ordering or one-at-a-time views, forcing avoidable transformation and memory work before alternatives can be compared. These harms describe a review risk, not an automatic legal conclusion. Australian section 28B commences on 1 July 2027 and requires its complete, context-specific test. Existing ACL provisions remain a separate current-law assessment.","contextFactors":["Two or more realistic alternatives are presented.","At least one material attribute cannot be compared without avoidable transformation or navigation.","The structure favours a particular option, default or abandonment of comparison.","Boundary to test: Inherent differences that cannot be expressed on a shared basis","Boundary to test: optional advanced detail with a complete comparable summary","Boundary to test: minor cosmetic inconsistency"],"affectedTeams":["Product","Design","Engineering","Legal","Compliance"],"reviewQuestions":["How many steps, waits and channel changes separate “From $8” from the completed telecom comparison outcome?","Place the compared prices, billing periods and material terms on one evidence sheet; where does it support “Two or more realistic alternatives are presented”?","Measure the same task through the clearest available route: does the effort difference persist once “Inherent differences that cannot be expressed on a shared basis” is accounted for?","How many steps, waits and channel changes separate “Open next quote” from the completed insurance quote comparison outcome?","Place the compared prices, billing periods and material terms on one evidence sheet; where does it support “At least one material attribute cannot be compared without avoidable transformation or navigation”?","Measure the same task through the clearest available route: does the effort difference persist once “optional advanced detail with a complete comparable summary” is accounted for?"],"evidence":["Annotated pricing screenshots at each responsive breakpoint","The complete state sequence before, during and after the consumer decision","Design-system component, content, default and configuration records for the reviewed release","Operational records substantiating price, availability, timing and eligibility claims","Usability, accessibility, reversal, complaint and support evidence relevant to consumer impact","A dated product and legal review record identifying evidence, uncertainties and release decisions"],"related":["account-deletion-obstruction","customer-support-obstruction","dead-end","cancellation-friction"],"sourceIds":["oecd-dark-commercial-patterns-2022","au-act-2026-64"],"altText":"Side-by-side telecom comparison interface showing “Three ways to save” and the clearer alternative “Compare monthly cost”.","provenance":"Original hypothetical interface comparisons from the shared learning library, adapted to Australian-dollar context for this portal; no real business, product or interface is depicted.","author":"Flowlane","datePublished":"2026-08-10","dateModified":"2026-09-14","lastReviewed":"2026-09-14","changeNote":"Source comparison recorded and the current status restated."},{"title":"Customer-support obstruction","slug":"customer-support-obstruction","preferredName":"Customer-support obstruction","directAnswer":"Customer-support obstruction is a working label for this design mechanism: Access to support needed to resolve a purchase, account, charge or right is hidden or burdened by unnecessary loops and dead ends. This is editorial implementation guidance for Australian journeys, not a finding of unlawfulness. From 1 July 2027, a similar interface is relevant to ACL section 28B only if the complete consumer-connection, manipulation or unreasonable-distortion and actual-or-likely-detriment test is met. Current ACL rules require a separate assessment.","definition":"Access to support needed to resolve a purchase, account, charge or right is hidden or burdened by unnecessary loops and dead ends. This is a design and research taxonomy for learning and evidence review, not a statutory offence label or an automatic finding that an interface is unlawful.","synonyms":["support maze","contact obstruction","contact channel hidden","bot loop without escalation","issue categories exclude the user's right","support form repeatedly resets"],"category":"Obstruction","family":"Obstruction","journeyStages":["Account Management","Pricing"],"jurisdiction":"Australia","status":"Editorial implementation guidance","howItWorks":"Access to support needed to resolve a purchase, account, charge or right is hidden or burdened by unnecessary loops and dead ends. Self-service loops or irrelevant prerequisites prevent a user from raising the actual issue and preserving a case through an accessible support route.","warningSigns":["Support is materially needed for a consumer issue connected with supply.","Available routes are difficult to find, repeatedly loop or lack a viable escalation path.","The obstruction plausibly delays or prevents remedy."],"harms":["A customer may be unable to dispute a charge or preserve evidence of the request.","Potential customers cannot obtain material support because the form assumes a completed transaction."],"legitimateUses":["Reasonable queue or documented service hours","self-service that fully resolves the issue","support not relevant to the scanned transaction"],"legalBasis":[{"provision":"ACL section 28B, inserted by the 2026 Act","sourceIds":["au-act-2026-64"],"classification":"Possible risk indicator","explanation":"In account management and pricing journeys, the customer-support obstruction mechanism may warrant review where it manipulates a consumer or unreasonably distorts the decision environment and causes, or is likely to cause, detriment. The obstruction label and an interface similarity do not establish a contravention; the complete section 28B test, scope, facts and evidence must be applied from 1 July 2027."},{"provision":"Dark-pattern research taxonomy","sourceIds":["gray-ontology-dark-patterns-2024"],"classification":"Editorial analysis","explanation":"The cited research sources support this working pattern within the obstruction family. It is editorial implementation guidance, not an Australian statutory category, regulator finding or legal safe harbour."}],"examples":[{"type":"Illustrative example","context":"Support bot loops without escalation","scenario":"A fictional subscription service routes every “charged after cancellation” message through the same three bot articles and offers no human or written case route.","harm":"A customer may be unable to dispute a charge or preserve evidence of the request."},{"type":"Illustrative example","context":"Contact form requires irrelevant purchase data","scenario":"A fictional retailer’s only contact form requires an order number and rejects enquiries from people seeking accessibility information before purchase.","harm":"Potential customers cannot obtain material support because the form assumes a completed transaction."}],"problematicUi":{"label":"How can we help?","copy":"How can we help? The bot repeats three articles and closes the conversation after each answer. Start over Unconfirmed state: Start over","annotations":["Why this state matters: The route adds avoidable effort between the user’s stated intention and completion. In this billing support example, the obstacle is: “The bot repeats three articles and closes the conversation after each answer.” Evidence should show whether the alternative remains usable and whether “Send to support” reaches the represented state. A customer may be unable to dispute a charge or preserve evidence of the request.","Review prompt: How many steps, waits and channel changes separate “Start over” from the completed billing support outcome?"]},"improvedUi":{"label":"Billing issue not resolved","copy":"Billing issue not resolved A written escalation route preserves the history and creates a case number. Send to support Saved state: Send to support Persisted account state The saved state behind “Send to support” remains consistent after refresh and across supported channels.","annotations":["Fairer design: Provide an accessible escalation route, retain the conversation and issue a case reference when self-service cannot resolve the issue.","Review prompt: Test the control across refresh, device and account states; is “Support is materially needed for a consumer issue connected with supply” still observable after persistence is considered?"]},"uiComparisons":[{"id":"customer-support-obstruction-scenario-1","title":"Support bot loops without escalation","context":"Billing support","journeyStage":"Account Management","summary":"A fictional subscription service routes every “charged after cancellation” message through the same three bot articles and offers no human or written case route.","problematic":{"label":"How can we help?","layout":"account-panel","elements":[{"id":"problematic-1-heading","type":"heading","text":"How can we help?"},{"id":"problematic-2-body","type":"text","text":"The bot repeats three articles and closes the conversation after each answer.","tone":"warning"},{"id":"problematic-3-link","type":"link","text":"Start over","emphasis":"subtle"},{"id":"problematic-4-badge","type":"badge","text":"Unconfirmed state: Start over","tone":"warning"}],"annotations":[{"targetId":"problematic-2-body","text":"Why this state matters: The route adds avoidable effort between the user’s stated intention and completion. In this billing support example, the obstacle is: “The bot repeats three articles and closes the conversation after each answer.” Evidence should show whether the alternative remains usable and whether “Send to support” reaches the represented state. A customer may be unable to dispute a charge or preserve evidence of the request."},{"targetId":"problematic-4-badge","text":"Review prompt: How many steps, waits and channel changes separate “Start over” from the completed billing support outcome?"}]},"neutral":{"label":"Billing issue not resolved","layout":"account-panel","elements":[{"id":"neutral-1-heading","type":"heading","text":"Billing issue not resolved"},{"id":"neutral-2-body","type":"text","text":"A written escalation route preserves the history and creates a case number.","tone":"default"},{"id":"neutral-3-link","type":"link","text":"Send to support","emphasis":"default"},{"id":"neutral-4-badge","type":"badge","text":"Saved state: Send to support","tone":"default"},{"id":"neutral-5-disclosure","type":"disclosure","summary":"Persisted account state","content":"The saved state behind “Send to support” remains consistent after refresh and across supported channels.","open":true}],"annotations":[{"targetId":"neutral-2-body","text":"Fairer design: Provide an accessible escalation route, retain the conversation and issue a case reference when self-service cannot resolve the issue."},{"targetId":"neutral-5-disclosure","text":"Review prompt: Test the control across refresh, device and account states; is “Support is materially needed for a consumer issue connected with supply” still observable after persistence is considered?"}]},"whyItMatters":"The route adds avoidable effort between the user’s stated intention and completion. In this billing support example, the obstacle is: “The bot repeats three articles and closes the conversation after each answer.” Evidence should show whether the alternative remains usable and whether “Send to support” reaches the represented state. A customer may be unable to dispute a charge or preserve evidence of the request.","fairDesignPrinciple":"Provide an accessible escalation route, retain the conversation and issue a case reference when self-service cannot resolve the issue.","reviewPrompts":["How many steps, waits and channel changes separate “Start over” from the completed billing support outcome?","Test the control across refresh, device and account states; is “Support is materially needed for a consumer issue connected with supply” still observable after persistence is considered?","Measure the same task through the clearest available route: does the effort difference persist once “Reasonable queue or documented service hours” is accounted for?"],"altText":"Side-by-side billing support interface showing “How can we help?” and the clearer alternative “Billing issue not resolved”.","provenance":"Original hypothetical billing support example created for this library; no real business, product or interface is depicted."},{"id":"customer-support-obstruction-scenario-2","title":"Contact form requires irrelevant purchase data","context":"Pre-sale accessibility query","journeyStage":"Pricing","summary":"A fictional retailer’s only contact form requires an order number and rejects enquiries from people seeking accessibility information before purchase.","problematic":{"label":"Contact customer care","layout":"form","elements":[{"id":"problematic-1-heading","type":"heading","text":"Contact customer care"},{"id":"problematic-2-body","type":"text","text":"An order number is mandatory for every topic.","tone":"warning"},{"id":"problematic-3-input","type":"input","label":"Required order number","placeholder":"Enter required order number"},{"id":"problematic-4-input","type":"input","label":"Question","placeholder":"Enter question"},{"id":"problematic-5-button","type":"button","text":"Enter order number","emphasis":"primary"}],"annotations":[{"targetId":"problematic-2-body","text":"Why this state matters: The route adds avoidable effort between the user’s stated intention and completion. In this pre-sale accessibility query example, the obstacle is: “An order number is mandatory for every topic.” Evidence should show whether the alternative remains usable and whether “Send accessibility question” reaches the represented state. Potential customers cannot obtain material support because the form assumes a completed transaction."},{"targetId":"problematic-5-button","text":"Review prompt: How many steps, waits and channel changes separate “Enter order number” from the completed pre-sale accessibility query outcome?"}]},"neutral":{"label":"Choose an enquiry type","layout":"form","elements":[{"id":"neutral-1-heading","type":"heading","text":"Choose an enquiry type"},{"id":"neutral-2-body","type":"text","text":"Pre-sale questions can be sent without purchase data.","tone":"default"},{"id":"neutral-3-input","type":"input","label":"Email address","placeholder":"Enter email address"},{"id":"neutral-4-input","type":"input","label":"Accessibility question","placeholder":"Enter accessibility question"},{"id":"neutral-5-button","type":"button","text":"Send accessibility question","emphasis":"secondary"},{"id":"neutral-6-disclosure","type":"disclosure","summary":"Purpose and refusal effect","content":"The form explains why “Send accessibility question” is requested and what happens if it is not used.","open":true}],"annotations":[{"targetId":"neutral-2-body","text":"Fairer design: Ask only for information relevant to the enquiry and provide routes for pre-sale, account and order support."},{"targetId":"neutral-6-disclosure","text":"Review prompt: Which fields or permissions are required, what happens on refusal, and does the resulting state support this criterion: “Available routes are difficult to find, repeatedly loop or lack a viable escalation path”?"}]},"whyItMatters":"The route adds avoidable effort between the user’s stated intention and completion. In this pre-sale accessibility query example, the obstacle is: “An order number is mandatory for every topic.” Evidence should show whether the alternative remains usable and whether “Send accessibility question” reaches the represented state. Potential customers cannot obtain material support because the form assumes a completed transaction.","fairDesignPrinciple":"Ask only for information relevant to the enquiry and provide routes for pre-sale, account and order support.","reviewPrompts":["How many steps, waits and channel changes separate “Enter order number” from the completed pre-sale accessibility query outcome?","Which fields or permissions are required, what happens on refusal, and does the resulting state support this criterion: “Available routes are difficult to find, repeatedly loop or lack a viable escalation path”?","Measure the same task through the clearest available route: does the effort difference persist once “self-service that fully resolves the issue” is accounted for?"],"altText":"Side-by-side pre-sale accessibility query interface showing “Contact customer care” and the clearer alternative “Choose an enquiry type”.","provenance":"Original hypothetical pre-sale accessibility query example created for this library; no real business, product or interface is depicted."}],"fairAlternative":"Provide a discoverable support route, preserve context, and offer viable escalation for unresolved material issues.","whyProblematic":"Access to support needed to resolve a purchase, account, charge or right is hidden or burdened by unnecessary loops and dead ends. Self-service loops or irrelevant prerequisites prevent a user from raising the actual issue and preserving a case through an accessible support route. These harms describe a review risk, not an automatic legal conclusion. Australian section 28B commences on 1 July 2027 and requires its complete, context-specific test. Existing ACL provisions remain a separate current-law assessment.","contextFactors":["Support is materially needed for a consumer issue connected with supply.","Available routes are difficult to find, repeatedly loop or lack a viable escalation path.","The obstruction plausibly delays or prevents remedy.","Boundary to test: Reasonable queue or documented service hours","Boundary to test: self-service that fully resolves the issue","Boundary to test: support not relevant to the scanned transaction"],"affectedTeams":["Product","Design","Engineering","Legal","Compliance"],"reviewQuestions":["How many steps, waits and channel changes separate “Start over” from the completed billing support outcome?","Test the control across refresh, device and account states; is “Support is materially needed for a consumer issue connected with supply” still observable after persistence is considered?","Measure the same task through the clearest available route: does the effort difference persist once “Reasonable queue or documented service hours” is accounted for?","How many steps, waits and channel changes separate “Enter order number” from the completed pre-sale accessibility query outcome?","Which fields or permissions are required, what happens on refusal, and does the resulting state support this criterion: “Available routes are difficult to find, repeatedly loop or lack a viable escalation path”?","Measure the same task through the clearest available route: does the effort difference persist once “self-service that fully resolves the issue” is accounted for?"],"evidence":["Annotated account management and pricing screenshots at each responsive breakpoint","The complete state sequence before, during and after the consumer decision","Design-system component, content, default and configuration records for the reviewed release","Operational records substantiating price, availability, timing and eligibility claims","Usability, accessibility, reversal, complaint and support evidence relevant to consumer impact","A dated product and legal review record identifying evidence, uncertainties and release decisions"],"related":["account-deletion-obstruction","comparison-prevention","dead-end","cancellation-friction"],"sourceIds":["gray-ontology-dark-patterns-2024","au-act-2026-64"],"altText":"Side-by-side billing support interface showing “How can we help?” and the clearer alternative “Billing issue not resolved”.","provenance":"Original hypothetical interface comparisons from the shared learning library, adapted to Australian-dollar context for this portal; no real business, product or interface is depicted.","author":"Flowlane","datePublished":"2026-08-10","dateModified":"2026-09-14","lastReviewed":"2026-09-14","changeNote":"Source comparison recorded and the current status restated."},{"title":"Dead end","slug":"dead-end","preferredName":"Dead end","directAnswer":"Dead end is a working label for this design mechanism: A consumer-favourable route cannot reach its represented outcome and instead loops, stalls or loses progress. This is editorial implementation guidance for Australian journeys, not a finding of unlawfulness. From 1 July 2027, a similar interface is relevant to ACL section 28B only if the complete consumer-connection, manipulation or unreasonable-distortion and actual-or-likely-detriment test is met. Current ACL rules require a separate assessment.","definition":"A consumer-favourable route cannot reach its represented outcome and instead loops, stalls or loses progress. This is a design and research taxonomy for learning and evidence review, not a statutory offence label or an automatic finding that an interface is unlawful.","synonyms":["interaction dead end","blocked path","decline route returns to same prompt","no completion control","error only on consumer-favourable path","back navigation loses progress"],"category":"Obstruction","family":"Obstruction","journeyStages":["Account Management","Cancellation"],"jurisdiction":"Australia","status":"Editorial implementation guidance","howItWorks":"A consumer-favourable route cannot reach its represented outcome and instead loops, stalls or loses progress. A route represents that a request can complete but then loops, errors or changes no durable state, without a working recovery path or confirmation record.","warningSigns":["The interface represents or reasonably implies that the outcome is available.","Repeated execution cannot reach that outcome under controlled conditions.","A business-favoured route remains functional or the failure systematically burdens the alternative."],"harms":["A customer may abandon a valid request after repeating work without a way to complete or recover.","The represented outcome is not reached, leaving the subscriber exposed to another charge."],"legitimateUses":["General outage affecting all paths","validation error caused by invalid fixture input","clearly unavailable option"],"legalBasis":[{"provision":"ACL section 28B, inserted by the 2026 Act","sourceIds":["au-act-2026-64"],"classification":"Possible risk indicator","explanation":"In account management and cancellation journeys, the dead end mechanism may warrant review where it manipulates a consumer or unreasonably distorts the decision environment and causes, or is likely to cause, detriment. The obstruction label and an interface similarity do not establish a contravention; the complete section 28B test, scope, facts and evidence must be applied from 1 July 2027."},{"provision":"Dark-pattern research taxonomy","sourceIds":["gray-ontology-dark-patterns-2024"],"classification":"Editorial analysis","explanation":"The cited research sources support this working pattern within the obstruction family. It is editorial implementation guidance, not an Australian statutory category, regulator finding or legal safe harbour."}],"examples":[{"type":"Illustrative example","context":"Refund form loops after submission","scenario":"A fictional refund form accepts every field, then returns to the first screen with “Something went wrong” and no saved state or alternative route.","harm":"A customer may abandon a valid request after repeating work without a way to complete or recover."},{"type":"Illustrative example","context":"Cancellation confirmation changes no account state","scenario":"A fictional service shows “Cancellation complete” but returns the user to an active-plan dashboard and continues renewal without a receipt or status event.","harm":"The represented outcome is not reached, leaving the subscriber exposed to another charge."}],"problematicUi":{"label":"Submit refund request","copy":"Submit refund request The form loops to an empty first screen without identifying a fix. Order number Enter order number Refund reason Enter refund reason Requested amount Enter requested amount Try again","annotations":["Why this state matters: The route adds avoidable effort between the user’s stated intention and completion. In this order support example, the obstacle is: “The form loops to an empty first screen without identifying a fix.” Evidence should show whether the alternative remains usable and whether “Resume or contact support” reaches the represented state. A customer may abandon a valid request after repeating work without a way to complete or recover.","Review prompt: How many steps, waits and channel changes separate “Try again” from the completed order support outcome?"]},"improvedUi":{"label":"We could not submit the request","copy":"We could not submit the request Entered details are saved and a supported fallback is offered. Saved order number Enter saved order number Saved refund reason Enter saved refund reason Saved requested amount Enter saved requested amount Resume or contact support Purpose and refusal effect The form explains why “Resume or contact support” is requested and what happens if it is not used.","annotations":["Fairer design: Preserve entered data, explain the specific error and provide a tested fallback route with a reference number.","Review prompt: Which fields or permissions are required, what happens on refusal, and does the resulting state support this criterion: “The interface represents or reasonably implies that the outcome is available”?"]},"uiComparisons":[{"id":"dead-end-scenario-1","title":"Refund form loops after submission","context":"Order support","journeyStage":"Account Management","summary":"A fictional refund form accepts every field, then returns to the first screen with “Something went wrong” and no saved state or alternative route.","problematic":{"label":"Submit refund request","layout":"form","elements":[{"id":"problematic-1-heading","type":"heading","text":"Submit refund request"},{"id":"problematic-2-body","type":"text","text":"The form loops to an empty first screen without identifying a fix.","tone":"warning"},{"id":"problematic-3-input","type":"input","label":"Order number","placeholder":"Enter order number"},{"id":"problematic-4-input","type":"input","label":"Refund reason","placeholder":"Enter refund reason"},{"id":"problematic-5-input","type":"input","label":"Requested amount","placeholder":"Enter requested amount"},{"id":"problematic-6-button","type":"button","text":"Try again","emphasis":"primary"}],"annotations":[{"targetId":"problematic-2-body","text":"Why this state matters: The route adds avoidable effort between the user’s stated intention and completion. In this order support example, the obstacle is: “The form loops to an empty first screen without identifying a fix.” Evidence should show whether the alternative remains usable and whether “Resume or contact support” reaches the represented state. A customer may abandon a valid request after repeating work without a way to complete or recover."},{"targetId":"problematic-6-button","text":"Review prompt: How many steps, waits and channel changes separate “Try again” from the completed order support outcome?"}]},"neutral":{"label":"We could not submit the request","layout":"form","elements":[{"id":"neutral-1-heading","type":"heading","text":"We could not submit the request"},{"id":"neutral-2-body","type":"text","text":"Entered details are saved and a supported fallback is offered.","tone":"default"},{"id":"neutral-3-input","type":"input","label":"Saved order number","placeholder":"Enter saved order number"},{"id":"neutral-4-input","type":"input","label":"Saved refund reason","placeholder":"Enter saved refund reason"},{"id":"neutral-5-input","type":"input","label":"Saved requested amount","placeholder":"Enter saved requested amount"},{"id":"neutral-6-button","type":"button","text":"Resume or contact support","emphasis":"secondary"},{"id":"neutral-7-disclosure","type":"disclosure","summary":"Purpose and refusal effect","content":"The form explains why “Resume or contact support” is requested and what happens if it is not used.","open":true}],"annotations":[{"targetId":"neutral-2-body","text":"Fairer design: Preserve entered data, explain the specific error and provide a tested fallback route with a reference number."},{"targetId":"neutral-7-disclosure","text":"Review prompt: Which fields or permissions are required, what happens on refusal, and does the resulting state support this criterion: “The interface represents or reasonably implies that the outcome is available”?"}]},"whyItMatters":"The route adds avoidable effort between the user’s stated intention and completion. In this order support example, the obstacle is: “The form loops to an empty first screen without identifying a fix.” Evidence should show whether the alternative remains usable and whether “Resume or contact support” reaches the represented state. A customer may abandon a valid request after repeating work without a way to complete or recover.","fairDesignPrinciple":"Preserve entered data, explain the specific error and provide a tested fallback route with a reference number.","reviewPrompts":["How many steps, waits and channel changes separate “Try again” from the completed order support outcome?","Which fields or permissions are required, what happens on refusal, and does the resulting state support this criterion: “The interface represents or reasonably implies that the outcome is available”?","Measure the same task through the clearest available route: does the effort difference persist once “General outage affecting all paths” is accounted for?"],"altText":"Side-by-side order support interface showing “Submit refund request” and the clearer alternative “We could not submit the request”.","provenance":"Original hypothetical order support example created for this library; no real business, product or interface is depicted."},{"id":"dead-end-scenario-2","title":"Cancellation confirmation changes no account state","context":"Subscription account","journeyStage":"Cancellation","summary":"A fictional service shows “Cancellation complete” but returns the user to an active-plan dashboard and continues renewal without a receipt or status event.","problematic":{"label":"Cancellation complete","layout":"cancellation-flow","elements":[{"id":"problematic-1-heading","type":"heading","text":"Cancellation complete"},{"id":"problematic-2-body","type":"text","text":"The plan remains active and no confirmation record exists.","tone":"warning"},{"id":"problematic-3-step","type":"step","label":"Blocking step"},{"id":"problematic-4-step","type":"step","label":"Obscured outcome"}],"annotations":[{"targetId":"problematic-2-body","text":"Why this state matters: The route adds avoidable effort between the user’s stated intention and completion. In this subscription account example, the obstacle is: “The plan remains active and no confirmation record exists.” Evidence should show whether the alternative remains usable and whether “Download confirmation” reaches the represented state. The represented outcome is not reached, leaving the subscriber exposed to another charge."},{"targetId":"problematic-4-step","text":"Review prompt: How many steps, waits and channel changes separate “Back to account” from the completed subscription account outcome?"}]},"neutral":{"label":"Plan ends on 30 September","layout":"cancellation-flow","elements":[{"id":"neutral-1-heading","type":"heading","text":"Plan ends on 30 September"},{"id":"neutral-2-body","type":"text","text":"The account status, renewal setting and receipt all reflect the completed request.","tone":"default"},{"id":"neutral-3-step","type":"step","label":"Completion step"},{"id":"neutral-4-step","type":"step","label":"Recorded outcome"},{"id":"neutral-5-badge","type":"badge","text":"Request recorded: Download confirmation","tone":"default"}],"annotations":[{"targetId":"neutral-2-body","text":"Fairer design: Update the account state atomically, display the effective date and issue a durable receipt that support can verify."},{"targetId":"neutral-5-badge","text":"Review prompt: Count steps, waits, offers and channel changes through final confirmation; where does the route meet “Repeated execution cannot reach that outcome under controlled conditions”?"}]},"whyItMatters":"The route adds avoidable effort between the user’s stated intention and completion. In this subscription account example, the obstacle is: “The plan remains active and no confirmation record exists.” Evidence should show whether the alternative remains usable and whether “Download confirmation” reaches the represented state. The represented outcome is not reached, leaving the subscriber exposed to another charge.","fairDesignPrinciple":"Update the account state atomically, display the effective date and issue a durable receipt that support can verify.","reviewPrompts":["How many steps, waits and channel changes separate “Back to account” from the completed subscription account outcome?","Count steps, waits, offers and channel changes through final confirmation; where does the route meet “Repeated execution cannot reach that outcome under controlled conditions”?","Measure the same task through the clearest available route: does the effort difference persist once “validation error caused by invalid fixture input” is accounted for?"],"altText":"Side-by-side subscription account interface showing “Cancellation complete” and the clearer alternative “Plan ends on 30 September”.","provenance":"Original hypothetical subscription account example created for this library; no real business, product or interface is depicted."}],"fairAlternative":"Provide a functional completion route, preserve progress, and surface recoverable errors equally across options.","whyProblematic":"A consumer-favourable route cannot reach its represented outcome and instead loops, stalls or loses progress. A route represents that a request can complete but then loops, errors or changes no durable state, without a working recovery path or confirmation record. These harms describe a review risk, not an automatic legal conclusion. Australian section 28B commences on 1 July 2027 and requires its complete, context-specific test. Existing ACL provisions remain a separate current-law assessment.","contextFactors":["The interface represents or reasonably implies that the outcome is available.","Repeated execution cannot reach that outcome under controlled conditions.","A business-favoured route remains functional or the failure systematically burdens the alternative.","Boundary to test: General outage affecting all paths","Boundary to test: validation error caused by invalid fixture input","Boundary to test: clearly unavailable option"],"affectedTeams":["Product","Design","Engineering","Legal","Compliance"],"reviewQuestions":["How many steps, waits and channel changes separate “Try again” from the completed order support outcome?","Which fields or permissions are required, what happens on refusal, and does the resulting state support this criterion: “The interface represents or reasonably implies that the outcome is available”?","Measure the same task through the clearest available route: does the effort difference persist once “General outage affecting all paths” is accounted for?","How many steps, waits and channel changes separate “Back to account” from the completed subscription account outcome?","Count steps, waits, offers and channel changes through final confirmation; where does the route meet “Repeated execution cannot reach that outcome under controlled conditions”?","Measure the same task through the clearest available route: does the effort difference persist once “validation error caused by invalid fixture input” is accounted for?"],"evidence":["Annotated account management and cancellation screenshots at each responsive breakpoint","The complete state sequence before, during and after the consumer decision","Design-system component, content, default and configuration records for the reviewed release","Operational records substantiating price, availability, timing and eligibility claims","Usability, accessibility, reversal, complaint and support evidence relevant to consumer impact","A dated product and legal review record identifying evidence, uncertainties and release decisions"],"related":["account-deletion-obstruction","comparison-prevention","customer-support-obstruction","cancellation-friction"],"sourceIds":["gray-ontology-dark-patterns-2024","au-act-2026-64"],"altText":"Side-by-side order support interface showing “Submit refund request” and the clearer alternative “We could not submit the request”.","provenance":"Original hypothetical interface comparisons from the shared learning library, adapted to Australian-dollar context for this portal; no real business, product or interface is depicted.","author":"Flowlane","datePublished":"2026-08-10","dateModified":"2026-09-14","lastReviewed":"2026-09-14","changeNote":"Source comparison recorded and the current status restated."},{"title":"Cancellation friction","slug":"cancellation-friction","preferredName":"Cancellation friction","directAnswer":"From 1 July 2027, section 48F will require every supplied cancellation method for a covered consumer or small-business subscription to be easy to find, straightforward and limited to reasonably necessary steps. An online method is required where the subscriber entered online or the supplier offers online entry for the same kind of subscription. Section 28B may also apply to obstructed decisions or legal rights.","definition":"Ending an existing subscription, recurring service or permission is made difficult to find or complete through unnecessary steps or channel asymmetry. This is a design and research taxonomy for learning and evidence review, not a statutory offence label or an automatic finding that an interface is unlawful.","synonyms":["roach motel","click fatigue","hard to unsubscribe","online sign-up but phone-only exit","repeated retention offers","unnecessary identity checks","cancellation link buried","unclear completion state","hard-to-cancel subscription","obstructed exit","cancellation maze","save-flow friction","Hard to cancel or opt out"],"category":"Obstruction","family":"Obstruction","journeyStages":["Cancellation"],"jurisdiction":"Australia","status":"Commences 1 July 2027","howItWorks":"Ending an existing subscription, recurring service or permission is made difficult to find or complete through unnecessary steps or channel asymmetry. Ending or refusing a service requires materially more steps, time or channel changes than entry, increasing the cost of completing an already stated exit intention.","warningSigns":["The user is trying to terminate or opt out of an existing relationship.","The route is difficult to find, non-straightforward or includes steps beyond those reasonably necessary.","Completion is verified through the resulting account or subscription state."],"harms":["Channel switching and avoidable delay may cause extra charges or prevent completion.","Repeated friction can delay an intended exit and increase the chance of another billing cycle."],"legitimateUses":["Reasonable authentication and fraud controls","mandatory consequence disclosure that does not impede completion","declining an offer before enrolment"],"legalBasis":[{"provision":"ACL section 48F(1), inserted by the 2026 Act","sourceIds":["au-act-2026-64"],"classification":"Express rule","explanation":"Requires a way to end, with every supplied way easy to find, straightforward and limited to reasonably necessary steps to end and protect the subscriber's interests."},{"provision":"ACL section 48F(2), inserted by the 2026 Act","sourceIds":["au-act-2026-64"],"classification":"Express rule","explanation":"Requires at least one online exit where entry occurred online or the supplier offers online entry for the same kind of goods or services."},{"provision":"ACL sections 48G to 48H, inserted by the 2026 Act","sourceIds":["au-act-2026-64"],"classification":"Express rule","explanation":"Define consumer and qualifying standard-form small-business subscription scope."},{"provision":"ACL section 28B(6)(a) and (d), inserted by the 2026 Act","sourceIds":["au-act-2026-64"],"classification":"Possible risk indicator","explanation":"Provides non-exhaustive examples concerning legal rights/remedies and obstruction."}],"examples":[{"type":"Illustrative example","context":"Online signup requires telephone cancellation","scenario":"A fictional streaming service accepts signup in three online steps but requires a weekday telephone call, repeated identity questions and a retention interview to cancel.","harm":"Channel switching and avoidable delay may cause extra charges or prevent completion."},{"type":"Illustrative example","context":"Five save offers block the final exit","scenario":"A fictional account shows a new discount, pause offer or survey after every click on “Cancel”, and the final confirmation appears only after five refusals.","harm":"Repeated friction can delay an intended exit and increase the chance of another billing cycle."},{"type":"Illustrative example","context":"Online sign-up, telephone-only exit","scenario":"A streaming service accepts sign-up in three online steps but requires a weekday telephone call, repeated identity questions and a retention interview to cancel.","harm":"Section 48F's online trigger would apply from commencement, and the extra steps may fail the straightforward and reasonably-necessary standards."},{"type":"Illustrative example","context":"Cancellation link loops to retention offers","scenario":"Each click on 'cancel plan' opens a new discount screen; the final confirmation appears only after five declines and uses a visually dominant 'keep plan' control.","harm":"The repeated save flow may make cancellation hard to find or non-straightforward and may also unreasonably obstruct the subscriber's decision."},{"type":"Enforcement example","context":"Microsoft 365 subscription proceedings","scenario":"The ACCC alleged that a lower-cost option was disclosed only during cancellation. Procedural posture: Proceedings and allegations only in the reviewed source; no liability finding should be implied.","harm":"This is verified current-ACL context, not enforcement of provisions commencing in 2027.","sourceIds":["au-accc-microsoft-2025"]},{"type":"Enforcement example","context":"HelloFresh and Youfoodz subscription proceedings","scenario":"The ACCC alleged subscription sign-up and cancellation conduct under existing law. Procedural posture: Proceedings and allegations only in the reviewed source; no liability finding should be implied.","harm":"This is verified current-ACL context, not enforcement of provisions commencing in 2027.","sourceIds":["au-accc-hellofresh-youfoodz-2025"]}],"problematicUi":{"label":"Call us to discuss your plan","copy":"Call us to discuss your plan The online account offers no completed cancellation route. Blocking step Obscured outcome","annotations":["Why this state matters: The route adds avoidable effort between the user’s stated intention and completion. In this streaming subscription example, the obstacle is: “The online account offers no completed cancellation route.” Evidence should show whether the alternative remains usable and whether “Confirm end date” reaches the represented state. Channel switching and avoidable delay may cause extra charges or prevent completion.","Review prompt: How many steps, waits and channel changes separate “Weekdays 9 to 16 only” from the completed streaming subscription outcome?"]},"improvedUi":{"label":"End subscription online","copy":"End subscription online Necessary verification, effective date and confirmation are handled in one route. Completion step Recorded outcome Request recorded: Confirm end date","annotations":["Fairer design: Provide a findable online route with proportionate verification and a durable cancellation receipt.","Review prompt: Count steps, waits, offers and channel changes through final confirmation; where does the route meet “The user is trying to terminate or opt out of an existing relationship”?"]},"uiComparisons":[{"id":"hard-to-cancel-or-opt-out-scenario-1","title":"Online signup requires telephone cancellation","context":"Streaming subscription","journeyStage":"Cancellation","summary":"A fictional streaming service accepts signup in three online steps but requires a weekday telephone call, repeated identity questions and a retention interview to cancel.","problematic":{"label":"Call us to discuss your plan","layout":"cancellation-flow","elements":[{"id":"problematic-1-heading","type":"heading","text":"Call us to discuss your plan"},{"id":"problematic-2-body","type":"text","text":"The online account offers no completed cancellation route.","tone":"warning"},{"id":"problematic-3-step","type":"step","label":"Blocking step"},{"id":"problematic-4-step","type":"step","label":"Obscured outcome"}],"annotations":[{"targetId":"problematic-2-body","text":"Why this state matters: The route adds avoidable effort between the user’s stated intention and completion. In this streaming subscription example, the obstacle is: “The online account offers no completed cancellation route.” Evidence should show whether the alternative remains usable and whether “Confirm end date” reaches the represented state. Channel switching and avoidable delay may cause extra charges or prevent completion."},{"targetId":"problematic-4-step","text":"Review prompt: How many steps, waits and channel changes separate “Weekdays 9 to 16 only” from the completed streaming subscription outcome?"}]},"neutral":{"label":"End subscription online","layout":"cancellation-flow","elements":[{"id":"neutral-1-heading","type":"heading","text":"End subscription online"},{"id":"neutral-2-body","type":"text","text":"Necessary verification, effective date and confirmation are handled in one route.","tone":"default"},{"id":"neutral-3-step","type":"step","label":"Completion step"},{"id":"neutral-4-step","type":"step","label":"Recorded outcome"},{"id":"neutral-5-badge","type":"badge","text":"Request recorded: Confirm end date","tone":"default"}],"annotations":[{"targetId":"neutral-2-body","text":"Fairer design: Provide a findable online route with proportionate verification and a durable cancellation receipt."},{"targetId":"neutral-5-badge","text":"Review prompt: Count steps, waits, offers and channel changes through final confirmation; where does the route meet “The user is trying to terminate or opt out of an existing relationship”?"}]},"whyItMatters":"The route adds avoidable effort between the user’s stated intention and completion. In this streaming subscription example, the obstacle is: “The online account offers no completed cancellation route.” Evidence should show whether the alternative remains usable and whether “Confirm end date” reaches the represented state. Channel switching and avoidable delay may cause extra charges or prevent completion.","fairDesignPrinciple":"Provide a findable online route with proportionate verification and a durable cancellation receipt.","reviewPrompts":["How many steps, waits and channel changes separate “Weekdays 9 to 16 only” from the completed streaming subscription outcome?","Count steps, waits, offers and channel changes through final confirmation; where does the route meet “The user is trying to terminate or opt out of an existing relationship”?","Measure the same task through the clearest available route: does the effort difference persist once “Reasonable authentication and fraud controls” is accounted for?"],"altText":"Side-by-side streaming subscription interface showing “Call us to discuss your plan” and the clearer alternative “End subscription online”.","provenance":"Original hypothetical streaming subscription example created for this library; no real business, product or interface is depicted."},{"id":"hard-to-cancel-or-opt-out-scenario-2","title":"Five save offers block the final exit","context":"Meal-plan account","journeyStage":"Cancellation","summary":"A fictional account shows a new discount, pause offer or survey after every click on “Cancel”, and the final confirmation appears only after five refusals.","problematic":{"label":"Before you go","layout":"cancellation-flow","elements":[{"id":"problematic-1-heading","type":"heading","text":"Before you go"},{"id":"problematic-2-body","type":"text","text":"Five sequential retention steps stand between request and confirmation.","tone":"warning"},{"id":"problematic-3-step","type":"step","label":"Blocking step"},{"id":"problematic-4-step","type":"step","label":"Obscured outcome"}],"annotations":[{"targetId":"problematic-2-body","text":"Why this state matters: The route adds avoidable effort between the user’s stated intention and completion. In this meal-plan account example, the obstacle is: “Five sequential retention steps stand between request and confirmation.” Evidence should show whether the alternative remains usable and whether “End deliveries” reaches the represented state. Repeated friction can delay an intended exit and increase the chance of another billing cycle."},{"targetId":"problematic-4-step","text":"Review prompt: How many steps, waits and channel changes separate “See another offer” from the completed meal-plan account outcome?"}]},"neutral":{"label":"Confirm cancellation","layout":"cancellation-flow","elements":[{"id":"neutral-1-heading","type":"heading","text":"Confirm cancellation"},{"id":"neutral-2-body","type":"text","text":"One optional alternative sits beside a direct confirmation action.","tone":"default"},{"id":"neutral-3-step","type":"step","label":"Completion step"},{"id":"neutral-4-step","type":"step","label":"Recorded outcome"},{"id":"neutral-5-badge","type":"badge","text":"Request recorded: End deliveries","tone":"default"}],"annotations":[{"targetId":"neutral-2-body","text":"Fairer design: Keep optional save offers non-blocking and provide a stable direct path to confirmation."},{"targetId":"neutral-5-badge","text":"Review prompt: Count steps, waits, offers and channel changes through final confirmation; where does the route meet “The route is difficult to find, non-straightforward or includes steps beyond those reasonably necessary”?"}]},"whyItMatters":"The route adds avoidable effort between the user’s stated intention and completion. In this meal-plan account example, the obstacle is: “Five sequential retention steps stand between request and confirmation.” Evidence should show whether the alternative remains usable and whether “End deliveries” reaches the represented state. Repeated friction can delay an intended exit and increase the chance of another billing cycle.","fairDesignPrinciple":"Keep optional save offers non-blocking and provide a stable direct path to confirmation.","reviewPrompts":["How many steps, waits and channel changes separate “See another offer” from the completed meal-plan account outcome?","Count steps, waits, offers and channel changes through final confirmation; where does the route meet “The route is difficult to find, non-straightforward or includes steps beyond those reasonably necessary”?","Measure the same task through the clearest available route: does the effort difference persist once “mandatory consequence disclosure that does not impede completion” is accounted for?"],"altText":"Side-by-side meal-plan account interface showing “Before you go” and the clearer alternative “Confirm cancellation”.","provenance":"Original hypothetical meal-plan account example created for this library; no real business, product or interface is depicted."}],"fairAlternative":"Provide an easy-to-find, direct exit path with only necessary verification and clear completion confirmation.","whyProblematic":"Ending an existing subscription, recurring service or permission is made difficult to find or complete through unnecessary steps or channel asymmetry. Ending or refusing a service requires materially more steps, time or channel changes than entry, increasing the cost of completing an already stated exit intention. Section 48F establishes an affirmative exit-method standard for subscription contracts that meet section 48G's consumer or small-business requirement. Section 28B(6)(a) and (d) also identify impeding legal rights or remedies and unreasonable obstruction in a decision environment as conduct that may satisfy the general prohibition. Existing misleading-conduct and contract rules can apply now. Current ACCC proceedings about cancellation must be described by their actual legal basis and procedural posture, not as enforcement of section 48F. Regulations may prescribe exceptions to section 48F. None had been identified by the review date.","contextFactors":["The user is trying to terminate or opt out of an existing relationship.","The route is difficult to find, non-straightforward or includes steps beyond those reasonably necessary.","Completion is verified through the resulting account or subscription state.","Boundary to test: Reasonable authentication and fraud controls","Boundary to test: mandatory consequence disclosure that does not impede completion","Boundary to test: declining an offer before enrolment","Does the contract meet the section 48B subscription definition and section 48G consumer or small-business requirement?","Can the exit control be found from normal account navigation and search?","How many steps are required compared with entry?","Which ending function or subscriber interest does each step protect, and why is that step reasonably necessary?","Is an online exit supplied whenever either statutory online trigger applies?","Do save offers delay, obscure or reverse the requested cancellation?","Can a person using assistive technology complete the exit?"],"affectedTeams":["Product","Design","Engineering","Customer Support","Retention","Billing","Legal","Security"],"reviewQuestions":["How many steps, waits and channel changes separate “Weekdays 9 to 16 only” from the completed streaming subscription outcome?","Count steps, waits, offers and channel changes through final confirmation; where does the route meet “The user is trying to terminate or opt out of an existing relationship”?","Measure the same task through the clearest available route: does the effort difference persist once “Reasonable authentication and fraud controls” is accounted for?","How many steps, waits and channel changes separate “See another offer” from the completed meal-plan account outcome?","Count steps, waits, offers and channel changes through final confirmation; where does the route meet “The route is difficult to find, non-straightforward or includes steps beyond those reasonably necessary”?","Measure the same task through the clearest available route: does the effort difference persist once “mandatory consequence disclosure that does not impede completion” is accounted for?","Can a subscriber locate cancellation without an external search or support contact?","Does either online-entry trigger apply to this kind of subscription?","What purpose supports every screen, field and channel switch?","Does accepting or declining a save offer preserve the cancellation request?","Is cancellation complete before any avoidable additional billing event?","Are the exit, end date and final charge confirmed durably?","Have prescribed exceptions been rechecked?"],"evidence":["entry-versus-exit journey comparison","step-level necessity and security rationale","responsive and accessibility test recordings","cancellation completion and failure logs","confirmation templates and delivery logs","retention-script approvals","complaints, chargebacks and cancellation-time data","regulation recheck record","Annotated cancellation screenshots at each responsive breakpoint","The complete state sequence before, during and after the consumer decision","Design-system component, content, default and configuration records for the reviewed release","Operational records substantiating price, availability, timing and eligibility claims","Usability, accessibility, reversal, complaint and support evidence relevant to consumer impact","A dated product and legal review record identifying evidence, uncertainties and release decisions"],"related":["account-deletion-obstruction","comparison-prevention","customer-support-obstruction","dead-end"],"sourceIds":["oecd-dark-commercial-patterns-2022","au-act-2026-64","au-acl-2010","au-accc-microsoft-2025","au-accc-hellofresh-youfoodz-2025","au-accc-priorities-2026"],"altText":"Side-by-side streaming subscription interface showing “Call us to discuss your plan” and the clearer alternative “End subscription online”.","provenance":"Original hypothetical interface comparisons from the shared learning library, adapted to Australian-dollar context for this portal; no real business, product or interface is depicted.","author":"Flowlane","datePublished":"2026-08-09","dateModified":"2026-09-14","lastReviewed":"2026-09-14","changeNote":"Source comparison recorded and the current status restated."},{"title":"Intermediate currency","slug":"intermediate-currency","preferredName":"Intermediate currency","directAnswer":"Intermediate currency is a working label for this design mechanism: A proprietary currency makes the real monetary cost or remaining value unnecessarily hard to understand. This is editorial implementation guidance for Australian journeys, not a finding of unlawfulness. From 1 July 2027, a similar interface is relevant to ACL section 28B only if the complete consumer-connection, manipulation or unreasonable-distortion and actual-or-likely-detriment test is met. Current ACL rules require a separate assessment.","definition":"A proprietary currency makes the real monetary cost or remaining value unnecessarily hard to understand. This is a design and research taxonomy for learning and evidence review, not a statutory offence label or an automatic finding that an interface is unlawful.","synonyms":["virtual currency obfuscation","token pricing","non-round conversion bundles","multiple virtual currencies","real-money equivalent hidden","unused remainder engineered"],"category":"Obstruction","family":"Obstruction","journeyStages":["Checkout"],"jurisdiction":"Australia","status":"Editorial implementation guidance","howItWorks":"A proprietary currency makes the real monetary cost or remaining value unnecessarily hard to understand. A proprietary unit separates the displayed item cost from real money and bundle constraints, obscuring both the required spend and residual value.","warningSigns":["The user exchanges real value for a proprietary unit or spends that unit.","The current real-money equivalent is not shown clearly at the purchase decision.","Conversion structure materially impairs cost comprehension or creates unavoidable remainder."],"harms":["Players may struggle to understand the real cost and must buy more currency than the item requires.","The customer may spend more than the service price and retain value that is difficult to use or recover."],"legitimateUses":["Transparent one-to-one or prominently converted loyalty points","currency conversion required by international payment with total displayed","non-purchasable game score"],"legalBasis":[{"provision":"ACL section 28B, inserted by the 2026 Act","sourceIds":["au-act-2026-64"],"classification":"Possible risk indicator","explanation":"In checkout journeys, the intermediate currency mechanism may warrant review where it manipulates a consumer or unreasonably distorts the decision environment and causes, or is likely to cause, detriment. The obstruction label and an interface similarity do not establish a contravention; the complete section 28B test, scope, facts and evidence must be applied from 1 July 2027."},{"provision":"Dark-pattern research taxonomy","sourceIds":["oecd-dark-commercial-patterns-2022"],"classification":"Editorial analysis","explanation":"The cited research sources support this working pattern within the obstruction family. It is editorial implementation guidance, not an Australian statutory category, regulator finding or legal safe harbour."}],"examples":[{"type":"Illustrative example","context":"Gem bundle hides an item’s real-money cost","scenario":"A fictional game prices an item at 1,350 gems but sells gems only in uneven bundles, with no Australian-dollar equivalent near the purchase action.","harm":"Players may struggle to understand the real cost and must buy more currency than the item requires."},{"type":"Illustrative example","context":"Unused tokens remain after a service booking","scenario":"A fictional marketplace sells 100 tokens for $10 while a booking costs 84 tokens and no service costs a multiple that uses the remaining balance.","harm":"The customer may spend more than the service price and retain value that is difficult to use or recover."}],"problematicUi":{"label":"Legendary item · 1,350 gems","copy":"Legendary item · 1,350 gems Gem bundles obscure that the smallest sufficient purchase costs $19.99. Buy more gems Review $19.99 bundle","annotations":["Why this state matters: The route adds avoidable effort between the user’s stated intention and completion. In this in-game store example, the obstacle is: “Gem bundles obscure that the smallest sufficient purchase costs $19.99.” Evidence should show whether the alternative remains usable and whether “Review $19.99 bundle” reaches the represented state. Players may struggle to understand the real cost and must buy more currency than the item requires.","Review prompt: How many steps, waits and channel changes separate “Buy more gems” from the completed in-game store outcome?"]},"improvedUi":{"label":"Legendary item · 1,350 gems ($13.50 value)","copy":"Legendary item · 1,350 gems ($13.50 value) Balance, shortfall and actual bundle cost are visible before commitment. Amount affected $19.99 Review $19.99 bundle Buy more gems Payable total and selected items The summary shows the line items and total before “Review $19.99 bundle” is activated.","annotations":["Fairer design: Show the real-money equivalent, available balance and exact currency shortfall before purchase.","Review prompt: Compare the basket before and after the action, including total and line items; does the mutation satisfy “The user exchanges real value for a proprietary unit or spends that unit”?"]},"uiComparisons":[{"id":"intermediate-currency-scenario-1","title":"Gem bundle hides an item’s real-money cost","context":"In-game store","journeyStage":"Checkout","summary":"A fictional game prices an item at 1,350 gems but sells gems only in uneven bundles, with no Australian-dollar equivalent near the purchase action.","problematic":{"label":"Legendary item · 1,350 gems","layout":"checkout-summary","elements":[{"id":"problematic-1-heading","type":"heading","text":"Legendary item · 1,350 gems"},{"id":"problematic-2-body","type":"text","text":"Gem bundles obscure that the smallest sufficient purchase costs $19.99.","tone":"warning"},{"id":"problematic-3-button","type":"button","text":"Buy more gems","emphasis":"primary"},{"id":"problematic-4-link","type":"link","text":"Review $19.99 bundle","emphasis":"subtle"}],"annotations":[{"targetId":"problematic-2-body","text":"Why this state matters: The route adds avoidable effort between the user’s stated intention and completion. In this in-game store example, the obstacle is: “Gem bundles obscure that the smallest sufficient purchase costs $19.99.” Evidence should show whether the alternative remains usable and whether “Review $19.99 bundle” reaches the represented state. Players may struggle to understand the real cost and must buy more currency than the item requires."},{"targetId":"problematic-4-link","text":"Review prompt: How many steps, waits and channel changes separate “Buy more gems” from the completed in-game store outcome?"}]},"neutral":{"label":"Legendary item · 1,350 gems ($13.50 value)","layout":"checkout-summary","elements":[{"id":"neutral-1-heading","type":"heading","text":"Legendary item · 1,350 gems ($13.50 value)"},{"id":"neutral-2-body","type":"text","text":"Balance, shortfall and actual bundle cost are visible before commitment.","tone":"default"},{"id":"neutral-3-price","type":"price","label":"Amount affected","amount":"$19.99"},{"id":"neutral-4-button","type":"button","text":"Review $19.99 bundle","emphasis":"secondary"},{"id":"neutral-5-link","type":"link","text":"Buy more gems","emphasis":"default"},{"id":"neutral-6-disclosure","type":"disclosure","summary":"Payable total and selected items","content":"The summary shows the line items and total before “Review $19.99 bundle” is activated.","open":true}],"annotations":[{"targetId":"neutral-2-body","text":"Fairer design: Show the real-money equivalent, available balance and exact currency shortfall before purchase."},{"targetId":"neutral-6-disclosure","text":"Review prompt: Compare the basket before and after the action, including total and line items; does the mutation satisfy “The user exchanges real value for a proprietary unit or spends that unit”?"}]},"whyItMatters":"The route adds avoidable effort between the user’s stated intention and completion. In this in-game store example, the obstacle is: “Gem bundles obscure that the smallest sufficient purchase costs $19.99.” Evidence should show whether the alternative remains usable and whether “Review $19.99 bundle” reaches the represented state. Players may struggle to understand the real cost and must buy more currency than the item requires.","fairDesignPrinciple":"Show the real-money equivalent, available balance and exact currency shortfall before purchase.","reviewPrompts":["How many steps, waits and channel changes separate “Buy more gems” from the completed in-game store outcome?","Compare the basket before and after the action, including total and line items; does the mutation satisfy “The user exchanges real value for a proprietary unit or spends that unit”?","Measure the same task through the clearest available route: does the effort difference persist once “Transparent one-to-one or prominently converted loyalty points” is accounted for?"],"altText":"Side-by-side in-game store interface showing “Legendary item · 1,350 gems” and the clearer alternative “Legendary item · 1,350 gems ($13.50 value)”.","provenance":"Original hypothetical in-game store example created for this library; no real business, product or interface is depicted."},{"id":"intermediate-currency-scenario-2","title":"Unused tokens remain after a service booking","context":"Creator marketplace","journeyStage":"Checkout","summary":"A fictional marketplace sells 100 tokens for $10 while a booking costs 84 tokens and no service costs a multiple that uses the remaining balance.","problematic":{"label":"Book for 84 tokens","layout":"pricing-card","elements":[{"id":"problematic-1-heading","type":"heading","text":"Book for 84 tokens"},{"id":"problematic-2-body","type":"text","text":"Only a 100-token bundle can be purchased and the $ value is remote.","tone":"warning"},{"id":"problematic-3-button","type":"button","text":"Buy 100 tokens","emphasis":"primary"},{"id":"problematic-4-link","type":"link","text":"Pay exact amount","emphasis":"subtle"}],"annotations":[{"targetId":"problematic-2-body","text":"Why this state matters: The route adds avoidable effort between the user’s stated intention and completion. In this creator marketplace example, the obstacle is: “Only a 100-token bundle can be purchased and the $ value is remote.” Evidence should show whether the alternative remains usable and whether “Pay exact amount” reaches the represented state. The customer may spend more than the service price and retain value that is difficult to use or recover."},{"targetId":"problematic-4-link","text":"Review prompt: How many steps, waits and channel changes separate “Buy 100 tokens” from the completed creator marketplace outcome?"}]},"neutral":{"label":"Book for $8.40","layout":"pricing-card","elements":[{"id":"neutral-1-heading","type":"heading","text":"Book for $8.40"},{"id":"neutral-2-body","type":"text","text":"Direct payment is available; token use shows conversion and remaining balance.","tone":"default"},{"id":"neutral-3-button","type":"button","text":"Pay exact amount","emphasis":"secondary"},{"id":"neutral-4-link","type":"link","text":"Buy 100 tokens","emphasis":"default"},{"id":"neutral-5-disclosure","type":"disclosure","summary":"Price, period and commitment","content":"The price and material terms associated with “Pay exact amount” remain beside this choice.","open":true}],"annotations":[{"targetId":"neutral-2-body","text":"Fairer design: Allow direct currency payment or explain conversion, residual value and refund options beside the token offer."},{"targetId":"neutral-5-disclosure","text":"Review prompt: Place the compared prices, billing periods and material terms on one evidence sheet; where does it support “The current real-money equivalent is not shown clearly at the purchase decision”?"}]},"whyItMatters":"The route adds avoidable effort between the user’s stated intention and completion. In this creator marketplace example, the obstacle is: “Only a 100-token bundle can be purchased and the $ value is remote.” Evidence should show whether the alternative remains usable and whether “Pay exact amount” reaches the represented state. The customer may spend more than the service price and retain value that is difficult to use or recover.","fairDesignPrinciple":"Allow direct currency payment or explain conversion, residual value and refund options beside the token offer.","reviewPrompts":["How many steps, waits and channel changes separate “Buy 100 tokens” from the completed creator marketplace outcome?","Place the compared prices, billing periods and material terms on one evidence sheet; where does it support “The current real-money equivalent is not shown clearly at the purchase decision”?","Measure the same task through the clearest available route: does the effort difference persist once “currency conversion required by international payment with total displayed” is accounted for?"],"altText":"Side-by-side creator marketplace interface showing “Book for 84 tokens” and the clearer alternative “Book for $8.40”.","provenance":"Original hypothetical creator marketplace example created for this library; no real business, product or interface is depicted."}],"fairAlternative":"Show the current real-money equivalent and total before commitment and avoid conversion structures that obscure or strand value.","whyProblematic":"A proprietary currency makes the real monetary cost or remaining value unnecessarily hard to understand. A proprietary unit separates the displayed item cost from real money and bundle constraints, obscuring both the required spend and residual value. These harms describe a review risk, not an automatic legal conclusion. Australian section 28B commences on 1 July 2027 and requires its complete, context-specific test. Existing ACL provisions remain a separate current-law assessment.","contextFactors":["The user exchanges real value for a proprietary unit or spends that unit.","The current real-money equivalent is not shown clearly at the purchase decision.","Conversion structure materially impairs cost comprehension or creates unavoidable remainder.","Boundary to test: Transparent one-to-one or prominently converted loyalty points","Boundary to test: currency conversion required by international payment with total displayed","Boundary to test: non-purchasable game score"],"affectedTeams":["Product","Design","Engineering","Legal","Compliance"],"reviewQuestions":["How many steps, waits and channel changes separate “Buy more gems” from the completed in-game store outcome?","Compare the basket before and after the action, including total and line items; does the mutation satisfy “The user exchanges real value for a proprietary unit or spends that unit”?","Measure the same task through the clearest available route: does the effort difference persist once “Transparent one-to-one or prominently converted loyalty points” is accounted for?","How many steps, waits and channel changes separate “Buy 100 tokens” from the completed creator marketplace outcome?","Place the compared prices, billing periods and material terms on one evidence sheet; where does it support “The current real-money equivalent is not shown clearly at the purchase decision”?","Measure the same task through the clearest available route: does the effort difference persist once “currency conversion required by international payment with total displayed” is accounted for?"],"evidence":["Annotated checkout screenshots at each responsive breakpoint","The complete state sequence before, during and after the consumer decision","Design-system component, content, default and configuration records for the reviewed release","Operational records substantiating price, availability, timing and eligibility claims","Usability, accessibility, reversal, complaint and support evidence relevant to consumer impact","A dated product and legal review record identifying evidence, uncertainties and release decisions"],"related":["account-deletion-obstruction","comparison-prevention","customer-support-obstruction","dead-end"],"sourceIds":["oecd-dark-commercial-patterns-2022","au-act-2026-64"],"altText":"Side-by-side in-game store interface showing “Legendary item · 1,350 gems” and the clearer alternative “Legendary item · 1,350 gems ($13.50 value)”.","provenance":"Original hypothetical interface comparisons from the shared learning library, adapted to Australian-dollar context for this portal; no real business, product or interface is depicted.","author":"Flowlane","datePublished":"2026-08-10","dateModified":"2026-09-14","lastReviewed":"2026-09-14","changeNote":"Source comparison recorded and the current status restated."},{"title":"Obstructed alternative","slug":"obstructed-alternative","preferredName":"Obstructed alternative","directAnswer":"Obstructed alternative is a working label for this design mechanism: A relevant alternative within the current decision is hidden, blocked or made materially harder than the business-favoured action. This is editorial implementation guidance for Australian journeys, not a finding of unlawfulness. From 1 July 2027, a similar interface is relevant to ACL section 28B only if the complete consumer-connection, manipulation or unreasonable-distortion and actual-or-likely-detriment test is met. Current ACL rules require a separate assessment.","definition":"A relevant alternative within the current decision is hidden, blocked or made materially harder than the business-favoured action. This is a design and research taxonomy for learning and evidence review, not a statutory offence label or an automatic finding that an interface is unlawful.","synonyms":["single-screen obstruction","hidden alternative","asymmetric choice path","decline behind manage options","secondary action outside viewport","alternative covered or disabled","accept directly but reject through extra screen"],"category":"Obstruction","family":"Obstruction","journeyStages":["Checkout","Signup"],"jurisdiction":"Australia","status":"Editorial implementation guidance","howItWorks":"A relevant alternative within the current decision is hidden, blocked or made materially harder than the business-favoured action. A real alternative remains technically present but is buried, de-emphasised or placed behind extra discovery effort compared with the favoured route.","warningSigns":["The options address the same decision.","The alternative is available in principle but requires additional discovery, interaction or recovery from obstruction.","The asymmetry is not necessary for security, safety or the user's stated task."],"harms":["A viable alternative becomes materially harder to discover than the business-preferred account route.","The asymmetric path can deter a user from reaching a genuine lower-data choice."],"legitimateUses":["Different actions with genuinely different complexity","exit from an existing subscription, which is classified as hard to cancel","alternative unavailable for a disclosed eligibility reason"],"legalBasis":[{"provision":"ACL section 28B, inserted by the 2026 Act","sourceIds":["au-act-2026-64"],"classification":"Possible risk indicator","explanation":"In checkout and signup journeys, the obstructed alternative mechanism may warrant review where it manipulates a consumer or unreasonably distorts the decision environment and causes, or is likely to cause, detriment. The obstruction label and an interface similarity do not establish a contravention; the complete section 28B test, scope, facts and evidence must be applied from 1 July 2027."},{"provision":"Dark-pattern research taxonomy","sourceIds":["oecd-dark-commercial-patterns-2022"],"classification":"Editorial analysis","explanation":"The cited research sources support this working pattern within the obstruction family. It is editorial implementation guidance, not an Australian statutory category, regulator finding or legal safe harbour."}],"examples":[{"type":"Illustrative example","context":"Guest checkout hidden behind account copy","scenario":"A fictional shop displays account creation as the only button and places guest checkout inside a collapsed paragraph titled “Other information”.","harm":"A viable alternative becomes materially harder to discover than the business-preferred account route."},{"type":"Illustrative example","context":"Rejecting optional tracking needs multiple panels","scenario":"A fictional consent layer accepts optional tracking in one click but requires opening three panels and disabling twelve switches to refuse it.","harm":"The asymmetric path can deter a user from reaching a genuine lower-data choice."}],"problematicUi":{"label":"Save time with an account","copy":"Save time with an account The visible action creates an account; the guest path is buried in unrelated copy. Create account Continue as guest","annotations":["Why this state matters: The route adds avoidable effort between the user’s stated intention and completion. In this retail basket example, the obstacle is: “The visible action creates an account; the guest path is buried in unrelated copy.” Evidence should show whether the alternative remains usable and whether “Continue as guest” reaches the represented state. A viable alternative becomes materially harder to discover than the business-preferred account route.","Review prompt: How many steps, waits and channel changes separate “Create account” from the completed retail basket outcome?"]},"improvedUi":{"label":"Choose a checkout route","copy":"Choose a checkout route Guest checkout and optional account creation appear together. Continue as guest Create account Choice consequences The consequence of selecting “Continue as guest” is displayed beside the option.","annotations":["Fairer design: Present guest and account routes together with clear consequences and comparable interaction effort.","Review prompt: Capture every peer option, its default state and visual prominence; do those states support “The options address the same decision”?"]},"uiComparisons":[{"id":"obstructed-alternative-scenario-1","title":"Guest checkout hidden behind account copy","context":"Retail basket","journeyStage":"Checkout","summary":"A fictional shop displays account creation as the only button and places guest checkout inside a collapsed paragraph titled “Other information”.","problematic":{"label":"Save time with an account","layout":"choice-list","elements":[{"id":"problematic-1-heading","type":"heading","text":"Save time with an account"},{"id":"problematic-2-body","type":"text","text":"The visible action creates an account; the guest path is buried in unrelated copy.","tone":"warning"},{"id":"problematic-3-radio","type":"radio","label":"Create account","checked":true},{"id":"problematic-4-radio","type":"radio","label":"Continue as guest","checked":false}],"annotations":[{"targetId":"problematic-2-body","text":"Why this state matters: The route adds avoidable effort between the user’s stated intention and completion. In this retail basket example, the obstacle is: “The visible action creates an account; the guest path is buried in unrelated copy.” Evidence should show whether the alternative remains usable and whether “Continue as guest” reaches the represented state. A viable alternative becomes materially harder to discover than the business-preferred account route."},{"targetId":"problematic-4-radio","text":"Review prompt: How many steps, waits and channel changes separate “Create account” from the completed retail basket outcome?"}]},"neutral":{"label":"Choose a checkout route","layout":"choice-list","elements":[{"id":"neutral-1-heading","type":"heading","text":"Choose a checkout route"},{"id":"neutral-2-body","type":"text","text":"Guest checkout and optional account creation appear together.","tone":"default"},{"id":"neutral-3-radio","type":"radio","label":"Continue as guest","checked":false},{"id":"neutral-4-radio","type":"radio","label":"Create account","checked":false},{"id":"neutral-5-disclosure","type":"disclosure","summary":"Choice consequences","content":"The consequence of selecting “Continue as guest” is displayed beside the option.","open":true}],"annotations":[{"targetId":"neutral-2-body","text":"Fairer design: Present guest and account routes together with clear consequences and comparable interaction effort."},{"targetId":"neutral-5-disclosure","text":"Review prompt: Capture every peer option, its default state and visual prominence; do those states support “The options address the same decision”?"}]},"whyItMatters":"The route adds avoidable effort between the user’s stated intention and completion. In this retail basket example, the obstacle is: “The visible action creates an account; the guest path is buried in unrelated copy.” Evidence should show whether the alternative remains usable and whether “Continue as guest” reaches the represented state. A viable alternative becomes materially harder to discover than the business-preferred account route.","fairDesignPrinciple":"Present guest and account routes together with clear consequences and comparable interaction effort.","reviewPrompts":["How many steps, waits and channel changes separate “Create account” from the completed retail basket outcome?","Capture every peer option, its default state and visual prominence; do those states support “The options address the same decision”?","Measure the same task through the clearest available route: does the effort difference persist once “Different actions with genuinely different complexity” is accounted for?"],"altText":"Side-by-side retail basket interface showing “Save time with an account” and the clearer alternative “Choose a checkout route”.","provenance":"Original hypothetical retail basket example created for this library; no real business, product or interface is depicted."},{"id":"obstructed-alternative-scenario-2","title":"Rejecting optional tracking needs multiple panels","context":"Cookie preferences","journeyStage":"Signup","summary":"A fictional consent layer accepts optional tracking in one click but requires opening three panels and disabling twelve switches to refuse it.","problematic":{"label":"Your privacy options","layout":"choice-list","elements":[{"id":"problematic-1-heading","type":"heading","text":"Your privacy options"},{"id":"problematic-2-body","type":"text","text":"Acceptance is immediate; refusal is distributed across three nested screens.","tone":"warning"},{"id":"problematic-3-radio","type":"radio","label":"Accept all","checked":true},{"id":"problematic-4-radio","type":"radio","label":"Reject optional tracking","checked":false}],"annotations":[{"targetId":"problematic-2-body","text":"Why this state matters: The route adds avoidable effort between the user’s stated intention and completion. In this cookie preferences example, the obstacle is: “Acceptance is immediate; refusal is distributed across three nested screens.” Evidence should show whether the alternative remains usable and whether “Reject optional tracking” reaches the represented state. The asymmetric path can deter a user from reaching a genuine lower-data choice."},{"targetId":"problematic-4-radio","text":"Review prompt: How many steps, waits and channel changes separate “Accept all” from the completed cookie preferences outcome?"}]},"neutral":{"label":"Choose optional tracking","layout":"choice-list","elements":[{"id":"neutral-1-heading","type":"heading","text":"Choose optional tracking"},{"id":"neutral-2-body","type":"text","text":"Accept all, reject optional and customise are visible at the same level.","tone":"default"},{"id":"neutral-3-radio","type":"radio","label":"Reject optional tracking","checked":false},{"id":"neutral-4-radio","type":"radio","label":"Accept all","checked":false},{"id":"neutral-5-disclosure","type":"disclosure","summary":"Choice consequences","content":"The consequence of selecting “Reject optional tracking” is displayed beside the option.","open":true}],"annotations":[{"targetId":"neutral-2-body","text":"Fairer design: Offer equally direct accept, reject and customise paths while preserving granular settings for users who want them."},{"targetId":"neutral-5-disclosure","text":"Review prompt: Capture every peer option, its default state and visual prominence; do those states support “The alternative is available in principle but requires additional discovery, interaction or recovery from obstruction”?"}]},"whyItMatters":"The route adds avoidable effort between the user’s stated intention and completion. In this cookie preferences example, the obstacle is: “Acceptance is immediate; refusal is distributed across three nested screens.” Evidence should show whether the alternative remains usable and whether “Reject optional tracking” reaches the represented state. The asymmetric path can deter a user from reaching a genuine lower-data choice.","fairDesignPrinciple":"Offer equally direct accept, reject and customise paths while preserving granular settings for users who want them.","reviewPrompts":["How many steps, waits and channel changes separate “Accept all” from the completed cookie preferences outcome?","Capture every peer option, its default state and visual prominence; do those states support “The alternative is available in principle but requires additional discovery, interaction or recovery from obstruction”?","Measure the same task through the clearest available route: does the effort difference persist once “exit from an existing subscription, which is classified as hard to cancel” is accounted for?"],"altText":"Side-by-side cookie preferences interface showing “Your privacy options” and the clearer alternative “Choose optional tracking”.","provenance":"Original hypothetical cookie preferences example created for this library; no real business, product or interface is depicted."}],"fairAlternative":"Place equivalent alternatives in the same decision context with comparable discoverability and no unnecessary steps.","whyProblematic":"A relevant alternative within the current decision is hidden, blocked or made materially harder than the business-favoured action. A real alternative remains technically present but is buried, de-emphasised or placed behind extra discovery effort compared with the favoured route. These harms describe a review risk, not an automatic legal conclusion. Australian section 28B commences on 1 July 2027 and requires its complete, context-specific test. Existing ACL provisions remain a separate current-law assessment.","contextFactors":["The options address the same decision.","The alternative is available in principle but requires additional discovery, interaction or recovery from obstruction.","The asymmetry is not necessary for security, safety or the user's stated task.","Boundary to test: Different actions with genuinely different complexity","Boundary to test: exit from an existing subscription, which is classified as hard to cancel","Boundary to test: alternative unavailable for a disclosed eligibility reason"],"affectedTeams":["Product","Design","Engineering","Legal","Compliance"],"reviewQuestions":["How many steps, waits and channel changes separate “Create account” from the completed retail basket outcome?","Capture every peer option, its default state and visual prominence; do those states support “The options address the same decision”?","Measure the same task through the clearest available route: does the effort difference persist once “Different actions with genuinely different complexity” is accounted for?","How many steps, waits and channel changes separate “Accept all” from the completed cookie preferences outcome?","Capture every peer option, its default state and visual prominence; do those states support “The alternative is available in principle but requires additional discovery, interaction or recovery from obstruction”?","Measure the same task through the clearest available route: does the effort difference persist once “exit from an existing subscription, which is classified as hard to cancel” is accounted for?"],"evidence":["Annotated checkout and signup screenshots at each responsive breakpoint","The complete state sequence before, during and after the consumer decision","Design-system component, content, default and configuration records for the reviewed release","Operational records substantiating price, availability, timing and eligibility claims","Usability, accessibility, reversal, complaint and support evidence relevant to consumer impact","A dated product and legal review record identifying evidence, uncertainties and release decisions"],"related":["account-deletion-obstruction","comparison-prevention","customer-support-obstruction","dead-end"],"sourceIds":["oecd-dark-commercial-patterns-2022","au-act-2026-64"],"altText":"Side-by-side retail basket interface showing “Save time with an account” and the clearer alternative “Choose a checkout route”.","provenance":"Original hypothetical interface comparisons from the shared learning library, adapted to Australian-dollar context for this portal; no real business, product or interface is depicted.","author":"Flowlane","datePublished":"2026-08-10","dateModified":"2026-09-14","lastReviewed":"2026-09-14","changeNote":"Source comparison recorded and the current status restated."},{"title":"Privacy maze","slug":"privacy-maze","preferredName":"Privacy maze","directAnswer":"Privacy maze is a working label for this design mechanism: Privacy controls are fragmented, inconsistently labelled or layered so that limiting collection or use is unnecessarily difficult. This is editorial implementation guidance for Australian journeys, not a finding of unlawfulness. From 1 July 2027, a similar interface is relevant to ACL section 28B only if the complete consumer-connection, manipulation or unreasonable-distortion and actual-or-likely-detriment test is met. Current ACL rules require a separate assessment.","definition":"Privacy controls are fragmented, inconsistently labelled or layered so that limiting collection or use is unnecessarily difficult. This is a design and research taxonomy for learning and evidence review, not a statutory offence label or an automatic finding that an interface is unlawful.","synonyms":["privacy settings maze","privacy zuckering by obstruction","tracking choices spread across screens","global opt-out unavailable","setting names inconsistent","decline route repeatedly branches"],"category":"Obstruction","family":"Obstruction","journeyStages":["Account Management"],"jurisdiction":"Australia","status":"Editorial implementation guidance","howItWorks":"Privacy controls are fragmented, inconsistently labelled or layered so that limiting collection or use is unnecessarily difficult. Related controls are distributed across inconsistent labels, menus or channels, preventing the user from seeing and maintaining one coherent privacy state.","warningSigns":["A meaningful privacy-restrictive outcome exists in principle.","The route contains unnecessary branching, repeated settings or inconsistent terminology.","The less-private route is materially easier or the maze is likely to cause abandonment."],"harms":["A person may fail to restrict optional uses because the controls are fragmented and inconsistently described.","The user cannot maintain a reliable privacy preference across interfaces."],"legitimateUses":["Granular controls with a clear overview and global options","complexity strictly required by genuinely distinct processing purposes","information-only privacy policy"],"legalBasis":[{"provision":"ACL section 28B, inserted by the 2026 Act","sourceIds":["au-act-2026-64"],"classification":"Possible risk indicator","explanation":"In account management journeys, the privacy maze mechanism may warrant review where it manipulates a consumer or unreasonably distorts the decision environment and causes, or is likely to cause, detriment. The obstruction label and an interface similarity do not establish a contravention; the complete section 28B test, scope, facts and evidence must be applied from 1 July 2027."},{"provision":"Dark-pattern research taxonomy","sourceIds":["gray-ontology-dark-patterns-2024","eu-behavioural-study-digital-environment-2022"],"classification":"Editorial analysis","explanation":"The cited research sources support this working pattern within the obstruction family. It is editorial implementation guidance, not an Australian statutory category, regulator finding or legal safe harbour."}],"examples":[{"type":"Illustrative example","context":"Advertising opt-out split across unrelated menus","scenario":"A fictional service places audience ads, partner sharing and measurement controls under three differently named menus with no summary of the final state.","harm":"A person may fail to restrict optional uses because the controls are fragmented and inconsistently described."},{"type":"Illustrative example","context":"Privacy choice silently re-enables elsewhere","scenario":"A fictional account lets users disable activity sharing on the web, but opening the mobile app silently restores the setting under a different label.","harm":"The user cannot maintain a reliable privacy preference across interfaces."}],"problematicUi":{"label":"Manage experience controls","copy":"Manage experience controls Related advertising choices are scattered across “Experience”, “Partners” and “Insights”. Open another menu Unconfirmed state: Open another menu","annotations":["Why this state matters: The route adds avoidable effort between the user’s stated intention and completion. In this privacy settings example, the obstacle is: “Related advertising choices are scattered across “Experience”, “Partners” and “Insights”.” Evidence should show whether the alternative remains usable and whether “Turn off optional uses” reaches the represented state. A person may fail to restrict optional uses because the controls are fragmented and inconsistently described.","Review prompt: How many steps, waits and channel changes separate “Open another menu” from the completed privacy settings outcome?"]},"improvedUi":{"label":"Optional data uses","copy":"Optional data uses All related purposes and current states are visible in one navigable overview. Turn off optional uses Saved state: Turn off optional uses Persisted account state The saved state behind “Turn off optional uses” remains consistent after refresh and across supported channels.","annotations":["Fairer design: Provide a coherent overview, consistent purpose names and a clear summary of what each choice changes.","Review prompt: Test the control across refresh, device and account states; is “A meaningful privacy-restrictive outcome exists in principle” still observable after persistence is considered?"]},"uiComparisons":[{"id":"privacy-maze-scenario-1","title":"Advertising opt-out split across unrelated menus","context":"Privacy settings","journeyStage":"Account Management","summary":"A fictional service places audience ads, partner sharing and measurement controls under three differently named menus with no summary of the final state.","problematic":{"label":"Manage experience controls","layout":"account-panel","elements":[{"id":"problematic-1-heading","type":"heading","text":"Manage experience controls"},{"id":"problematic-2-body","type":"text","text":"Related advertising choices are scattered across “Experience”, “Partners” and “Insights”.","tone":"warning"},{"id":"problematic-3-link","type":"link","text":"Open another menu","emphasis":"subtle"},{"id":"problematic-4-badge","type":"badge","text":"Unconfirmed state: Open another menu","tone":"warning"}],"annotations":[{"targetId":"problematic-2-body","text":"Why this state matters: The route adds avoidable effort between the user’s stated intention and completion. In this privacy settings example, the obstacle is: “Related advertising choices are scattered across “Experience”, “Partners” and “Insights”.” Evidence should show whether the alternative remains usable and whether “Turn off optional uses” reaches the represented state. A person may fail to restrict optional uses because the controls are fragmented and inconsistently described."},{"targetId":"problematic-4-badge","text":"Review prompt: How many steps, waits and channel changes separate “Open another menu” from the completed privacy settings outcome?"}]},"neutral":{"label":"Optional data uses","layout":"account-panel","elements":[{"id":"neutral-1-heading","type":"heading","text":"Optional data uses"},{"id":"neutral-2-body","type":"text","text":"All related purposes and current states are visible in one navigable overview.","tone":"default"},{"id":"neutral-3-link","type":"link","text":"Turn off optional uses","emphasis":"default"},{"id":"neutral-4-badge","type":"badge","text":"Saved state: Turn off optional uses","tone":"default"},{"id":"neutral-5-disclosure","type":"disclosure","summary":"Persisted account state","content":"The saved state behind “Turn off optional uses” remains consistent after refresh and across supported channels.","open":true}],"annotations":[{"targetId":"neutral-2-body","text":"Fairer design: Provide a coherent overview, consistent purpose names and a clear summary of what each choice changes."},{"targetId":"neutral-5-disclosure","text":"Review prompt: Test the control across refresh, device and account states; is “A meaningful privacy-restrictive outcome exists in principle” still observable after persistence is considered?"}]},"whyItMatters":"The route adds avoidable effort between the user’s stated intention and completion. In this privacy settings example, the obstacle is: “Related advertising choices are scattered across “Experience”, “Partners” and “Insights”.” Evidence should show whether the alternative remains usable and whether “Turn off optional uses” reaches the represented state. A person may fail to restrict optional uses because the controls are fragmented and inconsistently described.","fairDesignPrinciple":"Provide a coherent overview, consistent purpose names and a clear summary of what each choice changes.","reviewPrompts":["How many steps, waits and channel changes separate “Open another menu” from the completed privacy settings outcome?","Test the control across refresh, device and account states; is “A meaningful privacy-restrictive outcome exists in principle” still observable after persistence is considered?","Measure the same task through the clearest available route: does the effort difference persist once “Granular controls with a clear overview and global options” is accounted for?"],"altText":"Side-by-side privacy settings interface showing “Manage experience controls” and the clearer alternative “Optional data uses”.","provenance":"Original hypothetical privacy settings example created for this library; no real business, product or interface is depicted."},{"id":"privacy-maze-scenario-2","title":"Privacy choice silently re-enables elsewhere","context":"Connected-device account","journeyStage":"Account Management","summary":"A fictional account lets users disable activity sharing on the web, but opening the mobile app silently restores the setting under a different label.","problematic":{"label":"Personalised activity · Off","layout":"account-panel","elements":[{"id":"problematic-1-heading","type":"heading","text":"Personalised activity · Off"},{"id":"problematic-2-body","type":"text","text":"The mobile app later restores the same sharing under “Smart recommendations”.","tone":"warning"},{"id":"problematic-3-link","type":"link","text":"Setting may change","emphasis":"subtle"},{"id":"problematic-4-badge","type":"badge","text":"Unconfirmed state: Setting may change","tone":"warning"}],"annotations":[{"targetId":"problematic-2-body","text":"Why this state matters: The route adds avoidable effort between the user’s stated intention and completion. In this connected-device account example, the obstacle is: “The mobile app later restores the same sharing under “Smart recommendations”.” Evidence should show whether the alternative remains usable and whether “Keep off across devices” reaches the represented state. The user cannot maintain a reliable privacy preference across interfaces."},{"targetId":"problematic-4-badge","text":"Review prompt: How many steps, waits and channel changes separate “Setting may change” from the completed connected-device account outcome?"}]},"neutral":{"label":"Activity sharing · Off everywhere","layout":"account-panel","elements":[{"id":"neutral-1-heading","type":"heading","text":"Activity sharing · Off everywhere"},{"id":"neutral-2-body","type":"text","text":"Web and app show the same persisted state and audit date.","tone":"default"},{"id":"neutral-3-link","type":"link","text":"Keep off across devices","emphasis":"default"},{"id":"neutral-4-badge","type":"badge","text":"Saved state: Keep off across devices","tone":"default"},{"id":"neutral-5-disclosure","type":"disclosure","summary":"Persisted account state","content":"The saved state behind “Keep off across devices” remains consistent after refresh and across supported channels.","open":true}],"annotations":[{"targetId":"neutral-2-body","text":"Fairer design: Use one persistent state across channels, announce conflicts and require a deliberate choice before changing it."},{"targetId":"neutral-5-disclosure","text":"Review prompt: Test the control across refresh, device and account states; is “The route contains unnecessary branching, repeated settings or inconsistent terminology” still observable after persistence is considered?"}]},"whyItMatters":"The route adds avoidable effort between the user’s stated intention and completion. In this connected-device account example, the obstacle is: “The mobile app later restores the same sharing under “Smart recommendations”.” Evidence should show whether the alternative remains usable and whether “Keep off across devices” reaches the represented state. The user cannot maintain a reliable privacy preference across interfaces.","fairDesignPrinciple":"Use one persistent state across channels, announce conflicts and require a deliberate choice before changing it.","reviewPrompts":["How many steps, waits and channel changes separate “Setting may change” from the completed connected-device account outcome?","Test the control across refresh, device and account states; is “The route contains unnecessary branching, repeated settings or inconsistent terminology” still observable after persistence is considered?","Measure the same task through the clearest available route: does the effort difference persist once “complexity strictly required by genuinely distinct processing purposes” is accounted for?"],"altText":"Side-by-side connected-device account interface showing “Personalised activity · Off” and the clearer alternative “Activity sharing · Off everywhere”.","provenance":"Original hypothetical connected-device account example created for this library; no real business, product or interface is depicted."}],"fairAlternative":"Provide a coherent privacy-control overview, consistent labels and direct controls for common restrictive choices.","whyProblematic":"Privacy controls are fragmented, inconsistently labelled or layered so that limiting collection or use is unnecessarily difficult. Related controls are distributed across inconsistent labels, menus or channels, preventing the user from seeing and maintaining one coherent privacy state. These harms describe a review risk, not an automatic legal conclusion. Australian section 28B commences on 1 July 2027 and requires its complete, context-specific test. Existing ACL provisions remain a separate current-law assessment.","contextFactors":["A meaningful privacy-restrictive outcome exists in principle.","The route contains unnecessary branching, repeated settings or inconsistent terminology.","The less-private route is materially easier or the maze is likely to cause abandonment.","Boundary to test: Granular controls with a clear overview and global options","Boundary to test: complexity strictly required by genuinely distinct processing purposes","Boundary to test: information-only privacy policy"],"affectedTeams":["Product","Design","Engineering","Legal","Compliance"],"reviewQuestions":["How many steps, waits and channel changes separate “Open another menu” from the completed privacy settings outcome?","Test the control across refresh, device and account states; is “A meaningful privacy-restrictive outcome exists in principle” still observable after persistence is considered?","Measure the same task through the clearest available route: does the effort difference persist once “Granular controls with a clear overview and global options” is accounted for?","How many steps, waits and channel changes separate “Setting may change” from the completed connected-device account outcome?","Test the control across refresh, device and account states; is “The route contains unnecessary branching, repeated settings or inconsistent terminology” still observable after persistence is considered?","Measure the same task through the clearest available route: does the effort difference persist once “complexity strictly required by genuinely distinct processing purposes” is accounted for?"],"evidence":["Annotated account management screenshots at each responsive breakpoint","The complete state sequence before, during and after the consumer decision","Design-system component, content, default and configuration records for the reviewed release","Operational records substantiating price, availability, timing and eligibility claims","Usability, accessibility, reversal, complaint and support evidence relevant to consumer impact","A dated product and legal review record identifying evidence, uncertainties and release decisions"],"related":["account-deletion-obstruction","comparison-prevention","customer-support-obstruction","dead-end"],"sourceIds":["gray-ontology-dark-patterns-2024","eu-behavioural-study-digital-environment-2022","au-act-2026-64"],"altText":"Side-by-side privacy settings interface showing “Manage experience controls” and the clearer alternative “Optional data uses”.","provenance":"Original hypothetical interface comparisons from the shared learning library, adapted to Australian-dollar context for this portal; no real business, product or interface is depicted.","author":"Flowlane","datePublished":"2026-08-10","dateModified":"2026-09-14","lastReviewed":"2026-09-14","changeNote":"Source comparison recorded and the current status restated."},{"title":"Bait and switch","slug":"bait-and-switch","preferredName":"Bait and switch","directAnswer":"Bait and switch is a working label for this design mechanism: The user selects a represented action or offer but receives a materially different outcome that favours the business. This is editorial implementation guidance for Australian journeys, not a finding of unlawfulness. From 1 July 2027, a similar interface is relevant to ACL section 28B only if the complete consumer-connection, manipulation or unreasonable-distortion and actual-or-likely-detriment test is met. Current ACL rules require a separate assessment.","definition":"The user selects a represented action or offer but receives a materially different outcome that favours the business. This is a design and research taxonomy for learning and evidence review, not a statutory offence label or an automatic finding that an interface is unlawful.","synonyms":["outcome switch","misdirected action","represented free action becomes paid","control triggers different action","selected offer replaced after click","close control opens promotion"],"category":"Sneaking","family":"Sneaking","journeyStages":["Account Management","Checkout"],"jurisdiction":"Australia","status":"Editorial implementation guidance","howItWorks":"The user selects a represented action or offer but receives a materially different outcome that favours the business. The activated control produces a materially different product, price or action from the one its label and preceding selection represented.","warningSigns":["The pre-action representation supports a reasonably specific expected outcome.","The observed post-action state materially differs from that outcome.","The mismatch is not corrected before commitment and favours the business."],"harms":["The user receives a materially different action from the one represented and may install unwanted software.","The traveller may buy a different, more expensive product than the one selected."],"legitimateUses":["Clearly disclosed intermediate step","availability change explained before commitment","ordinary navigation label imprecision with no detriment"],"legalBasis":[{"provision":"ACL section 28B, inserted by the 2026 Act","sourceIds":["au-act-2026-64"],"classification":"Possible risk indicator","explanation":"In account management and checkout journeys, the bait and switch mechanism may warrant review where it manipulates a consumer or unreasonably distorts the decision environment and causes, or is likely to cause, detriment. The sneaking label and an interface similarity do not establish a contravention; the complete section 28B test, scope, facts and evidence must be applied from 1 July 2027."},{"provision":"Dark-pattern research taxonomy","sourceIds":["oecd-dark-commercial-patterns-2022"],"classification":"Editorial analysis","explanation":"The cited research sources support this working pattern within the sneaking family. It is editorial implementation guidance, not an Australian statutory category, regulator finding or legal safe harbour."}],"examples":[{"type":"Illustrative example","context":"Download control opens an unrelated installer","scenario":"A fictional account page labels a prominent control “Download document”, but it launches an optional browser-extension installer instead.","harm":"The user receives a materially different action from the one represented and may install unwanted software."},{"type":"Illustrative example","context":"Selected basic fare changes at confirmation","scenario":"A fictional booking flow records a basic fare selection but the final action purchases a premium flexible fare without a new price-and-product confirmation.","harm":"The traveller may buy a different, more expensive product than the one selected."}],"problematicUi":{"label":"Download your document","copy":"Download your document The prominent control starts an extension installer instead of the file. Download now Download PDF","annotations":["Why this state matters: The final commercial state diverges from the choice represented earlier in the journey. The problematic state records: “The prominent control starts an extension installer instead of the file.” Review the timing and affirmative selection needed before “Download now” changes price, product or recurring liability. The user receives a materially different action from the one represented and may install unwanted software.","Review prompt: Which affirmative action authorises “Download now”, and where is the resulting price, product or recurring state shown before commitment?"]},"improvedUi":{"label":"Your document is ready","copy":"Your document is ready The file action downloads the document; optional software is a separate offer. Download PDF Download now What happens next Activating “Download PDF” produces the outcome stated on the control.","annotations":["Fairer design: Make the document action perform the stated download and label any optional software offer separately.","Review prompt: Can the dialog be dismissed, what action does each control trigger, and what later state confirms or contradicts “The pre-action representation supports a reasonably specific expected outcome”?"]},"uiComparisons":[{"id":"bait-and-switch-scenario-1","title":"Download control opens an unrelated installer","context":"Account document download","journeyStage":"Account Management","summary":"A fictional account page labels a prominent control “Download document”, but it launches an optional browser-extension installer instead.","problematic":{"label":"Download your document","layout":"dialog","elements":[{"id":"problematic-1-heading","type":"heading","text":"Download your document"},{"id":"problematic-2-body","type":"text","text":"The prominent control starts an extension installer instead of the file.","tone":"warning"},{"id":"problematic-3-button","type":"button","text":"Download now","emphasis":"primary"},{"id":"problematic-4-link","type":"link","text":"Download PDF","emphasis":"subtle"}],"annotations":[{"targetId":"problematic-2-body","text":"Why this state matters: The final commercial state diverges from the choice represented earlier in the journey. The problematic state records: “The prominent control starts an extension installer instead of the file.” Review the timing and affirmative selection needed before “Download now” changes price, product or recurring liability. The user receives a materially different action from the one represented and may install unwanted software."},{"targetId":"problematic-4-link","text":"Review prompt: Which affirmative action authorises “Download now”, and where is the resulting price, product or recurring state shown before commitment?"}]},"neutral":{"label":"Your document is ready","layout":"dialog","elements":[{"id":"neutral-1-heading","type":"heading","text":"Your document is ready"},{"id":"neutral-2-body","type":"text","text":"The file action downloads the document; optional software is a separate offer.","tone":"default"},{"id":"neutral-3-button","type":"button","text":"Download PDF","emphasis":"secondary"},{"id":"neutral-4-link","type":"link","text":"Download now","emphasis":"default"},{"id":"neutral-5-disclosure","type":"disclosure","summary":"What happens next","content":"Activating “Download PDF” produces the outcome stated on the control.","open":true}],"annotations":[{"targetId":"neutral-2-body","text":"Fairer design: Make the document action perform the stated download and label any optional software offer separately."},{"targetId":"neutral-5-disclosure","text":"Review prompt: Can the dialog be dismissed, what action does each control trigger, and what later state confirms or contradicts “The pre-action representation supports a reasonably specific expected outcome”?"}]},"whyItMatters":"The final commercial state diverges from the choice represented earlier in the journey. The problematic state records: “The prominent control starts an extension installer instead of the file.” Review the timing and affirmative selection needed before “Download now” changes price, product or recurring liability. The user receives a materially different action from the one represented and may install unwanted software.","fairDesignPrinciple":"Make the document action perform the stated download and label any optional software offer separately.","reviewPrompts":["Which affirmative action authorises “Download now”, and where is the resulting price, product or recurring state shown before commitment?","Can the dialog be dismissed, what action does each control trigger, and what later state confirms or contradicts “The pre-action representation supports a reasonably specific expected outcome”?","Which specific affirmative event creates the final commercial state, and could “Clearly disclosed intermediate step” explain the observed outcome instead?"],"altText":"Side-by-side account document download interface showing “Download your document” and the clearer alternative “Your document is ready”.","provenance":"Original hypothetical account document download example created for this library; no real business, product or interface is depicted."},{"id":"bait-and-switch-scenario-2","title":"Selected basic fare changes at confirmation","context":"Travel booking","journeyStage":"Checkout","summary":"A fictional booking flow records a basic fare selection but the final action purchases a premium flexible fare without a new price-and-product confirmation.","problematic":{"label":"Complete booking","layout":"checkout-summary","elements":[{"id":"problematic-1-heading","type":"heading","text":"Complete booking"},{"id":"problematic-2-body","type":"text","text":"The final summary silently substitutes the premium fare.","tone":"warning"},{"id":"problematic-3-price","type":"price","label":"Amount affected","amount":"$240"},{"id":"problematic-4-button","type":"button","text":"Pay $240","emphasis":"primary"},{"id":"problematic-5-link","type":"link","text":"Book basic fare $160","emphasis":"subtle"}],"annotations":[{"targetId":"problematic-2-body","text":"Why this state matters: The final commercial state diverges from the choice represented earlier in the journey. The problematic state records: “The final summary silently substitutes the premium fare.” Review the timing and affirmative selection needed before “Pay $240” changes price, product or recurring liability. The traveller may buy a different, more expensive product than the one selected."},{"targetId":"problematic-5-link","text":"Review prompt: Which affirmative action authorises “Pay $240”, and where is the resulting price, product or recurring state shown before commitment?"}]},"neutral":{"label":"Basic fare selected","layout":"checkout-summary","elements":[{"id":"neutral-1-heading","type":"heading","text":"Basic fare selected"},{"id":"neutral-2-body","type":"text","text":"The fare, conditions and $160 total match the earlier choice.","tone":"default"},{"id":"neutral-3-price","type":"price","label":"Amount affected","amount":"$160"},{"id":"neutral-4-button","type":"button","text":"Book basic fare $160","emphasis":"secondary"},{"id":"neutral-5-link","type":"link","text":"Pay $240","emphasis":"default"},{"id":"neutral-6-disclosure","type":"disclosure","summary":"Payable total and selected items","content":"The summary shows the line items and total before “Book basic fare $160” is activated.","open":true}],"annotations":[{"targetId":"neutral-2-body","text":"Fairer design: Preserve the selected fare and require explicit review if availability requires a different product or price."},{"targetId":"neutral-6-disclosure","text":"Review prompt: Compare the basket before and after the action, including total and line items; does the mutation satisfy “The observed post-action state materially differs from that outcome”?"}]},"whyItMatters":"The final commercial state diverges from the choice represented earlier in the journey. The problematic state records: “The final summary silently substitutes the premium fare.” Review the timing and affirmative selection needed before “Pay $240” changes price, product or recurring liability. The traveller may buy a different, more expensive product than the one selected.","fairDesignPrinciple":"Preserve the selected fare and require explicit review if availability requires a different product or price.","reviewPrompts":["Which affirmative action authorises “Pay $240”, and where is the resulting price, product or recurring state shown before commitment?","Compare the basket before and after the action, including total and line items; does the mutation satisfy “The observed post-action state materially differs from that outcome”?","Which specific affirmative event creates the final commercial state, and could “availability change explained before commitment” explain the observed outcome instead?"],"altText":"Side-by-side travel booking interface showing “Complete booking” and the clearer alternative “Basic fare selected”.","provenance":"Original hypothetical travel booking example created for this library; no real business, product or interface is depicted."}],"fairAlternative":"Make the action produce its represented result or disclose and obtain assent to any material change before commitment.","whyProblematic":"The user selects a represented action or offer but receives a materially different outcome that favours the business. The activated control produces a materially different product, price or action from the one its label and preceding selection represented. These harms describe a review risk, not an automatic legal conclusion. Australian section 28B commences on 1 July 2027 and requires its complete, context-specific test. Existing ACL provisions remain a separate current-law assessment.","contextFactors":["The pre-action representation supports a reasonably specific expected outcome.","The observed post-action state materially differs from that outcome.","The mismatch is not corrected before commitment and favours the business.","Boundary to test: Clearly disclosed intermediate step","Boundary to test: availability change explained before commitment","Boundary to test: ordinary navigation label imprecision with no detriment"],"affectedTeams":["Product","Design","Engineering","Legal","Compliance"],"reviewQuestions":["Which affirmative action authorises “Download now”, and where is the resulting price, product or recurring state shown before commitment?","Can the dialog be dismissed, what action does each control trigger, and what later state confirms or contradicts “The pre-action representation supports a reasonably specific expected outcome”?","Which specific affirmative event creates the final commercial state, and could “Clearly disclosed intermediate step” explain the observed outcome instead?","Which affirmative action authorises “Pay $240”, and where is the resulting price, product or recurring state shown before commitment?","Compare the basket before and after the action, including total and line items; does the mutation satisfy “The observed post-action state materially differs from that outcome”?","Which specific affirmative event creates the final commercial state, and could “availability change explained before commitment” explain the observed outcome instead?"],"evidence":["Annotated account management and checkout screenshots at each responsive breakpoint","The complete state sequence before, during and after the consumer decision","Design-system component, content, default and configuration records for the reviewed release","Operational records substantiating price, availability, timing and eligibility claims","Usability, accessibility, reversal, complaint and support evidence relevant to consumer impact","A dated product and legal review record identifying evidence, uncertainties and release decisions"],"related":["drip-pricing-and-mandatory-fees","subscription-traps-and-automatic-renewal","negative-option-or-unauthorised-transaction","sneak-into-basket"],"sourceIds":["oecd-dark-commercial-patterns-2022","au-act-2026-64"],"altText":"Side-by-side account document download interface showing “Download your document” and the clearer alternative “Your document is ready”.","provenance":"Original hypothetical interface comparisons from the shared learning library, adapted to Australian-dollar context for this portal; no real business, product or interface is depicted.","author":"Flowlane","datePublished":"2026-08-10","dateModified":"2026-09-14","lastReviewed":"2026-09-14","changeNote":"Source comparison recorded and the current status restated."},{"title":"Drip pricing and mandatory fees","slug":"drip-pricing-and-mandatory-fees","preferredName":"Drip pricing and mandatory fees","directAnswer":"From 1 July 2027, section 48A will require specified information about a transaction-based charge to appear legibly, prominently, unambiguously and close to a displayed base price for consumer-type goods or services. It does not replace the ACL's single-price or misleading- conduct rules. Whether an amount is a transaction-based charge or an excluded amount must be checked carefully.","definition":"A mandatory or foreseeable charge is omitted, obscured or revealed only after the user has invested effort in the transaction. This is a design and research taxonomy for learning and evidence review, not a statutory offence label or an automatic finding that an interface is unlawful.","synonyms":["hidden charges","drip pricing","late mandatory fee","transaction fee shown late","mandatory service charge absent from initial price","base price excludes unavoidable component","per-transaction fee unclear","hidden mandatory fee","transaction fee","service fee","unavoidable charge","Hidden costs or drip pricing"],"category":"Sneaking","family":"Sneaking","journeyStages":["Checkout","Pricing"],"jurisdiction":"Australia","status":"Commences 1 July 2027","howItWorks":"A mandatory or foreseeable charge is omitted, obscured or revealed only after the user has invested effort in the transaction. A foreseeable compulsory charge is withheld until later effort has been invested, making the offer appear cheaper at search, selection or comparison.","warningSigns":["A price is displayed before a later charge becomes visible.","The charge is mandatory, transaction-linked or reasonably foreseeable for the selected path.","Earlier presentation does not effectively communicate amount, method or inclusion status."],"harms":["Late disclosure can make the offer appear cheaper and exploit effort already invested in checkout.","Travellers may compare and select rooms using an understated unavoidable cost."],"legitimateUses":["Optional add-on deliberately selected","variable charge impossible to calculate but calculation method and applicability clearly disclosed","government charge clearly disclosed at the initial price"],"legalBasis":[{"provision":"ACL section 48A(1) to (5), inserted by the 2026 Act","sourceIds":["au-act-2026-64"],"classification":"Express rule","explanation":"Sets the product scope and the transaction-charge disclosure content, timing and presentation requirements."},{"provision":"ACL section 48A(6) to (8), inserted by the 2026 Act","sourceIds":["au-act-2026-64"],"classification":"Express rule","explanation":"Defines base price and transaction-based charge and lists excluded amounts."},{"provision":"ACL section 48A(9) to (10), inserted by the 2026 Act","sourceIds":["au-act-2026-64"],"classification":"Express rule","explanation":"Allows prescribed exclusions and preserves the operation of the existing section 48 single-price rule."}],"examples":[{"type":"Illustrative example","context":"Mandatory service fee revealed after payment details","scenario":"A fictional booking site shows a $40 ticket through search and selection but adds a compulsory $9 service fee only after card details are entered.","harm":"Late disclosure can make the offer appear cheaper and exploit effort already invested in checkout."},{"type":"Illustrative example","context":"Resort fee appears after room selection","scenario":"A fictional hotel result advertises $120 per night while a compulsory $28 nightly facility fee appears only in the final booking summary.","harm":"Travellers may compare and select rooms using an understated unavoidable cost."},{"type":"Illustrative example","context":"Mandatory booking charge shown only at payment","scenario":"A booking site displays a $40 base price on search and product pages, but every transaction attracts a $9 booking charge revealed only after the consumer enters payment details.","harm":"From commencement, the charge information may need to accompany each displayed base price under section 48A. Existing component-pricing and misleading-conduct rules also require review."},{"type":"Illustrative example","context":"Variable service fee without a calculation method","scenario":"A delivery marketplace shows meal prices but says only 'service fee may apply', although the compulsory fee is calculated as 8% of the basket.","harm":"The statement omits the amount or method and may not satisfy the specific content and clarity requirements from 1 July 2027."}],"problematicUi":{"label":"Ticket · $40","copy":"Ticket · $40 A mandatory $9 service fee appears only after card entry. Continue to payment Pay $49","annotations":["Why this state matters: The final commercial state diverges from the choice represented earlier in the journey. The problematic state records: “A mandatory $9 service fee appears only after card entry.” Review the timing and affirmative selection needed before “Continue to payment” changes price, product or recurring liability. Late disclosure can make the offer appear cheaper and exploit effort already invested in checkout.","Review prompt: Which affirmative action authorises “Continue to payment”, and where is the resulting price, product or recurring state shown before commitment?"]},"improvedUi":{"label":"Ticket total · $49","copy":"Ticket total · $49 The $40 base amount and $9 compulsory service fee appear together. Amount affected $49 Pay $49 Continue to payment Payable total and selected items The summary shows the line items and total before “Pay $49” is activated.","annotations":["Fairer design: Show the foreseeable payable total and compulsory fee near the first material price and preserve it throughout the journey.","Review prompt: Compare the basket before and after the action, including total and line items; does the mutation satisfy “A price is displayed before a later charge becomes visible”?"]},"uiComparisons":[{"id":"hidden-costs-or-drip-pricing-scenario-1","title":"Mandatory service fee revealed after payment details","context":"Ticket booking","journeyStage":"Checkout","summary":"A fictional booking site shows a $40 ticket through search and selection but adds a compulsory $9 service fee only after card details are entered.","problematic":{"label":"Ticket · $40","layout":"checkout-summary","elements":[{"id":"problematic-1-heading","type":"heading","text":"Ticket · $40"},{"id":"problematic-2-body","type":"text","text":"A mandatory $9 service fee appears only after card entry.","tone":"warning"},{"id":"problematic-3-button","type":"button","text":"Continue to payment","emphasis":"primary"},{"id":"problematic-4-link","type":"link","text":"Pay $49","emphasis":"subtle"}],"annotations":[{"targetId":"problematic-2-body","text":"Why this state matters: The final commercial state diverges from the choice represented earlier in the journey. The problematic state records: “A mandatory $9 service fee appears only after card entry.” Review the timing and affirmative selection needed before “Continue to payment” changes price, product or recurring liability. Late disclosure can make the offer appear cheaper and exploit effort already invested in checkout."},{"targetId":"problematic-4-link","text":"Review prompt: Which affirmative action authorises “Continue to payment”, and where is the resulting price, product or recurring state shown before commitment?"}]},"neutral":{"label":"Ticket total · $49","layout":"checkout-summary","elements":[{"id":"neutral-1-heading","type":"heading","text":"Ticket total · $49"},{"id":"neutral-2-body","type":"text","text":"The $40 base amount and $9 compulsory service fee appear together.","tone":"default"},{"id":"neutral-3-price","type":"price","label":"Amount affected","amount":"$49"},{"id":"neutral-4-button","type":"button","text":"Pay $49","emphasis":"secondary"},{"id":"neutral-5-link","type":"link","text":"Continue to payment","emphasis":"default"},{"id":"neutral-6-disclosure","type":"disclosure","summary":"Payable total and selected items","content":"The summary shows the line items and total before “Pay $49” is activated.","open":true}],"annotations":[{"targetId":"neutral-2-body","text":"Fairer design: Show the foreseeable payable total and compulsory fee near the first material price and preserve it throughout the journey."},{"targetId":"neutral-6-disclosure","text":"Review prompt: Compare the basket before and after the action, including total and line items; does the mutation satisfy “A price is displayed before a later charge becomes visible”?"}]},"whyItMatters":"The final commercial state diverges from the choice represented earlier in the journey. The problematic state records: “A mandatory $9 service fee appears only after card entry.” Review the timing and affirmative selection needed before “Continue to payment” changes price, product or recurring liability. Late disclosure can make the offer appear cheaper and exploit effort already invested in checkout.","fairDesignPrinciple":"Show the foreseeable payable total and compulsory fee near the first material price and preserve it throughout the journey.","reviewPrompts":["Which affirmative action authorises “Continue to payment”, and where is the resulting price, product or recurring state shown before commitment?","Compare the basket before and after the action, including total and line items; does the mutation satisfy “A price is displayed before a later charge becomes visible”?","Which specific affirmative event creates the final commercial state, and could “Optional add-on deliberately selected” explain the observed outcome instead?"],"altText":"Side-by-side ticket booking interface showing “Ticket · $40” and the clearer alternative “Ticket total · $49”.","provenance":"Original hypothetical ticket booking example created for this library; no real business, product or interface is depicted."},{"id":"hidden-costs-or-drip-pricing-scenario-2","title":"Resort fee appears after room selection","context":"Accommodation booking","journeyStage":"Pricing","summary":"A fictional hotel result advertises $120 per night while a compulsory $28 nightly facility fee appears only in the final booking summary.","problematic":{"label":"Room · $120/night","layout":"pricing-card","elements":[{"id":"problematic-1-heading","type":"heading","text":"Room · $120/night"},{"id":"problematic-2-body","type":"text","text":"The unavoidable $28 nightly fee is omitted from search and room cards.","tone":"warning"},{"id":"problematic-3-button","type":"button","text":"Select room","emphasis":"primary"},{"id":"problematic-4-link","type":"link","text":"Choose at $148/night","emphasis":"subtle"}],"annotations":[{"targetId":"problematic-2-body","text":"Why this state matters: The final commercial state diverges from the choice represented earlier in the journey. The problematic state records: “The unavoidable $28 nightly fee is omitted from search and room cards.” Review the timing and affirmative selection needed before “Select room” changes price, product or recurring liability. Travellers may compare and select rooms using an understated unavoidable cost."},{"targetId":"problematic-4-link","text":"Review prompt: Which affirmative action authorises “Select room”, and where is the resulting price, product or recurring state shown before commitment?"}]},"neutral":{"label":"Room total · $148/night","layout":"pricing-card","elements":[{"id":"neutral-1-heading","type":"heading","text":"Room total · $148/night"},{"id":"neutral-2-body","type":"text","text":"The base price and compulsory facility fee are shown before selection.","tone":"default"},{"id":"neutral-3-price","type":"price","label":"Displayed amount","amount":"$148"},{"id":"neutral-4-button","type":"button","text":"Choose at $148/night","emphasis":"secondary"},{"id":"neutral-5-link","type":"link","text":"Select room","emphasis":"default"},{"id":"neutral-6-disclosure","type":"disclosure","summary":"Price, period and commitment","content":"The price and material terms associated with “Choose at $148/night” remain beside this choice.","open":true}],"annotations":[{"targetId":"neutral-2-body","text":"Fairer design: Include compulsory charges in the comparable total and explain any component breakdown before room selection."},{"targetId":"neutral-6-disclosure","text":"Review prompt: Place the compared prices, billing periods and material terms on one evidence sheet; where does it support “The charge is mandatory, transaction-linked or reasonably foreseeable for the selected path”?"}]},"whyItMatters":"The final commercial state diverges from the choice represented earlier in the journey. The problematic state records: “The unavoidable $28 nightly fee is omitted from search and room cards.” Review the timing and affirmative selection needed before “Select room” changes price, product or recurring liability. Travellers may compare and select rooms using an understated unavoidable cost.","fairDesignPrinciple":"Include compulsory charges in the comparable total and explain any component breakdown before room selection.","reviewPrompts":["Which affirmative action authorises “Select room”, and where is the resulting price, product or recurring state shown before commitment?","Place the compared prices, billing periods and material terms on one evidence sheet; where does it support “The charge is mandatory, transaction-linked or reasonably foreseeable for the selected path”?","Which specific affirmative event creates the final commercial state, and could “variable charge impossible to calculate but calculation method and applicability clearly disclosed” explain the observed outcome instead?"],"altText":"Side-by-side accommodation booking interface showing “Room · $120/night” and the clearer alternative “Room total · $148/night”.","provenance":"Original hypothetical accommodation booking example created for this library; no real business, product or interface is depicted."}],"fairAlternative":"Show unavoidable and transaction-linked charges with the price, including amount or method, applicability and inclusion status.","whyProblematic":"A mandatory or foreseeable charge is omitted, obscured or revealed only after the user has invested effort in the transaction. A foreseeable compulsory charge is withheld until later effort has been invested, making the offer appear cheaper at search, selection or comparison. If an offer displays a base price, section 48A requires disclosure of the charge amount or calculation method, whether it is payable or may be payable, that it applies per transaction, and whether the base price includes it. The disclosure must remain with the base-price display and meet legibility, prominence, ambiguity and proximity requirements. Existing section 48 component-pricing and sections 18 and 29 can already apply to pricing presentations. Section 48A adds a specific rule at commencement and expressly does not limit section 48. Regulations may prescribe additional excluded charges or circumstances. None had been identified by the review date.","contextFactors":["A price is displayed before a later charge becomes visible.","The charge is mandatory, transaction-linked or reasonably foreseeable for the selected path.","Earlier presentation does not effectively communicate amount, method or inclusion status.","Boundary to test: Optional add-on deliberately selected","Boundary to test: variable charge impossible to calculate but calculation method and applicability clearly disclosed","Boundary to test: government charge clearly disclosed at the initial price","Is the amount compulsory for the transaction or genuinely optional?","Is it a price for the good or service itself, or a separate charge associated with supply?","When is the amount payable relative to the base price?","Does an exclusion in section 48A(8), or a later regulation, apply?","Can the charge be calculated and shown as a single price under existing section 48?","Does every base-price placement carry the required nearby charge information?"],"affectedTeams":["Pricing","Ecommerce","Product","Design","Engineering","Legal","Finance"],"reviewQuestions":["Which affirmative action authorises “Continue to payment”, and where is the resulting price, product or recurring state shown before commitment?","Compare the basket before and after the action, including total and line items; does the mutation satisfy “A price is displayed before a later charge becomes visible”?","Which specific affirmative event creates the final commercial state, and could “Optional add-on deliberately selected” explain the observed outcome instead?","Which affirmative action authorises “Select room”, and where is the resulting price, product or recurring state shown before commitment?","Place the compared prices, billing periods and material terms on one evidence sheet; where does it support “The charge is mandatory, transaction-linked or reasonably foreseeable for the selected path”?","Which specific affirmative event creates the final commercial state, and could “variable charge impossible to calculate but calculation method and applicability clearly disclosed” explain the observed outcome instead?","List every amount a consumer may pay: which are mandatory, optional, surcharges, government charges or pass-through amounts?","Does the same base price appear in ads, search, structured data, comparison feeds or affiliates?","Can the business display a single total price instead?","If a fee varies, is the calculation method intelligible before checkout?","Have mobile truncation and dynamically loaded prices been tested?","Has the regulations check been repeated since the content review date?"],"evidence":["fee taxonomy with legal rationale","price-feed and affiliate inventory","screenshots of every base-price placement","calculation specification and test cases","checkout totals and receipts","regulation recheck record","Annotated checkout and pricing screenshots at each responsive breakpoint","The complete state sequence before, during and after the consumer decision","Design-system component, content, default and configuration records for the reviewed release","Operational records substantiating price, availability, timing and eligibility claims","Usability, accessibility, reversal, complaint and support evidence relevant to consumer impact","A dated product and legal review record identifying evidence, uncertainties and release decisions"],"related":["bait-and-switch","subscription-traps-and-automatic-renewal","negative-option-or-unauthorised-transaction","sneak-into-basket"],"sourceIds":["oecd-dark-commercial-patterns-2022","au-act-2026-64","au-acl-2010"],"altText":"Side-by-side ticket booking interface showing “Ticket · $40” and the clearer alternative “Ticket total · $49”.","provenance":"Original hypothetical interface comparisons from the shared learning library, adapted to Australian-dollar context for this portal; no real business, product or interface is depicted.","author":"Flowlane","datePublished":"2026-08-09","dateModified":"2026-09-14","lastReviewed":"2026-09-14","changeNote":"Source comparison recorded and the current status restated."},{"title":"Subscription traps and automatic renewal","slug":"subscription-traps-and-automatic-renewal","preferredName":"Subscription traps and automatic renewal","directAnswer":"The Act creates specific subscription rules from 1 July 2027. Section 48D requires clear pre-contract disclosure of subscription status, payment liabilities, duration, continuation, notice and exit information. Section 48E's in-contract information duty applies only as prescribed, so the Act does not yet supply a universal reminder interval. Existing ACL rules already apply to misleading recurring-price and subscription representations.","definition":"A transaction creates or continues recurring liability without effective, timely disclosure of the subscription, renewal and exit consequences. This is a design and research taxonomy for learning and evidence review, not a statutory offence label or an automatic finding that an interface is unlawful.","synonyms":["forced continuity","hidden subscription","automatic renewal surprise","trial rolls into paid plan","renewal term hidden","recurring liability disclosed after assent","renewal notice absent where prescribed","subscription trap","automatic renewal","free-trial conversion","negative-option subscription","recurring billing","Hidden subscription or forced continuity"],"category":"Sneaking","family":"Sneaking","journeyStages":["Subscription","Checkout"],"jurisdiction":"Australia","status":"Commences 1 July 2027","howItWorks":"A transaction creates or continues recurring liability without effective, timely disclosure of the subscription, renewal and exit consequences. A free, low-cost or one-off presentation conceals the later recurring payment, conversion date or renewal state beside the action that creates it.","warningSigns":["The offer creates a subscription, renewal or recurring liability.","One or more material terms are missing, low-salience, ambiguous or late before assent.","The user can incur continued payment or commitment."],"harms":["A user may enter a large recurring liability without understanding the conversion.","A shopper may incur repeated charges after believing the transaction was one-off."],"legitimateUses":["Recurring terms clearly and prominently disclosed before assent","A clearly presented one-off purchase with no continuing payment or renewal consequence","Cancellation friction without an offer-disclosure defect","A continuing service that creates no automatic payment, renewal or post-trial liability"],"legalBasis":[{"provision":"ACL sections 48B to 48C, inserted by the 2026 Act","sourceIds":["au-act-2026-64"],"classification":"Express rule","explanation":"Define subscription contracts and exclude leases, real-property licences, hire-purchase, instalment-payment contracts, childcare, specified school tuition and prescribed kinds."},{"provision":"ACL section 48D, inserted by the 2026 Act","sourceIds":["au-act-2026-64"],"classification":"Express rule","explanation":"Requires the offer to state that the arrangement would be a subscription and disclose liabilities, period, continuation, required notice, exit method and any prescribed matter with specified clarity and timing."},{"provision":"ACL section 48E, inserted by the 2026 Act","sourceIds":["au-act-2026-64"],"classification":"Express rule","explanation":"For prescribed subscription contracts meeting the consumer or small-business requirement, requires prescribed information at each prescribed time and in the required manner."},{"provision":"ACL sections 48G to 48H, inserted by the 2026 Act","sourceIds":["au-act-2026-64"],"classification":"Express rule","explanation":"Define consumer and small-business requirements and the standard-form-contract test for the subscription division."},{"provision":"ACL sections 18 and 29","sourceIds":["au-acl-2010"],"classification":"Current law","explanation":"May already apply to misleading subscription status, price, renewal or trial-conversion representations."}],"examples":[{"type":"Illustrative example","context":"Free trial converts to an annual charge","scenario":"A fictional fitness app promotes seven free days but places the $240 annual conversion, date and cancellation route only inside a remote terms link.","harm":"A user may enter a large recurring liability without understanding the conversion."},{"type":"Illustrative example","context":"One-off sample silently creates monthly deliveries","scenario":"A fictional shop sells a $5 sample kit but treats the order as agreement to a $45 monthly delivery without naming a subscription beside the purchase button.","harm":"A shopper may incur repeated charges after believing the transaction was one-off."},{"type":"Illustrative example","context":"Free trial with obscured annual conversion","scenario":"A fitness app promotes '7 days free' beside the commit button but places the automatic $240 annual charge and cancellation method inside a remote terms link.","harm":"The arrangement fits the initial-free-period subscription structure. From commencement, section 48D requires clear offer-stage information; the overall impression may already engage existing ACL law."},{"type":"Illustrative example","context":"Fixed term silently continues month to month","scenario":"A twelve-month service agreement continues at $85 per month unless cancelled, but the sign-up summary describes only the initial term and omits continuation and notice requirements.","harm":"The continuation structure can fall within section 48B(3), and section 48D specifically calls for period, continuation, notice and exit information."},{"type":"Enforcement example","context":"eDreams subscription pricing","scenario":"Recurring-price presentation and total annual cost. Procedural posture: Infringement notices and undertaking; admissions are contained in the undertaking, not inferred merely from notice payment.","harm":"This is verified current-ACL context, not enforcement of provisions commencing in 2027.","sourceIds":["au-accc-edreams-2026"]},{"type":"Enforcement example","context":"JustAnswer pricing representations","scenario":"A low one-off price was presented against a much larger recurring liability. Procedural posture: Federal Court orders following admissions.","harm":"This is verified current-ACL context, not enforcement of provisions commencing in 2027.","sourceIds":["au-accc-justanswer-2026"]},{"type":"Enforcement example","context":"HelloFresh and Youfoodz subscription proceedings","scenario":"Alleged subscription sign-up and cancellation representations. Procedural posture: Proceedings and allegations only in the reviewed source; no liability finding should be implied.","harm":"This is verified current-ACL context, not enforcement of provisions commencing in 2027.","sourceIds":["au-accc-hellofresh-youfoodz-2025"]}],"problematicUi":{"label":"Start 7 days free","copy":"Start 7 days free Annual conversion details are hidden in a remote document. Displayed amount $0 Review recurring terms","annotations":["Why this state matters: The final commercial state diverges from the choice represented earlier in the journey. The problematic state records: “Annual conversion details are hidden in a remote document.” Review the timing and affirmative selection needed before “$0 today” changes price, product or recurring liability. A user may enter a large recurring liability without understanding the conversion.","Review prompt: Which affirmative action authorises “$0 today”, and where is the resulting price, product or recurring state shown before commitment?"]},"improvedUi":{"label":"Start 7-day trial","copy":"Start 7-day trial $240 per year from 18 September until cancelled online. Review recurring terms $0 today Price, period and commitment The price and material terms associated with “Review recurring terms” remain beside this choice.","annotations":["Fairer design: State the later price, billing period, conversion date and exit method beside the trial action and in confirmation.","Review prompt: Place the compared prices, billing periods and material terms on one evidence sheet; where does it support “The offer creates a subscription, renewal or recurring liability”?"]},"uiComparisons":[{"id":"hidden-subscription-or-forced-continuity-scenario-1","title":"Free trial converts to an annual charge","context":"Fitness app signup","journeyStage":"Subscription","summary":"A fictional fitness app promotes seven free days but places the $240 annual conversion, date and cancellation route only inside a remote terms link.","problematic":{"label":"Start 7 days free","layout":"pricing-card","elements":[{"id":"problematic-1-heading","type":"heading","text":"Start 7 days free"},{"id":"problematic-2-body","type":"text","text":"Annual conversion details are hidden in a remote document.","tone":"warning"},{"id":"problematic-3-price","type":"price","label":"Displayed amount","amount":"$0"},{"id":"problematic-4-link","type":"link","text":"Review recurring terms","emphasis":"subtle"}],"annotations":[{"targetId":"problematic-2-body","text":"Why this state matters: The final commercial state diverges from the choice represented earlier in the journey. The problematic state records: “Annual conversion details are hidden in a remote document.” Review the timing and affirmative selection needed before “$0 today” changes price, product or recurring liability. A user may enter a large recurring liability without understanding the conversion."},{"targetId":"problematic-4-link","text":"Review prompt: Which affirmative action authorises “$0 today”, and where is the resulting price, product or recurring state shown before commitment?"}]},"neutral":{"label":"Start 7-day trial","layout":"pricing-card","elements":[{"id":"neutral-1-heading","type":"heading","text":"Start 7-day trial"},{"id":"neutral-2-body","type":"text","text":"$240 per year from 18 September until cancelled online.","tone":"default"},{"id":"neutral-3-button","type":"button","text":"Review recurring terms","emphasis":"secondary"},{"id":"neutral-4-link","type":"link","text":"$0 today","emphasis":"default"},{"id":"neutral-5-disclosure","type":"disclosure","summary":"Price, period and commitment","content":"The price and material terms associated with “Review recurring terms” remain beside this choice.","open":true}],"annotations":[{"targetId":"neutral-2-body","text":"Fairer design: State the later price, billing period, conversion date and exit method beside the trial action and in confirmation."},{"targetId":"neutral-5-disclosure","text":"Review prompt: Place the compared prices, billing periods and material terms on one evidence sheet; where does it support “The offer creates a subscription, renewal or recurring liability”?"}]},"whyItMatters":"The final commercial state diverges from the choice represented earlier in the journey. The problematic state records: “Annual conversion details are hidden in a remote document.” Review the timing and affirmative selection needed before “$0 today” changes price, product or recurring liability. A user may enter a large recurring liability without understanding the conversion.","fairDesignPrinciple":"State the later price, billing period, conversion date and exit method beside the trial action and in confirmation.","reviewPrompts":["Which affirmative action authorises “$0 today”, and where is the resulting price, product or recurring state shown before commitment?","Place the compared prices, billing periods and material terms on one evidence sheet; where does it support “The offer creates a subscription, renewal or recurring liability”?","Which specific affirmative event creates the final commercial state, and could “Recurring terms clearly and prominently disclosed before assent” explain the observed outcome instead?"],"altText":"Side-by-side fitness app signup interface showing “Start 7 days free” and the clearer alternative “Start 7-day trial”.","provenance":"Original hypothetical fitness app signup example created for this library; no real business, product or interface is depicted."},{"id":"hidden-subscription-or-forced-continuity-scenario-2","title":"One-off sample silently creates monthly deliveries","context":"Personal-care checkout","journeyStage":"Checkout","summary":"A fictional shop sells a $5 sample kit but treats the order as agreement to a $45 monthly delivery without naming a subscription beside the purchase button.","problematic":{"label":"Try the sample kit · $5","layout":"choice-list","elements":[{"id":"problematic-1-heading","type":"heading","text":"Try the sample kit · $5"},{"id":"problematic-2-body","type":"text","text":"The monthly continuation appears only after payment.","tone":"warning"},{"id":"problematic-3-radio","type":"radio","label":"Buy sample","checked":true},{"id":"problematic-4-radio","type":"radio","label":"Buy one-off sample $5","checked":false}],"annotations":[{"targetId":"problematic-2-body","text":"Why this state matters: The final commercial state diverges from the choice represented earlier in the journey. The problematic state records: “The monthly continuation appears only after payment.” Review the timing and affirmative selection needed before “Buy sample” changes price, product or recurring liability. A shopper may incur repeated charges after believing the transaction was one-off."},{"targetId":"problematic-4-radio","text":"Review prompt: Which affirmative action authorises “Buy sample”, and where is the resulting price, product or recurring state shown before commitment?"}]},"neutral":{"label":"Choose one-off or subscription","layout":"choice-list","elements":[{"id":"neutral-1-heading","type":"heading","text":"Choose one-off or subscription"},{"id":"neutral-2-body","type":"text","text":"Each option states price, cadence and whether it renews.","tone":"default"},{"id":"neutral-3-radio","type":"radio","label":"Buy one-off sample $5","checked":false},{"id":"neutral-4-radio","type":"radio","label":"Buy sample","checked":false},{"id":"neutral-5-disclosure","type":"disclosure","summary":"Choice consequences","content":"The consequence of selecting “Buy one-off sample $5” is displayed beside the option.","open":true}],"annotations":[{"targetId":"neutral-2-body","text":"Fairer design: Offer one-off and subscription choices separately with clear recurring price, cadence and ending information."},{"targetId":"neutral-5-disclosure","text":"Review prompt: Capture every peer option, its default state and visual prominence; do those states support “One or more material terms are missing, low-salience, ambiguous or late before assent”?"}]},"whyItMatters":"The final commercial state diverges from the choice represented earlier in the journey. The problematic state records: “The monthly continuation appears only after payment.” Review the timing and affirmative selection needed before “Buy sample” changes price, product or recurring liability. A shopper may incur repeated charges after believing the transaction was one-off.","fairDesignPrinciple":"Offer one-off and subscription choices separately with clear recurring price, cadence and ending information.","reviewPrompts":["Which affirmative action authorises “Buy sample”, and where is the resulting price, product or recurring state shown before commitment?","Capture every peer option, its default state and visual prominence; do those states support “One or more material terms are missing, low-salience, ambiguous or late before assent”?","Which specific affirmative event creates the final commercial state, and could “one-off purchase” explain the observed outcome instead?"],"altText":"Side-by-side personal-care checkout interface showing “Try the sample kit · $5” and the clearer alternative “Choose one-off or subscription”.","provenance":"Original hypothetical personal-care checkout example created for this library; no real business, product or interface is depicted."}],"fairAlternative":"Present every material subscription, renewal and exit term clearly before assent and satisfy current notice rules.","whyProblematic":"A transaction creates or continues recurring liability without effective, timely disclosure of the subscription, renewal and exit consequences. A free, low-cost or one-off presentation conceals the later recurring payment, conversion date or renewal state beside the action that creates it. Section 48B defines four subscription structures: indefinite recurring or continuing supply with automatic payment; fixed-period supply that continues unless stopped; an initial free period followed by automatic payment; and an initial discounted period followed by automatic payment at a higher rate. The contract must include a right to end and must not be an excluded subscription contract under section 48C. Regulations may add excluded contract kinds, disclosure matters or manners, section 48E coverage/content/times and exceptions. No such dedicated instrument had been identified by the review date.","contextFactors":["The offer creates a subscription, renewal or recurring liability.","One or more material terms are missing, low-salience, ambiguous or late before assent.","The user can incur continued payment or commitment.","Boundary to test: Recurring terms clearly and prominently disclosed before assent","Boundary to test: A clearly presented one-off purchase with no continuing payment or renewal consequence","Boundary to test: Cancellation friction without an offer-disclosure defect","Boundary to test: A continuing service that creates no automatic payment, renewal or post-trial liability","Does the arrangement fit one of section 48B's four structures?","Does a section 48C exclusion or later prescribed exclusion apply?","Is subscription status stated rather than left to inference?","Are actual payment liabilities and billing periods prominent before agreement?","Are trial conversion, renewal, continuation, notice and exit consequences explained together?","Does the contract meet the consumer or small-business requirement for sections 48E and 48F?","Is the contract new, renewed, continued or varied after commencement?"],"affectedTeams":["Product","Design","Engineering","Billing","Marketing","Legal","Customer Support","Finance"],"reviewQuestions":["Which affirmative action authorises “$0 today”, and where is the resulting price, product or recurring state shown before commitment?","Place the compared prices, billing periods and material terms on one evidence sheet; where does it support “The offer creates a subscription, renewal or recurring liability”?","Which specific affirmative event creates the final commercial state, and could “Recurring terms clearly and prominently disclosed before assent” explain the observed outcome instead?","Which affirmative action authorises “Buy sample”, and where is the resulting price, product or recurring state shown before commitment?","Capture every peer option, its default state and visual prominence; do those states support “One or more material terms are missing, low-salience, ambiguous or late before assent”?","Which specific affirmative event creates the final commercial state, and could “one-off purchase” explain the observed outcome instead?","Which section 48B structure, if any, describes each product?","Has every section 48C exclusion and regulation hook been checked?","Can a subscriber identify the actual next charge, billing period and date before agreeing?","Do the headline, price tile, button and terms tell a consistent story?","Which contracts meet the consumer or small-business requirement?","Can notification timing be configured once regulations are made?","How will renewals, continuations and variations of pre-commencement contracts be identified?"],"evidence":["contract-type and exclusion register","pre-contract disclosure matrix","annotated sign-up screenshots and call scripts","billing-event and trial-conversion specification","contract-version and transition inventory","configurable notification rules and delivery logs","complaints, refunds and chargeback analysis","regulation recheck record","Annotated subscription and checkout screenshots at each responsive breakpoint","The complete state sequence before, during and after the consumer decision","Design-system component, content, default and configuration records for the reviewed release","Operational records substantiating price, availability, timing and eligibility claims","Usability, accessibility, reversal, complaint and support evidence relevant to consumer impact","A dated product and legal review record identifying evidence, uncertainties and release decisions"],"related":["bait-and-switch","drip-pricing-and-mandatory-fees","negative-option-or-unauthorised-transaction","sneak-into-basket"],"sourceIds":["oecd-dark-commercial-patterns-2022","au-act-2026-64","au-acl-2010","au-accc-edreams-2026","au-accc-justanswer-2026","au-accc-hellofresh-youfoodz-2025","au-treasury-announcement-2026"],"altText":"Side-by-side fitness app signup interface showing “Start 7 days free” and the clearer alternative “Start 7-day trial”.","provenance":"Original hypothetical interface comparisons from the shared learning library, adapted to Australian-dollar context for this portal; no real business, product or interface is depicted.","author":"Flowlane","datePublished":"2026-08-09","dateModified":"2026-09-14","lastReviewed":"2026-09-14","changeNote":"Source comparison recorded and the current status restated."},{"title":"Negative option or unauthorised transaction","slug":"negative-option-or-unauthorised-transaction","preferredName":"Negative option or unauthorised transaction","directAnswer":"Negative option or unauthorised transaction is a working label for this design mechanism: Silence, inactivity or an ineffective prior interaction is treated as authorisation for a paid or consequential transaction. This is editorial implementation guidance for Australian journeys, not a finding of unlawfulness. From 1 July 2027, a similar interface is relevant to ACL section 28B only if the complete consumer-connection, manipulation or unreasonable-distortion and actual-or-likely-detriment test is met. Current ACL rules require a separate assessment.","definition":"Silence, inactivity or an ineffective prior interaction is treated as authorisation for a paid or consequential transaction. This is a design and research taxonomy for learning and evidence review, not a statutory offence label or an automatic finding that an interface is unlawful.","synonyms":["inertia selling","silence as consent","unauthorised renewal","charge unless user opts out","paid conversion without valid assent","post-trial transaction without effective notice","service supplied and billed without request"],"category":"Sneaking","family":"Sneaking","journeyStages":["Subscription","Cancellation"],"jurisdiction":"Australia","status":"Editorial implementation guidance","howItWorks":"Silence, inactivity or an ineffective prior interaction is treated as authorisation for a paid or consequential transaction. Silence, a failed refusal or another non-affirmative event is interpreted as permission for a new charge, product or continuing commercial state.","warningSigns":["A charge, supply or commitment occurs or is scheduled.","No clear current assent to that consequence is evidenced.","The design relies on non-response, hidden default or ambiguous prior wording."],"harms":["Inactivity may produce a charge that the subscriber never actively authorised.","A person can be charged despite attempting to refuse the transaction through the supplied route."],"legitimateUses":["Clearly disclosed subscription renewal supported by valid assent and applicable notices","transaction explicitly confirmed at the material decision point","purely free continuation with no material consequence"],"legalBasis":[{"provision":"ACL section 28B, inserted by the 2026 Act","sourceIds":["au-act-2026-64"],"classification":"Possible risk indicator","explanation":"In subscription and cancellation journeys, the negative option or unauthorised transaction mechanism may warrant review where it manipulates a consumer or unreasonably distorts the decision environment and causes, or is likely to cause, detriment. The sneaking label and an interface similarity do not establish a contravention; the complete section 28B test, scope, facts and evidence must be applied from 1 July 2027."},{"provision":"Dark-pattern research taxonomy","sourceIds":["gray-ontology-dark-patterns-2024"],"classification":"Editorial analysis","explanation":"The cited research sources support this working pattern within the sneaking family. It is editorial implementation guidance, not an Australian statutory category, regulator finding or legal safe harbour."}],"examples":[{"type":"Illustrative example","context":"Silence treated as renewal approval","scenario":"A fictional service states that failing to reply to an email will be treated as approval for a new paid add-on at renewal.","harm":"Inactivity may produce a charge that the subscriber never actively authorised."},{"type":"Illustrative example","context":"Broken opt-out still results in a charge","scenario":"A fictional trial email provides an opt-out link that returns an error, then charges the customer because the failed request is recorded as no response.","harm":"A person can be charged despite attempting to refuse the transaction through the supplied route."}],"problematicUi":{"label":"Upgrade at renewal","copy":"Upgrade at renewal No reply is treated as acceptance of a $60 add-on. No action means yes Keep current plan","annotations":["Why this state matters: The final commercial state diverges from the choice represented earlier in the journey. The problematic state records: “No reply is treated as acceptance of a $60 add-on.” Review the timing and affirmative selection needed before “No action means yes” changes price, product or recurring liability. Inactivity may produce a charge that the subscriber never actively authorised.","Review prompt: Which affirmative action authorises “No action means yes”, and where is the resulting price, product or recurring state shown before commitment?"]},"improvedUi":{"label":"Optional renewal upgrade","copy":"Optional renewal upgrade The add-on remains off unless the subscriber selects it. Keep current plan No action means yes Choice consequences The consequence of selecting “Keep current plan” is displayed beside the option.","annotations":["Fairer design: Do not treat silence as a new purchase; request a clear choice and preserve the existing contract if none is made.","Review prompt: Capture every peer option, its default state and visual prominence; do those states support “A charge, supply or commitment occurs or is scheduled”?"]},"uiComparisons":[{"id":"negative-option-or-unauthorised-transaction-scenario-1","title":"Silence treated as renewal approval","context":"Annual service renewal","journeyStage":"Subscription","summary":"A fictional service states that failing to reply to an email will be treated as approval for a new paid add-on at renewal.","problematic":{"label":"Upgrade at renewal","layout":"choice-list","elements":[{"id":"problematic-1-heading","type":"heading","text":"Upgrade at renewal"},{"id":"problematic-2-body","type":"text","text":"No reply is treated as acceptance of a $60 add-on.","tone":"warning"},{"id":"problematic-3-radio","type":"radio","label":"No action means yes","checked":true},{"id":"problematic-4-radio","type":"radio","label":"Keep current plan","checked":false}],"annotations":[{"targetId":"problematic-2-body","text":"Why this state matters: The final commercial state diverges from the choice represented earlier in the journey. The problematic state records: “No reply is treated as acceptance of a $60 add-on.” Review the timing and affirmative selection needed before “No action means yes” changes price, product or recurring liability. Inactivity may produce a charge that the subscriber never actively authorised."},{"targetId":"problematic-4-radio","text":"Review prompt: Which affirmative action authorises “No action means yes”, and where is the resulting price, product or recurring state shown before commitment?"}]},"neutral":{"label":"Optional renewal upgrade","layout":"choice-list","elements":[{"id":"neutral-1-heading","type":"heading","text":"Optional renewal upgrade"},{"id":"neutral-2-body","type":"text","text":"The add-on remains off unless the subscriber selects it.","tone":"default"},{"id":"neutral-3-radio","type":"radio","label":"Keep current plan","checked":false},{"id":"neutral-4-radio","type":"radio","label":"No action means yes","checked":false},{"id":"neutral-5-disclosure","type":"disclosure","summary":"Choice consequences","content":"The consequence of selecting “Keep current plan” is displayed beside the option.","open":true}],"annotations":[{"targetId":"neutral-2-body","text":"Fairer design: Do not treat silence as a new purchase; request a clear choice and preserve the existing contract if none is made."},{"targetId":"neutral-5-disclosure","text":"Review prompt: Capture every peer option, its default state and visual prominence; do those states support “A charge, supply or commitment occurs or is scheduled”?"}]},"whyItMatters":"The final commercial state diverges from the choice represented earlier in the journey. The problematic state records: “No reply is treated as acceptance of a $60 add-on.” Review the timing and affirmative selection needed before “No action means yes” changes price, product or recurring liability. Inactivity may produce a charge that the subscriber never actively authorised.","fairDesignPrinciple":"Do not treat silence as a new purchase; request a clear choice and preserve the existing contract if none is made.","reviewPrompts":["Which affirmative action authorises “No action means yes”, and where is the resulting price, product or recurring state shown before commitment?","Capture every peer option, its default state and visual prominence; do those states support “A charge, supply or commitment occurs or is scheduled”?","Which specific affirmative event creates the final commercial state, and could “Clearly disclosed subscription renewal supported by valid assent and applicable notices” explain the observed outcome instead?"],"altText":"Side-by-side annual service renewal interface showing “Upgrade at renewal” and the clearer alternative “Optional renewal upgrade”.","provenance":"Original hypothetical annual service renewal example created for this library; no real business, product or interface is depicted."},{"id":"negative-option-or-unauthorised-transaction-scenario-2","title":"Broken opt-out still results in a charge","context":"Subscription extension","journeyStage":"Cancellation","summary":"A fictional trial email provides an opt-out link that returns an error, then charges the customer because the failed request is recorded as no response.","problematic":{"label":"Keep your trial benefits","layout":"cancellation-flow","elements":[{"id":"problematic-1-heading","type":"heading","text":"Keep your trial benefits"},{"id":"problematic-2-body","type":"text","text":"The opt-out link errors and the system interprets failure as acceptance.","tone":"warning"},{"id":"problematic-3-step","type":"step","label":"Blocking step"},{"id":"problematic-4-step","type":"step","label":"Obscured outcome"}],"annotations":[{"targetId":"problematic-2-body","text":"Why this state matters: The final commercial state diverges from the choice represented earlier in the journey. The problematic state records: “The opt-out link errors and the system interprets failure as acceptance.” Review the timing and affirmative selection needed before “No response recorded” changes price, product or recurring liability. A person can be charged despite attempting to refuse the transaction through the supplied route."},{"targetId":"problematic-4-step","text":"Review prompt: Which affirmative action authorises “No response recorded”, and where is the resulting price, product or recurring state shown before commitment?"}]},"neutral":{"label":"Your opt-out is recorded","layout":"cancellation-flow","elements":[{"id":"neutral-1-heading","type":"heading","text":"Your opt-out is recorded"},{"id":"neutral-2-body","type":"text","text":"The request receives a timestamped receipt and no renewal charge is created.","tone":"default"},{"id":"neutral-3-step","type":"step","label":"Completion step"},{"id":"neutral-4-step","type":"step","label":"Recorded outcome"},{"id":"neutral-5-badge","type":"badge","text":"Request recorded: Download opt-out receipt","tone":"default"}],"annotations":[{"targetId":"neutral-2-body","text":"Fairer design: Make the refusal route reliable, record attempted requests and suspend charging when the service cannot confirm the choice."},{"targetId":"neutral-5-badge","text":"Review prompt: Count steps, waits, offers and channel changes through final confirmation; where does the route meet “No clear current assent to that consequence is evidenced”?"}]},"whyItMatters":"The final commercial state diverges from the choice represented earlier in the journey. The problematic state records: “The opt-out link errors and the system interprets failure as acceptance.” Review the timing and affirmative selection needed before “No response recorded” changes price, product or recurring liability. A person can be charged despite attempting to refuse the transaction through the supplied route.","fairDesignPrinciple":"Make the refusal route reliable, record attempted requests and suspend charging when the service cannot confirm the choice.","reviewPrompts":["Which affirmative action authorises “No response recorded”, and where is the resulting price, product or recurring state shown before commitment?","Count steps, waits, offers and channel changes through final confirmation; where does the route meet “No clear current assent to that consequence is evidenced”?","Which specific affirmative event creates the final commercial state, and could “transaction explicitly confirmed at the material decision point” explain the observed outcome instead?"],"altText":"Side-by-side subscription extension interface showing “Keep your trial benefits” and the clearer alternative “Your opt-out is recorded”.","provenance":"Original hypothetical subscription extension example created for this library; no real business, product or interface is depicted."}],"fairAlternative":"Obtain clear, specific assent before any paid consequence and do not treat silence or inactivity as a new authorisation.","whyProblematic":"Silence, inactivity or an ineffective prior interaction is treated as authorisation for a paid or consequential transaction. Silence, a failed refusal or another non-affirmative event is interpreted as permission for a new charge, product or continuing commercial state. These harms describe a review risk, not an automatic legal conclusion. Australian section 28B commences on 1 July 2027 and requires its complete, context-specific test. Existing ACL provisions remain a separate current-law assessment.","contextFactors":["A charge, supply or commitment occurs or is scheduled.","No clear current assent to that consequence is evidenced.","The design relies on non-response, hidden default or ambiguous prior wording.","Boundary to test: Clearly disclosed subscription renewal supported by valid assent and applicable notices","Boundary to test: transaction explicitly confirmed at the material decision point","Boundary to test: purely free continuation with no material consequence"],"affectedTeams":["Product","Design","Engineering","Legal","Compliance"],"reviewQuestions":["Which affirmative action authorises “No action means yes”, and where is the resulting price, product or recurring state shown before commitment?","Capture every peer option, its default state and visual prominence; do those states support “A charge, supply or commitment occurs or is scheduled”?","Which specific affirmative event creates the final commercial state, and could “Clearly disclosed subscription renewal supported by valid assent and applicable notices” explain the observed outcome instead?","Which affirmative action authorises “No response recorded”, and where is the resulting price, product or recurring state shown before commitment?","Count steps, waits, offers and channel changes through final confirmation; where does the route meet “No clear current assent to that consequence is evidenced”?","Which specific affirmative event creates the final commercial state, and could “transaction explicitly confirmed at the material decision point” explain the observed outcome instead?"],"evidence":["Annotated subscription and cancellation screenshots at each responsive breakpoint","The complete state sequence before, during and after the consumer decision","Design-system component, content, default and configuration records for the reviewed release","Operational records substantiating price, availability, timing and eligibility claims","Usability, accessibility, reversal, complaint and support evidence relevant to consumer impact","A dated product and legal review record identifying evidence, uncertainties and release decisions"],"related":["bait-and-switch","drip-pricing-and-mandatory-fees","subscription-traps-and-automatic-renewal","sneak-into-basket"],"sourceIds":["gray-ontology-dark-patterns-2024","au-act-2026-64"],"altText":"Side-by-side annual service renewal interface showing “Upgrade at renewal” and the clearer alternative “Optional renewal upgrade”.","provenance":"Original hypothetical interface comparisons from the shared learning library, adapted to Australian-dollar context for this portal; no real business, product or interface is depicted.","author":"Flowlane","datePublished":"2026-08-10","dateModified":"2026-09-14","lastReviewed":"2026-09-14","changeNote":"Source comparison recorded and the current status restated."},{"title":"Sneak into basket","slug":"sneak-into-basket","preferredName":"Sneak into basket","directAnswer":"Sneak into basket is a working label for this design mechanism: A paid or consequential item is added to a basket or transaction without a clear, deliberate and specific user choice. This is editorial implementation guidance for Australian journeys, not a finding of unlawfulness. From 1 July 2027, a similar interface is relevant to ACL section 28B only if the complete consumer-connection, manipulation or unreasonable-distortion and actual-or-likely-detriment test is met. Current ACL rules require a separate assessment.","definition":"A paid or consequential item is added to a basket or transaction without a clear, deliberate and specific user choice. This is a design and research taxonomy for learning and evidence review, not a statutory offence label or an automatic finding that an interface is unlawful.","synonyms":["automatic add-on","sneak into cart","insurance automatically added","donation inserted","accessory added by default","quantity increased without deliberate selection"],"category":"Sneaking","family":"Sneaking","journeyStages":["Checkout"],"jurisdiction":"Australia","status":"Editorial implementation guidance","howItWorks":"A paid or consequential item is added to a basket or transaction without a clear, deliberate and specific user choice. An item or donation enters or re-enters the basket without a current add action, so the payable state changes independently of the shopper’s recorded choice.","warningSigns":["A line item or quantity appears after a transition.","No preceding deliberate action specifically selected that item or quantity.","The addition creates cost, commitment or another material consequence."],"harms":["The shopper may pay an additional amount that was never deliberately added.","A removed item can re-enter the transaction and create an unintended charge."],"legitimateUses":["Tax or unavoidable charge represented separately","user-selected bundle whose included items were clearly disclosed","free non-consequential item"],"legalBasis":[{"provision":"ACL section 28B, inserted by the 2026 Act","sourceIds":["au-act-2026-64"],"classification":"Possible risk indicator","explanation":"In checkout journeys, the sneak into basket mechanism may warrant review where it manipulates a consumer or unreasonably distorts the decision environment and causes, or is likely to cause, detriment. The sneaking label and an interface similarity do not establish a contravention; the complete section 28B test, scope, facts and evidence must be applied from 1 July 2027."},{"provision":"Dark-pattern research taxonomy","sourceIds":["oecd-dark-commercial-patterns-2022"],"classification":"Editorial analysis","explanation":"The cited research sources support this working pattern within the sneaking family. It is editorial implementation guidance, not an Australian statutory category, regulator finding or legal safe harbour."}],"examples":[{"type":"Illustrative example","context":"Donation added without a deliberate choice","scenario":"A fictional grocery service inserts a $2 charity donation into the basket when the shopper chooses a delivery slot, without showing a selection control.","harm":"The shopper may pay an additional amount that was never deliberately added."},{"type":"Illustrative example","context":"Removed accessory returns after cart refresh","scenario":"A fictional store adds a cable bundle to a laptop order, lets the shopper remove it, then silently restores it when the delivery postcode changes.","harm":"A removed item can re-enter the transaction and create an unintended charge."}],"problematicUi":{"label":"Order total · $64","copy":"Order total · $64 A $2 donation appears after delivery selection without an add action. Donation included Add $2 donation","annotations":["Why this state matters: The final commercial state diverges from the choice represented earlier in the journey. The problematic state records: “A $2 donation appears after delivery selection without an add action.” Review the timing and affirmative selection needed before “Donation included” changes price, product or recurring liability. The shopper may pay an additional amount that was never deliberately added.","Review prompt: Which affirmative action authorises “Donation included”, and where is the resulting price, product or recurring state shown before commitment?"]},"improvedUi":{"label":"Order total · $62","copy":"Order total · $62 Donation choices are optional, unselected and visible before the total changes. Amount affected $2 Add $2 donation Donation included Payable total and selected items The summary shows the line items and total before “Add $2 donation” is activated.","annotations":["Fairer design: Leave donations out of the basket until the shopper selects a clearly priced option.","Review prompt: Compare the basket before and after the action, including total and line items; does the mutation satisfy “A line item or quantity appears after a transition”?"]},"uiComparisons":[{"id":"sneak-into-basket-scenario-1","title":"Donation added without a deliberate choice","context":"Grocery checkout","journeyStage":"Checkout","summary":"A fictional grocery service inserts a $2 charity donation into the basket when the shopper chooses a delivery slot, without showing a selection control.","problematic":{"label":"Order total · $64","layout":"checkout-summary","elements":[{"id":"problematic-1-heading","type":"heading","text":"Order total · $64"},{"id":"problematic-2-body","type":"text","text":"A $2 donation appears after delivery selection without an add action.","tone":"warning"},{"id":"problematic-3-badge","type":"badge","text":"Donation included","tone":"warning"},{"id":"problematic-4-link","type":"link","text":"Add $2 donation","emphasis":"subtle"}],"annotations":[{"targetId":"problematic-2-body","text":"Why this state matters: The final commercial state diverges from the choice represented earlier in the journey. The problematic state records: “A $2 donation appears after delivery selection without an add action.” Review the timing and affirmative selection needed before “Donation included” changes price, product or recurring liability. The shopper may pay an additional amount that was never deliberately added."},{"targetId":"problematic-4-link","text":"Review prompt: Which affirmative action authorises “Donation included”, and where is the resulting price, product or recurring state shown before commitment?"}]},"neutral":{"label":"Order total · $62","layout":"checkout-summary","elements":[{"id":"neutral-1-heading","type":"heading","text":"Order total · $62"},{"id":"neutral-2-body","type":"text","text":"Donation choices are optional, unselected and visible before the total changes.","tone":"default"},{"id":"neutral-3-price","type":"price","label":"Amount affected","amount":"$2"},{"id":"neutral-4-button","type":"button","text":"Add $2 donation","emphasis":"secondary"},{"id":"neutral-5-link","type":"link","text":"Donation included","emphasis":"default"},{"id":"neutral-6-disclosure","type":"disclosure","summary":"Payable total and selected items","content":"The summary shows the line items and total before “Add $2 donation” is activated.","open":true}],"annotations":[{"targetId":"neutral-2-body","text":"Fairer design: Leave donations out of the basket until the shopper selects a clearly priced option."},{"targetId":"neutral-6-disclosure","text":"Review prompt: Compare the basket before and after the action, including total and line items; does the mutation satisfy “A line item or quantity appears after a transition”?"}]},"whyItMatters":"The final commercial state diverges from the choice represented earlier in the journey. The problematic state records: “A $2 donation appears after delivery selection without an add action.” Review the timing and affirmative selection needed before “Donation included” changes price, product or recurring liability. The shopper may pay an additional amount that was never deliberately added.","fairDesignPrinciple":"Leave donations out of the basket until the shopper selects a clearly priced option.","reviewPrompts":["Which affirmative action authorises “Donation included”, and where is the resulting price, product or recurring state shown before commitment?","Compare the basket before and after the action, including total and line items; does the mutation satisfy “A line item or quantity appears after a transition”?","Which specific affirmative event creates the final commercial state, and could “Tax or unavoidable charge represented separately” explain the observed outcome instead?"],"altText":"Side-by-side grocery checkout interface showing “Order total · $64” and the clearer alternative “Order total · $62”.","provenance":"Original hypothetical grocery checkout example created for this library; no real business, product or interface is depicted."},{"id":"sneak-into-basket-scenario-2","title":"Removed accessory returns after cart refresh","context":"Electronics basket","journeyStage":"Checkout","summary":"A fictional store adds a cable bundle to a laptop order, lets the shopper remove it, then silently restores it when the delivery postcode changes.","problematic":{"label":"Updated order · $829","layout":"checkout-summary","elements":[{"id":"problematic-1-heading","type":"heading","text":"Updated order · $829"},{"id":"problematic-2-body","type":"text","text":"The $30 cable bundle returns after a postcode edit.","tone":"warning"},{"id":"problematic-3-badge","type":"badge","text":"Accessory restored","tone":"warning"},{"id":"problematic-4-link","type":"link","text":"Add cable bundle $30","emphasis":"subtle"}],"annotations":[{"targetId":"problematic-2-body","text":"Why this state matters: The final commercial state diverges from the choice represented earlier in the journey. The problematic state records: “The $30 cable bundle returns after a postcode edit.” Review the timing and affirmative selection needed before “Accessory restored” changes price, product or recurring liability. A removed item can re-enter the transaction and create an unintended charge."},{"targetId":"problematic-4-link","text":"Review prompt: Which affirmative action authorises “Accessory restored”, and where is the resulting price, product or recurring state shown before commitment?"}]},"neutral":{"label":"Updated order · $799","layout":"checkout-summary","elements":[{"id":"neutral-1-heading","type":"heading","text":"Updated order · $799"},{"id":"neutral-2-body","type":"text","text":"The shopper’s removal persists through recalculation.","tone":"default"},{"id":"neutral-3-price","type":"price","label":"Amount affected","amount":"$30"},{"id":"neutral-4-button","type":"button","text":"Add cable bundle $30","emphasis":"secondary"},{"id":"neutral-5-link","type":"link","text":"Accessory restored","emphasis":"default"},{"id":"neutral-6-disclosure","type":"disclosure","summary":"Payable total and selected items","content":"The summary shows the line items and total before “Add cable bundle $30” is activated.","open":true}],"annotations":[{"targetId":"neutral-2-body","text":"Fairer design: Persist removal across all cart updates and require a new deliberate add action before restoring an accessory."},{"targetId":"neutral-6-disclosure","text":"Review prompt: Compare the basket before and after the action, including total and line items; does the mutation satisfy “No preceding deliberate action specifically selected that item or quantity”?"}]},"whyItMatters":"The final commercial state diverges from the choice represented earlier in the journey. The problematic state records: “The $30 cable bundle returns after a postcode edit.” Review the timing and affirmative selection needed before “Accessory restored” changes price, product or recurring liability. A removed item can re-enter the transaction and create an unintended charge.","fairDesignPrinciple":"Persist removal across all cart updates and require a new deliberate add action before restoring an accessory.","reviewPrompts":["Which affirmative action authorises “Accessory restored”, and where is the resulting price, product or recurring state shown before commitment?","Compare the basket before and after the action, including total and line items; does the mutation satisfy “No preceding deliberate action specifically selected that item or quantity”?","Which specific affirmative event creates the final commercial state, and could “user-selected bundle whose included items were clearly disclosed” explain the observed outcome instead?"],"altText":"Side-by-side electronics basket interface showing “Updated order · $829” and the clearer alternative “Updated order · $799”.","provenance":"Original hypothetical electronics basket example created for this library; no real business, product or interface is depicted."}],"fairAlternative":"Add an item only after a deliberate selection, preserve removal through every recalculation and show the updated line item and total before commitment.","whyProblematic":"A paid or consequential item is added to a basket or transaction without a clear, deliberate and specific user choice. An item or donation enters or re-enters the basket without a current add action, so the payable state changes independently of the shopper’s recorded choice. These harms describe a review risk, not an automatic legal conclusion. Australian section 28B commences on 1 July 2027 and requires its complete, context-specific test. Existing ACL provisions remain a separate current-law assessment.","contextFactors":["A line item or quantity appears after a transition.","No preceding deliberate action specifically selected that item or quantity.","The addition creates cost, commitment or another material consequence.","Boundary to test: Tax or unavoidable charge represented separately","Boundary to test: user-selected bundle whose included items were clearly disclosed","Boundary to test: free non-consequential item"],"affectedTeams":["Product","Design","Engineering","Legal","Compliance"],"reviewQuestions":["Which affirmative action authorises “Donation included”, and where is the resulting price, product or recurring state shown before commitment?","Compare the basket before and after the action, including total and line items; does the mutation satisfy “A line item or quantity appears after a transition”?","Which specific affirmative event creates the final commercial state, and could “Tax or unavoidable charge represented separately” explain the observed outcome instead?","Which affirmative action authorises “Accessory restored”, and where is the resulting price, product or recurring state shown before commitment?","Compare the basket before and after the action, including total and line items; does the mutation satisfy “No preceding deliberate action specifically selected that item or quantity”?","Which specific affirmative event creates the final commercial state, and could “user-selected bundle whose included items were clearly disclosed” explain the observed outcome instead?"],"evidence":["Annotated checkout screenshots at each responsive breakpoint","The complete state sequence before, during and after the consumer decision","Design-system component, content, default and configuration records for the reviewed release","Operational records substantiating price, availability, timing and eligibility claims","Usability, accessibility, reversal, complaint and support evidence relevant to consumer impact","A dated product and legal review record identifying evidence, uncertainties and release decisions"],"related":["bait-and-switch","drip-pricing-and-mandatory-fees","subscription-traps-and-automatic-renewal","negative-option-or-unauthorised-transaction"],"sourceIds":["oecd-dark-commercial-patterns-2022","au-act-2026-64"],"altText":"Side-by-side grocery checkout interface showing “Order total · $64” and the clearer alternative “Order total · $62”.","provenance":"Original hypothetical interface comparisons from the shared learning library, adapted to Australian-dollar context for this portal; no real business, product or interface is depicted.","author":"Flowlane","datePublished":"2026-08-10","dateModified":"2026-09-14","lastReviewed":"2026-09-14","changeNote":"Source comparison recorded and the current status restated."},{"title":"Activity messages","slug":"activity-messages","preferredName":"Activity messages","directAnswer":"Activity messages is a working label for this design mechanism: Claims about recent or current actions by other users are used to steer the decision, particularly where authenticity, timing or relevance is unsupported. This is editorial implementation guidance for Australian journeys, not a finding of unlawfulness. From 1 July 2027, a similar interface is relevant to ACL section 28B only if the complete consumer-connection, manipulation or unreasonable-distortion and actual-or-likely-detriment test is met. Current ACL rules require a separate assessment.","definition":"Claims about recent or current actions by other users are used to steer the decision, particularly where authenticity, timing or relevance is unsupported. This is a design and research taxonomy for learning and evidence review, not a statutory offence label or an automatic finding that an interface is unlawful.","synonyms":["recent activity","live purchase notification","someone just bought","viewers right now","recent booking popup","location-based activity claim"],"category":"Social proof","family":"Social proof","journeyStages":["Pricing"],"jurisdiction":"Australia","status":"Editorial implementation guidance","howItWorks":"Claims about recent or current actions by other users are used to steer the decision, particularly where authenticity, timing or relevance is unsupported. Purported recent behaviour is used as live social evidence even though the event, person, count or period does not correspond to the represented activity.","warningSigns":["The message describes actions by other people as current or recent.","It appears near a transactional choice or repeatedly interrupts it.","Provenance or freshness must be externally verified before alleging falsity."],"harms":["Unsupported activity can create false confidence and urgency around the purchase.","A visitor may infer genuine recent participation and social confidence from activity that never occurred."],"legitimateUses":["Static aggregate popularity claim","A named testimonial whose speaker, relationship and non-live character are clearly stated","Verifiable operational status unrelated to persuasion","A clearly historical activity figure whose period and non-live character are stated beside it"],"legalBasis":[{"provision":"ACL section 28B, inserted by the 2026 Act","sourceIds":["au-act-2026-64"],"classification":"Possible risk indicator","explanation":"In pricing journeys, the activity messages mechanism may warrant review where it manipulates a consumer or unreasonably distorts the decision environment and causes, or is likely to cause, detriment. The social proof label and an interface similarity do not establish a contravention; the complete section 28B test, scope, facts and evidence must be applied from 1 July 2027."},{"provision":"Dark-pattern research taxonomy","sourceIds":["oecd-dark-commercial-patterns-2022"],"classification":"Editorial analysis","explanation":"The cited research sources support this working pattern within the social proof family. It is editorial implementation guidance, not an Australian statutory category, regulator finding or legal safe harbour."}],"examples":[{"type":"Illustrative example","context":"Randomised recent-purchase notification","scenario":"A fictional store displays “12 people bought this in the last hour” using a random number unrelated to completed orders.","harm":"Unsupported activity can create false confidence and urgency around the purchase."},{"type":"Illustrative example","context":"Fabricated named signup notification","scenario":"A fictional course page rotates messages such as “Mia from Berlin just enrolled” using invented names and locations rather than completed enrolments.","harm":"A visitor may infer genuine recent participation and social confidence from activity that never occurred."}],"problematicUi":{"label":"Popular right now","copy":"Popular right now A generated number is presented as recent customer activity. 12 bought this hour Claim basis No supporting population, period, inventory or offer event is presented with this message.","annotations":["Why this state matters: The interface asks the user to rely on other people’s behaviour or approval. The cue “12 bought this hour” has persuasive meaning only if its population, period, metric and relationship match the represented claim. The panel instead says: “A generated number is presented as recent customer activity.” Unsupported activity can create false confidence and urgency around the purchase.","Review prompt: Which source record substantiates “12 bought this hour”, including its population, period, metric and any commercial relationship?"]},"improvedUi":{"label":"Verified activity information","copy":"Verified activity information The message states its period and is shown only when live order data supports it. 8 purchases in the past 24 hours Claim basis The relevant population, period, inventory or offer state is presented with the message. View the source and period for “8 purchases in the past 24 hours”","annotations":["Fairer design: Use activity messages only when they are accurate, timely, relevant and supported by a defined data source.","Review prompt: Record the claim, timestamp, data source and post-claim state; which evidence supports “The message describes actions by other people as current or recent”?"]},"uiComparisons":[{"id":"activity-messages-scenario-1","title":"Randomised recent-purchase notification","context":"Product page","journeyStage":"Pricing","summary":"A fictional store displays “12 people bought this in the last hour” using a random number unrelated to completed orders.","problematic":{"label":"Popular right now","layout":"banner","elements":[{"id":"problematic-1-heading","type":"heading","text":"Popular right now"},{"id":"problematic-2-body","type":"text","text":"A generated number is presented as recent customer activity.","tone":"warning"},{"id":"problematic-3-badge","type":"badge","text":"12 bought this hour","tone":"warning"},{"id":"problematic-4-disclosure","type":"disclosure","summary":"Claim basis","content":"No supporting population, period, inventory or offer event is presented with this message.","open":false}],"annotations":[{"targetId":"problematic-2-body","text":"Why this state matters: The interface asks the user to rely on other people’s behaviour or approval. The cue “12 bought this hour” has persuasive meaning only if its population, period, metric and relationship match the represented claim. The panel instead says: “A generated number is presented as recent customer activity.” Unsupported activity can create false confidence and urgency around the purchase."},{"targetId":"problematic-4-disclosure","text":"Review prompt: Which source record substantiates “12 bought this hour”, including its population, period, metric and any commercial relationship?"}]},"neutral":{"label":"Verified activity information","layout":"banner","elements":[{"id":"neutral-1-heading","type":"heading","text":"Verified activity information"},{"id":"neutral-2-body","type":"text","text":"The message states its period and is shown only when live order data supports it.","tone":"default"},{"id":"neutral-3-badge","type":"badge","text":"8 purchases in the past 24 hours","tone":"default"},{"id":"neutral-4-disclosure","type":"disclosure","summary":"Claim basis","content":"The relevant population, period, inventory or offer state is presented with the message.","open":true},{"id":"neutral-5-link","type":"link","text":"View the source and period for “8 purchases in the past 24 hours”","emphasis":"default"}],"annotations":[{"targetId":"neutral-2-body","text":"Fairer design: Use activity messages only when they are accurate, timely, relevant and supported by a defined data source."},{"targetId":"neutral-5-link","text":"Review prompt: Record the claim, timestamp, data source and post-claim state; which evidence supports “The message describes actions by other people as current or recent”?"}]},"whyItMatters":"The interface asks the user to rely on other people’s behaviour or approval. The cue “12 bought this hour” has persuasive meaning only if its population, period, metric and relationship match the represented claim. The panel instead says: “A generated number is presented as recent customer activity.” Unsupported activity can create false confidence and urgency around the purchase.","fairDesignPrinciple":"Use activity messages only when they are accurate, timely, relevant and supported by a defined data source.","reviewPrompts":["Which source record substantiates “12 bought this hour”, including its population, period, metric and any commercial relationship?","Record the claim, timestamp, data source and post-claim state; which evidence supports “The message describes actions by other people as current or recent”?","Can the claim be reproduced from a defined population and period, or does the evidence instead fit “Static aggregate popularity claim”?"],"altText":"Side-by-side product page interface showing “Popular right now” and the clearer alternative “Verified activity information”.","provenance":"Original hypothetical product page example created for this library; no real business, product or interface is depicted."},{"id":"activity-messages-scenario-2","title":"Fabricated named signup notification","context":"Course landing page","journeyStage":"Pricing","summary":"A fictional course page rotates messages such as “Mia from Berlin just enrolled” using invented names and locations rather than completed enrolments.","problematic":{"label":"New learner joined","layout":"banner","elements":[{"id":"problematic-1-heading","type":"heading","text":"New learner joined"},{"id":"problematic-2-body","type":"text","text":"Invented names and cities are presented as completed enrolment events.","tone":"warning"},{"id":"problematic-3-badge","type":"badge","text":"Mia from Berlin enrolled","tone":"warning"},{"id":"problematic-4-disclosure","type":"disclosure","summary":"Claim basis","content":"No supporting population, period, inventory or offer event is presented with this message.","open":false}],"annotations":[{"targetId":"problematic-2-body","text":"Why this state matters: The interface asks the user to rely on other people’s behaviour or approval. The cue “Mia from Berlin enrolled” has persuasive meaning only if its population, period, metric and relationship match the represented claim. The panel instead says: “Invented names and cities are presented as completed enrolment events.” A visitor may infer genuine recent participation and social confidence from activity that never occurred."},{"targetId":"problematic-4-disclosure","text":"Review prompt: Which source record substantiates “Mia from Berlin enrolled”, including its population, period, metric and any commercial relationship?"}]},"neutral":{"label":"Course participation","layout":"banner","elements":[{"id":"neutral-1-heading","type":"heading","text":"Course participation"},{"id":"neutral-2-body","type":"text","text":"A verified aggregate states its period without fabricating an individual event.","tone":"default"},{"id":"neutral-3-badge","type":"badge","text":"124 enrolments this month","tone":"default"},{"id":"neutral-4-disclosure","type":"disclosure","summary":"Claim basis","content":"The relevant population, period, inventory or offer state is presented with the message.","open":true},{"id":"neutral-5-link","type":"link","text":"View the source and period for “124 enrolments this month”","emphasis":"default"}],"annotations":[{"targetId":"neutral-2-body","text":"Fairer design: Show only verified activity with a defined period and privacy-safe aggregation, or remove the notification."},{"targetId":"neutral-5-link","text":"Review prompt: Record the claim, timestamp, data source and post-claim state; which evidence supports “It appears near a transactional choice or repeatedly interrupts it”?"}]},"whyItMatters":"The interface asks the user to rely on other people’s behaviour or approval. The cue “Mia from Berlin enrolled” has persuasive meaning only if its population, period, metric and relationship match the represented claim. The panel instead says: “Invented names and cities are presented as completed enrolment events.” A visitor may infer genuine recent participation and social confidence from activity that never occurred.","fairDesignPrinciple":"Show only verified activity with a defined period and privacy-safe aggregation, or remove the notification.","reviewPrompts":["Which source record substantiates “Mia from Berlin enrolled”, including its population, period, metric and any commercial relationship?","Record the claim, timestamp, data source and post-claim state; which evidence supports “It appears near a transactional choice or repeatedly interrupts it”?","Can the claim be reproduced from a defined population and period, or does the evidence instead fit “named testimonial”?"],"altText":"Side-by-side course landing page interface showing “New learner joined” and the clearer alternative “Course participation”.","provenance":"Original hypothetical course landing page example created for this library; no real business, product or interface is depicted."}],"fairAlternative":"Use accurate, auditable and appropriately time-bounded activity data and explain what the metric represents.","whyProblematic":"Claims about recent or current actions by other users are used to steer the decision, particularly where authenticity, timing or relevance is unsupported. Purported recent behaviour is used as live social evidence even though the event, person, count or period does not correspond to the represented activity. These harms describe a review risk, not an automatic legal conclusion. Australian section 28B commences on 1 July 2027 and requires its complete, context-specific test. Existing ACL provisions remain a separate current-law assessment.","contextFactors":["The message describes actions by other people as current or recent.","It appears near a transactional choice or repeatedly interrupts it.","Provenance or freshness must be externally verified before alleging falsity.","Boundary to test: Static aggregate popularity claim","Boundary to test: A named testimonial whose speaker, relationship and non-live character are clearly stated","Boundary to test: Verifiable operational status unrelated to persuasion","Boundary to test: A clearly historical activity figure whose period and non-live character are stated beside it"],"affectedTeams":["Product","Design","Engineering","Legal","Compliance"],"reviewQuestions":["Which source record substantiates “12 bought this hour”, including its population, period, metric and any commercial relationship?","Record the claim, timestamp, data source and post-claim state; which evidence supports “The message describes actions by other people as current or recent”?","Can the claim be reproduced from a defined population and period, or does the evidence instead fit “Static aggregate popularity claim”?","Which source record substantiates “Mia from Berlin enrolled”, including its population, period, metric and any commercial relationship?","Record the claim, timestamp, data source and post-claim state; which evidence supports “It appears near a transactional choice or repeatedly interrupts it”?","Can the claim be reproduced from a defined population and period, or does the evidence instead fit “named testimonial”?"],"evidence":["Annotated pricing screenshots at each responsive breakpoint","The complete state sequence before, during and after the consumer decision","Design-system component, content, default and configuration records for the reviewed release","Operational records substantiating price, availability, timing and eligibility claims","Usability, accessibility, reversal, complaint and support evidence relevant to consumer impact","A dated product and legal review record identifying evidence, uncertainties and release decisions"],"related":["popularity-claims","testimonials-or-endorsements","automatic-attention-capture","bundled-options"],"sourceIds":["oecd-dark-commercial-patterns-2022","au-act-2026-64"],"altText":"Side-by-side product page interface showing “Popular right now” and the clearer alternative “Verified activity information”.","provenance":"Original hypothetical interface comparisons from the shared learning library, adapted to Australian-dollar context for this portal; no real business, product or interface is depicted.","author":"Flowlane","datePublished":"2026-08-10","dateModified":"2026-09-14","lastReviewed":"2026-09-14","changeNote":"Source comparison recorded and the current status restated."},{"title":"Popularity claims","slug":"popularity-claims","preferredName":"Popularity claims","directAnswer":"Popularity claims is a working label for this design mechanism: Aggregate popularity or approval is presented to steer a choice where the metric, population, period or basis is unclear or unsupported. This is editorial implementation guidance for Australian journeys, not a finding of unlawfulness. From 1 July 2027, a similar interface is relevant to ACL section 28B only if the complete consumer-connection, manipulation or unreasonable-distortion and actual-or-likely-detriment test is met. Current ACL rules require a separate assessment.","definition":"Aggregate popularity or approval is presented to steer a choice where the metric, population, period or basis is unclear or unsupported. This is a design and research taxonomy for learning and evidence review, not a statutory offence label or an automatic finding that an interface is unlawful.","synonyms":["best seller claim","most popular","aggregate social proof","most popular plan","number of customers","star rating","trending badge"],"category":"Social proof","family":"Social proof","journeyStages":["Pricing"],"jurisdiction":"Australia","status":"Editorial implementation guidance","howItWorks":"Aggregate popularity or approval is presented to steer a choice where the metric, population, period or basis is unclear or unsupported. A ranking or badge implies collective preference without a defined population, period and metric, or substitutes a commercial objective for actual popularity.","warningSigns":["The claim asserts relative or aggregate popularity.","It is used near a choice or recommendation.","The relevant metric basis requires provenance verification before alleging deception."],"harms":["The badge may steer users using an unsupported impression of collective preference.","Shoppers may interpret commercial ranking as genuine purchase popularity."],"legitimateUses":["Individual testimonial","recent-activity message","transparent internally computed recommendation not presented as social behaviour"],"legalBasis":[{"provision":"ACL section 28B, inserted by the 2026 Act","sourceIds":["au-act-2026-64"],"classification":"Possible risk indicator","explanation":"In pricing journeys, the popularity claims mechanism may warrant review where it manipulates a consumer or unreasonably distorts the decision environment and causes, or is likely to cause, detriment. The social proof label and an interface similarity do not establish a contravention; the complete section 28B test, scope, facts and evidence must be applied from 1 July 2027."},{"provision":"Dark-pattern research taxonomy","sourceIds":["oecd-dark-commercial-patterns-2022"],"classification":"Editorial analysis","explanation":"The cited research sources support this working pattern within the social proof family. It is editorial implementation guidance, not an Australian statutory category, regulator finding or legal safe harbour."}],"examples":[{"type":"Illustrative example","context":"“Most popular” has no defined metric","scenario":"A fictional service labels its highest-margin plan “Most popular” without recording sales, selection period or the population being measured.","harm":"The badge may steer users using an unsupported impression of collective preference."},{"type":"Illustrative example","context":"Bestseller badge follows margin rather than sales","scenario":"A fictional marketplace assigns “Bestseller” to whichever item yields the highest commission, regardless of units sold.","harm":"Shoppers may interpret commercial ranking as genuine purchase popularity."}],"problematicUi":{"label":"Most popular","copy":"Most popular No population, period or selection measure supports the badge. Choose Pro Compare Pro features","annotations":["Why this state matters: The interface asks the user to rely on other people’s behaviour or approval. The cue “Choose Pro” has persuasive meaning only if its population, period, metric and relationship match the represented claim. The panel instead says: “No population, period or selection measure supports the badge.” The badge may steer users using an unsupported impression of collective preference.","Review prompt: Which source record substantiates “Choose Pro”, including its population, period, metric and any commercial relationship?"]},"improvedUi":{"label":"Plan comparison","copy":"Plan comparison Feature and price differences replace the unsupported popularity cue. Compare Pro features Choose Pro Price, period and commitment The price and material terms associated with “Compare Pro features” remain beside this choice.","annotations":["Fairer design: Use the claim only with a defined, current and supportable metric, or use a factual feature label instead.","Review prompt: Place the compared prices, billing periods and material terms on one evidence sheet; where does it support “The claim asserts relative or aggregate popularity”?"]},"uiComparisons":[{"id":"popularity-claims-scenario-1","title":"“Most popular” has no defined metric","context":"Subscription plans","journeyStage":"Pricing","summary":"A fictional service labels its highest-margin plan “Most popular” without recording sales, selection period or the population being measured.","problematic":{"label":"Most popular","layout":"pricing-card","elements":[{"id":"problematic-1-heading","type":"heading","text":"Most popular"},{"id":"problematic-2-body","type":"text","text":"No population, period or selection measure supports the badge.","tone":"warning"},{"id":"problematic-3-button","type":"button","text":"Choose Pro","emphasis":"primary"},{"id":"problematic-4-link","type":"link","text":"Compare Pro features","emphasis":"subtle"}],"annotations":[{"targetId":"problematic-2-body","text":"Why this state matters: The interface asks the user to rely on other people’s behaviour or approval. The cue “Choose Pro” has persuasive meaning only if its population, period, metric and relationship match the represented claim. The panel instead says: “No population, period or selection measure supports the badge.” The badge may steer users using an unsupported impression of collective preference."},{"targetId":"problematic-4-link","text":"Review prompt: Which source record substantiates “Choose Pro”, including its population, period, metric and any commercial relationship?"}]},"neutral":{"label":"Plan comparison","layout":"pricing-card","elements":[{"id":"neutral-1-heading","type":"heading","text":"Plan comparison"},{"id":"neutral-2-body","type":"text","text":"Feature and price differences replace the unsupported popularity cue.","tone":"default"},{"id":"neutral-3-button","type":"button","text":"Compare Pro features","emphasis":"secondary"},{"id":"neutral-4-link","type":"link","text":"Choose Pro","emphasis":"default"},{"id":"neutral-5-disclosure","type":"disclosure","summary":"Price, period and commitment","content":"The price and material terms associated with “Compare Pro features” remain beside this choice.","open":true}],"annotations":[{"targetId":"neutral-2-body","text":"Fairer design: Use the claim only with a defined, current and supportable metric, or use a factual feature label instead."},{"targetId":"neutral-5-disclosure","text":"Review prompt: Place the compared prices, billing periods and material terms on one evidence sheet; where does it support “The claim asserts relative or aggregate popularity”?"}]},"whyItMatters":"The interface asks the user to rely on other people’s behaviour or approval. The cue “Choose Pro” has persuasive meaning only if its population, period, metric and relationship match the represented claim. The panel instead says: “No population, period or selection measure supports the badge.” The badge may steer users using an unsupported impression of collective preference.","fairDesignPrinciple":"Use the claim only with a defined, current and supportable metric, or use a factual feature label instead.","reviewPrompts":["Which source record substantiates “Choose Pro”, including its population, period, metric and any commercial relationship?","Place the compared prices, billing periods and material terms on one evidence sheet; where does it support “The claim asserts relative or aggregate popularity”?","Can the claim be reproduced from a defined population and period, or does the evidence instead fit “Individual testimonial”?"],"altText":"Side-by-side subscription plans interface showing “Most popular” and the clearer alternative “Plan comparison”.","provenance":"Original hypothetical subscription plans example created for this library; no real business, product or interface is depicted."},{"id":"popularity-claims-scenario-2","title":"Bestseller badge follows margin rather than sales","context":"Marketplace results","journeyStage":"Pricing","summary":"A fictional marketplace assigns “Bestseller” to whichever item yields the highest commission, regardless of units sold.","problematic":{"label":"Bestseller","layout":"banner","elements":[{"id":"problematic-1-heading","type":"heading","text":"Bestseller"},{"id":"problematic-2-body","type":"text","text":"The badge reflects commission, not customer purchases.","tone":"warning"},{"id":"problematic-3-badge","type":"badge","text":"Top customer choice","tone":"warning"},{"id":"problematic-4-disclosure","type":"disclosure","summary":"Claim basis","content":"No supporting population, period, inventory or offer event is presented with this message.","open":false}],"annotations":[{"targetId":"problematic-2-body","text":"Why this state matters: The interface asks the user to rely on other people’s behaviour or approval. The cue “Top customer choice” has persuasive meaning only if its population, period, metric and relationship match the represented claim. The panel instead says: “The badge reflects commission, not customer purchases.” Shoppers may interpret commercial ranking as genuine purchase popularity."},{"targetId":"problematic-4-disclosure","text":"Review prompt: Which source record substantiates “Top customer choice”, including its population, period, metric and any commercial relationship?"}]},"neutral":{"label":"Sponsored placement","layout":"banner","elements":[{"id":"neutral-1-heading","type":"heading","text":"Sponsored placement"},{"id":"neutral-2-body","type":"text","text":"Commercial ranking is labelled and no sales popularity is implied.","tone":"default"},{"id":"neutral-3-badge","type":"badge","text":"View sponsored item","tone":"default"},{"id":"neutral-4-disclosure","type":"disclosure","summary":"Claim basis","content":"The relevant population, period, inventory or offer state is presented with the message.","open":true},{"id":"neutral-5-link","type":"link","text":"View the source and period for “View sponsored item”","emphasis":"default"}],"annotations":[{"targetId":"neutral-2-body","text":"Fairer design: Separate sponsored or commercial placement from verified sales-based popularity and state the ranking basis."},{"targetId":"neutral-5-link","text":"Review prompt: Record the claim, timestamp, data source and post-claim state; which evidence supports “It is used near a choice or recommendation”?"}]},"whyItMatters":"The interface asks the user to rely on other people’s behaviour or approval. The cue “Top customer choice” has persuasive meaning only if its population, period, metric and relationship match the represented claim. The panel instead says: “The badge reflects commission, not customer purchases.” Shoppers may interpret commercial ranking as genuine purchase popularity.","fairDesignPrinciple":"Separate sponsored or commercial placement from verified sales-based popularity and state the ranking basis.","reviewPrompts":["Which source record substantiates “Top customer choice”, including its population, period, metric and any commercial relationship?","Record the claim, timestamp, data source and post-claim state; which evidence supports “It is used near a choice or recommendation”?","Can the claim be reproduced from a defined population and period, or does the evidence instead fit “recent-activity message”?"],"altText":"Side-by-side marketplace results interface showing “Bestseller” and the clearer alternative “Sponsored placement”.","provenance":"Original hypothetical marketplace results example created for this library; no real business, product or interface is depicted."}],"fairAlternative":"Use popularity claims only with a defined population, period and metric; document the calculation beside the claim or replace it with factual product information.","whyProblematic":"Aggregate popularity or approval is presented to steer a choice where the metric, population, period or basis is unclear or unsupported. A ranking or badge implies collective preference without a defined population, period and metric, or substitutes a commercial objective for actual popularity. These harms describe a review risk, not an automatic legal conclusion. Australian section 28B commences on 1 July 2027 and requires its complete, context-specific test. Existing ACL provisions remain a separate current-law assessment.","contextFactors":["The claim asserts relative or aggregate popularity.","It is used near a choice or recommendation.","The relevant metric basis requires provenance verification before alleging deception.","Boundary to test: Individual testimonial","Boundary to test: recent-activity message","Boundary to test: transparent internally computed recommendation not presented as social behaviour"],"affectedTeams":["Product","Design","Engineering","Legal","Compliance"],"reviewQuestions":["Which source record substantiates “Choose Pro”, including its population, period, metric and any commercial relationship?","Place the compared prices, billing periods and material terms on one evidence sheet; where does it support “The claim asserts relative or aggregate popularity”?","Can the claim be reproduced from a defined population and period, or does the evidence instead fit “Individual testimonial”?","Which source record substantiates “Top customer choice”, including its population, period, metric and any commercial relationship?","Record the claim, timestamp, data source and post-claim state; which evidence supports “It is used near a choice or recommendation”?","Can the claim be reproduced from a defined population and period, or does the evidence instead fit “recent-activity message”?"],"evidence":["Annotated pricing screenshots at each responsive breakpoint","The complete state sequence before, during and after the consumer decision","Design-system component, content, default and configuration records for the reviewed release","Operational records substantiating price, availability, timing and eligibility claims","Usability, accessibility, reversal, complaint and support evidence relevant to consumer impact","A dated product and legal review record identifying evidence, uncertainties and release decisions"],"related":["activity-messages","testimonials-or-endorsements","automatic-attention-capture","bundled-options"],"sourceIds":["oecd-dark-commercial-patterns-2022","au-act-2026-64"],"altText":"Side-by-side subscription plans interface showing “Most popular” and the clearer alternative “Plan comparison”.","provenance":"Original hypothetical interface comparisons from the shared learning library, adapted to Australian-dollar context for this portal; no real business, product or interface is depicted.","author":"Flowlane","datePublished":"2026-08-10","dateModified":"2026-09-14","lastReviewed":"2026-09-14","changeNote":"Source comparison recorded and the current status restated."},{"title":"Testimonials or endorsements","slug":"testimonials-or-endorsements","preferredName":"Testimonials or endorsements","directAnswer":"Testimonials or endorsements is a working label for this design mechanism: A named or attributed person's approval is used persuasively without sufficient authenticity, representativeness or relationship disclosure. This is editorial implementation guidance for Australian journeys, not a finding of unlawfulness. From 1 July 2027, a similar interface is relevant to ACL section 28B only if the complete consumer-connection, manipulation or unreasonable-distortion and actual-or-likely-detriment test is met. Current ACL rules require a separate assessment.","definition":"A named or attributed person's approval is used persuasively without sufficient authenticity, representativeness or relationship disclosure. This is a design and research taxonomy for learning and evidence review, not a statutory offence label or an automatic finding that an interface is unlawful.","synonyms":["customer testimonial","influencer endorsement","expert endorsement","fabricated review","material connection undisclosed","testimonial not representative","authority claim unsupported"],"category":"Social proof","family":"Social proof","journeyStages":["Pricing"],"jurisdiction":"Australia","status":"Editorial implementation guidance","howItWorks":"A named or attributed person's approval is used persuasively without sufficient authenticity, representativeness or relationship disclosure. A recommendation gains apparent independence or expertise by withholding the speaker’s payment, employment or other material relationship.","warningSigns":["The interface attributes an evaluative statement or approval to a person or identifiable group.","The statement is connected to a purchase or other material choice.","Authenticity, material connection or representativeness is unsupported or contradicted by verified evidence."],"harms":["Viewers may give the recommendation weight they would not give a clearly identified advertisement.","Buyers may mistake an internal promotional statement for independent evaluation."],"legitimateUses":["Unaffiliated verifiable statement accurately quoted in context","aggregate rating without testimonial attribution","clearly labelled fictional illustration"],"legalBasis":[{"provision":"ACL section 28B, inserted by the 2026 Act","sourceIds":["au-act-2026-64"],"classification":"Possible risk indicator","explanation":"In pricing journeys, the testimonials or endorsements mechanism may warrant review where it manipulates a consumer or unreasonably distorts the decision environment and causes, or is likely to cause, detriment. The social proof label and an interface similarity do not establish a contravention; the complete section 28B test, scope, facts and evidence must be applied from 1 July 2027."},{"provision":"Dark-pattern research taxonomy","sourceIds":["oecd-dark-commercial-patterns-2022"],"classification":"Editorial analysis","explanation":"The cited research sources support this working pattern within the social proof family. It is editorial implementation guidance, not an Australian statutory category, regulator finding or legal safe harbour."}],"examples":[{"type":"Illustrative example","context":"Paid creator recommendation lacks disclosure","scenario":"A fictional creator calls a skincare product a personal favourite and links to purchase without disclosing payment until the bottom of a collapsed caption.","harm":"Viewers may give the recommendation weight they would not give a clearly identified advertisement."},{"type":"Illustrative example","context":"Employee review presented as independent expertise","scenario":"A fictional software company publishes a five-star quote from its product manager under an “Independent experts recommend” heading.","harm":"Buyers may mistake an internal promotional statement for independent evaluation."}],"problematicUi":{"label":"My everyday favourite","copy":"My everyday favourite The creator’s payment is hidden below the promotional claim. Shop my pick Claim basis No supporting population, period, inventory or offer event is presented with this message.","annotations":["Why this state matters: The interface asks the user to rely on other people’s behaviour or approval. The cue “Shop my pick” has persuasive meaning only if its population, period, metric and relationship match the represented claim. The panel instead says: “The creator’s payment is hidden below the promotional claim.” Viewers may give the recommendation weight they would not give a clearly identified advertisement.","Review prompt: Which source record substantiates “Shop my pick”, including its population, period, metric and any commercial relationship?"]},"improvedUi":{"label":"Paid advertisement","copy":"Paid advertisement The material relationship appears before the recommendation and link. View advertised product Claim basis The relevant population, period, inventory or offer state is presented with the message. View the source and period for “View advertised product”","annotations":["Fairer design: Disclose the material relationship at first exposure and keep it visible near the endorsement and purchase route.","Review prompt: Record the claim, timestamp, data source and post-claim state; which evidence supports “The interface attributes an evaluative statement or approval to a person or identifiable group”?"]},"uiComparisons":[{"id":"testimonials-or-endorsements-scenario-1","title":"Paid creator recommendation lacks disclosure","context":"Social product landing page","journeyStage":"Pricing","summary":"A fictional creator calls a skincare product a personal favourite and links to purchase without disclosing payment until the bottom of a collapsed caption.","problematic":{"label":"My everyday favourite","layout":"banner","elements":[{"id":"problematic-1-heading","type":"heading","text":"My everyday favourite"},{"id":"problematic-2-body","type":"text","text":"The creator’s payment is hidden below the promotional claim.","tone":"warning"},{"id":"problematic-3-badge","type":"badge","text":"Shop my pick","tone":"warning"},{"id":"problematic-4-disclosure","type":"disclosure","summary":"Claim basis","content":"No supporting population, period, inventory or offer event is presented with this message.","open":false}],"annotations":[{"targetId":"problematic-2-body","text":"Why this state matters: The interface asks the user to rely on other people’s behaviour or approval. The cue “Shop my pick” has persuasive meaning only if its population, period, metric and relationship match the represented claim. The panel instead says: “The creator’s payment is hidden below the promotional claim.” Viewers may give the recommendation weight they would not give a clearly identified advertisement."},{"targetId":"problematic-4-disclosure","text":"Review prompt: Which source record substantiates “Shop my pick”, including its population, period, metric and any commercial relationship?"}]},"neutral":{"label":"Paid advertisement","layout":"banner","elements":[{"id":"neutral-1-heading","type":"heading","text":"Paid advertisement"},{"id":"neutral-2-body","type":"text","text":"The material relationship appears before the recommendation and link.","tone":"default"},{"id":"neutral-3-badge","type":"badge","text":"View advertised product","tone":"default"},{"id":"neutral-4-disclosure","type":"disclosure","summary":"Claim basis","content":"The relevant population, period, inventory or offer state is presented with the message.","open":true},{"id":"neutral-5-link","type":"link","text":"View the source and period for “View advertised product”","emphasis":"default"}],"annotations":[{"targetId":"neutral-2-body","text":"Fairer design: Disclose the material relationship at first exposure and keep it visible near the endorsement and purchase route."},{"targetId":"neutral-5-link","text":"Review prompt: Record the claim, timestamp, data source and post-claim state; which evidence supports “The interface attributes an evaluative statement or approval to a person or identifiable group”?"}]},"whyItMatters":"The interface asks the user to rely on other people’s behaviour or approval. The cue “Shop my pick” has persuasive meaning only if its population, period, metric and relationship match the represented claim. The panel instead says: “The creator’s payment is hidden below the promotional claim.” Viewers may give the recommendation weight they would not give a clearly identified advertisement.","fairDesignPrinciple":"Disclose the material relationship at first exposure and keep it visible near the endorsement and purchase route.","reviewPrompts":["Which source record substantiates “Shop my pick”, including its population, period, metric and any commercial relationship?","Record the claim, timestamp, data source and post-claim state; which evidence supports “The interface attributes an evaluative statement or approval to a person or identifiable group”?","Can the claim be reproduced from a defined population and period, or does the evidence instead fit “Unaffiliated verifiable statement accurately quoted in context”?"],"altText":"Side-by-side social product landing page interface showing “My everyday favourite” and the clearer alternative “Paid advertisement”.","provenance":"Original hypothetical social product landing page example created for this library; no real business, product or interface is depicted."},{"id":"testimonials-or-endorsements-scenario-2","title":"Employee review presented as independent expertise","context":"Software comparison page","journeyStage":"Pricing","summary":"A fictional software company publishes a five-star quote from its product manager under an “Independent experts recommend” heading.","problematic":{"label":"Independent expert verdict","layout":"pricing-card","elements":[{"id":"problematic-1-heading","type":"heading","text":"Independent expert verdict"},{"id":"problematic-2-body","type":"text","text":"The reviewer is an employee and the relationship is not disclosed.","tone":"warning"},{"id":"problematic-3-badge","type":"badge","text":"Five stars","tone":"warning"},{"id":"problematic-4-link","type":"link","text":"Read methodology","emphasis":"subtle"}],"annotations":[{"targetId":"problematic-2-body","text":"Why this state matters: The interface asks the user to rely on other people’s behaviour or approval. The cue “Five stars” has persuasive meaning only if its population, period, metric and relationship match the represented claim. The panel instead says: “The reviewer is an employee and the relationship is not disclosed.” Buyers may mistake an internal promotional statement for independent evaluation."},{"targetId":"problematic-4-link","text":"Review prompt: Which source record substantiates “Five stars”, including its population, period, metric and any commercial relationship?"}]},"neutral":{"label":"Product-team perspective","layout":"pricing-card","elements":[{"id":"neutral-1-heading","type":"heading","text":"Product-team perspective"},{"id":"neutral-2-body","type":"text","text":"The speaker’s role and connection are visible beside the quote.","tone":"default"},{"id":"neutral-3-badge","type":"badge","text":"Read methodology","tone":"default"},{"id":"neutral-4-link","type":"link","text":"Five stars","emphasis":"default"},{"id":"neutral-5-disclosure","type":"disclosure","summary":"Price, period and commitment","content":"The price and material terms associated with “Read methodology” remain beside this choice.","open":true}],"annotations":[{"targetId":"neutral-2-body","text":"Fairer design: Identify the speaker and relationship accurately and substantiate any expertise or independence claim."},{"targetId":"neutral-5-disclosure","text":"Review prompt: Place the compared prices, billing periods and material terms on one evidence sheet; where does it support “The statement is connected to a purchase or other material choice”?"}]},"whyItMatters":"The interface asks the user to rely on other people’s behaviour or approval. The cue “Five stars” has persuasive meaning only if its population, period, metric and relationship match the represented claim. The panel instead says: “The reviewer is an employee and the relationship is not disclosed.” Buyers may mistake an internal promotional statement for independent evaluation.","fairDesignPrinciple":"Identify the speaker and relationship accurately and substantiate any expertise or independence claim.","reviewPrompts":["Which source record substantiates “Five stars”, including its population, period, metric and any commercial relationship?","Place the compared prices, billing periods and material terms on one evidence sheet; where does it support “The statement is connected to a purchase or other material choice”?","Can the claim be reproduced from a defined population and period, or does the evidence instead fit “aggregate rating without testimonial attribution”?"],"altText":"Side-by-side software comparison page interface showing “Independent expert verdict” and the clearer alternative “Product-team perspective”.","provenance":"Original hypothetical software comparison page example created for this library; no real business, product or interface is depicted."}],"fairAlternative":"Use authentic, supportable testimonials and clearly disclose material commercial connections and limitations.","whyProblematic":"A named or attributed person's approval is used persuasively without sufficient authenticity, representativeness or relationship disclosure. A recommendation gains apparent independence or expertise by withholding the speaker’s payment, employment or other material relationship. These harms describe a review risk, not an automatic legal conclusion. Australian section 28B commences on 1 July 2027 and requires its complete, context-specific test. Existing ACL provisions remain a separate current-law assessment.","contextFactors":["The interface attributes an evaluative statement or approval to a person or identifiable group.","The statement is connected to a purchase or other material choice.","Authenticity, material connection or representativeness is unsupported or contradicted by verified evidence.","Boundary to test: Unaffiliated verifiable statement accurately quoted in context","Boundary to test: aggregate rating without testimonial attribution","Boundary to test: clearly labelled fictional illustration"],"affectedTeams":["Product","Design","Engineering","Legal","Compliance"],"reviewQuestions":["Which source record substantiates “Shop my pick”, including its population, period, metric and any commercial relationship?","Record the claim, timestamp, data source and post-claim state; which evidence supports “The interface attributes an evaluative statement or approval to a person or identifiable group”?","Can the claim be reproduced from a defined population and period, or does the evidence instead fit “Unaffiliated verifiable statement accurately quoted in context”?","Which source record substantiates “Five stars”, including its population, period, metric and any commercial relationship?","Place the compared prices, billing periods and material terms on one evidence sheet; where does it support “The statement is connected to a purchase or other material choice”?","Can the claim be reproduced from a defined population and period, or does the evidence instead fit “aggregate rating without testimonial attribution”?"],"evidence":["Annotated pricing screenshots at each responsive breakpoint","The complete state sequence before, during and after the consumer decision","Design-system component, content, default and configuration records for the reviewed release","Operational records substantiating price, availability, timing and eligibility claims","Usability, accessibility, reversal, complaint and support evidence relevant to consumer impact","A dated product and legal review record identifying evidence, uncertainties and release decisions"],"related":["activity-messages","popularity-claims","automatic-attention-capture","bundled-options"],"sourceIds":["oecd-dark-commercial-patterns-2022","au-act-2026-64"],"altText":"Side-by-side social product landing page interface showing “My everyday favourite” and the clearer alternative “Paid advertisement”.","provenance":"Original hypothetical interface comparisons from the shared learning library, adapted to Australian-dollar context for this portal; no real business, product or interface is depicted.","author":"Flowlane","datePublished":"2026-08-10","dateModified":"2026-09-14","lastReviewed":"2026-09-14","changeNote":"Source comparison recorded and the current status restated."},{"title":"Countdown timer","slug":"false-urgency-and-scarcity","preferredName":"Countdown timer","directAnswer":"Countdown timer is a working label for this design mechanism: A visible countdown applies time pressure, particularly where it resets, is personalised without disclosure or has no corresponding consequence at zero. This is editorial implementation guidance for Australian journeys, not a finding of unlawfulness. From 1 July 2027, a similar interface is relevant to ACL section 28B only if the complete consumer-connection, manipulation or unreasonable-distortion and actual-or-likely-detriment test is met. Current ACL rules require a separate assessment.","definition":"A visible countdown applies time pressure, particularly where it resets, is personalised without disclosure or has no corresponding consequence at zero. This is a design and research taxonomy for learning and evidence review, not a statutory offence label or an automatic finding that an interface is unlawful.","synonyms":["countdown scarcity","resetting timer","timer resets on reload","timer differs by user","zero has no consequence","deadline repeatedly extended","fake countdown","false low-stock claim","manufactured urgency","scarcity cue","expiring-offer claim","False urgency and scarcity"],"category":"Urgency","family":"Urgency","journeyStages":["Pricing","Checkout"],"jurisdiction":"Australia","status":"Commences 1 July 2027","howItWorks":"A visible countdown applies time pressure, particularly where it resets, is personalised without disclosure or has no corresponding consequence at zero. A visible timer accelerates the decision, but its value, reset behaviour or expiry consequence is detached from a real offer or reservation event.","warningSigns":["A decreasing time representation is shown near a choice.","The stated or implied consequence at expiry is material.","Controlled replay can test reset and expiry behaviour."],"harms":["The timer can manufacture urgency without a corresponding offer deadline.","A buyer may hurry through payment because the interface represents a protection that does not exist."],"legitimateUses":["Purely informational clock","genuine fixed event deadline that produces the represented consequence","session timeout required for security and accurately described"],"legalBasis":[{"provision":"ACL section 28B(2), inserted by the 2026 Act","sourceIds":["au-act-2026-64"],"classification":"Possible risk indicator","explanation":"Potentially applies where a pressure device manipulates or unreasonably distorts the decision environment and causes or is likely to cause detriment."},{"provision":"ACL section 28B(6)(d), inserted by the 2026 Act","sourceIds":["au-act-2026-64"],"classification":"Possible risk indicator","explanation":"Identifies unreasonable pressure in a decision environment as an example that may satisfy the prohibition."},{"provision":"ACL sections 18 and 29","sourceIds":["au-acl-2010"],"classification":"Current law","explanation":"May already apply where an urgency, stock, demand or duration claim is false or creates a misleading overall impression."}],"examples":[{"type":"Illustrative example","context":"Sale timer resets on reload","scenario":"A fictional retailer shows a fifteen-minute sale countdown that returns to fifteen minutes whenever the page reloads and the price never changes at zero.","harm":"The timer can manufacture urgency without a corresponding offer deadline."},{"type":"Illustrative example","context":"Reservation timer has no inventory hold","scenario":"A fictional ticket seller displays “Seats held for 02:00” although no seats are reserved and the timer simply restarts after zero.","harm":"A buyer may hurry through payment because the interface represents a protection that does not exist."}],"problematicUi":{"label":"Sale ends in","copy":"Sale ends in The timer restarts and has no effect on price or availability. Displayed time 14:59 Expiry consequence No corresponding expiry event or reservation state is shown with the timer.","annotations":["Why this state matters: The message applies immediate pressure at the pricing decision. The cue “14:59” should correspond to a defined operating state and a real consequence. The example instead states: “The timer restarts and has no effect on price or availability.” The timer can manufacture urgency without a corresponding offer deadline.","Review prompt: Which timestamped inventory, reservation, demand or offer event substantiates “14:59”, and what changes when its limit is reached?"]},"improvedUi":{"label":"Offer ends at 18:00 CET","copy":"Offer ends at 18:00 CET The deadline is fixed and the stated discount ends at that time. Displayed time 42 minutes remaining Expiry consequence The expiry event and resulting reservation or offer state are shown with the timer. View the source and period for “42 minutes remaining”","annotations":["Fairer design: Use a countdown only for a genuine deadline and explain exactly what changes when it reaches zero.","Review prompt: Record the claim, timestamp, data source and post-claim state; which evidence supports “A decreasing time representation is shown near a choice”?"]},"uiComparisons":[{"id":"countdown-timer-scenario-1","title":"Sale timer resets on reload","context":"Retail promotion","journeyStage":"Pricing","summary":"A fictional retailer shows a fifteen-minute sale countdown that returns to fifteen minutes whenever the page reloads and the price never changes at zero.","problematic":{"label":"Sale ends in","layout":"banner","elements":[{"id":"problematic-1-heading","type":"heading","text":"Sale ends in"},{"id":"problematic-2-body","type":"text","text":"The timer restarts and has no effect on price or availability.","tone":"warning"},{"id":"problematic-3-timer","type":"timer","label":"Displayed time","value":"14:59"},{"id":"problematic-4-disclosure","type":"disclosure","summary":"Expiry consequence","content":"No corresponding expiry event or reservation state is shown with the timer.","open":false}],"annotations":[{"targetId":"problematic-2-body","text":"Why this state matters: The message applies immediate pressure at the pricing decision. The cue “14:59” should correspond to a defined operating state and a real consequence. The example instead states: “The timer restarts and has no effect on price or availability.” The timer can manufacture urgency without a corresponding offer deadline."},{"targetId":"problematic-4-disclosure","text":"Review prompt: Which timestamped inventory, reservation, demand or offer event substantiates “14:59”, and what changes when its limit is reached?"}]},"neutral":{"label":"Offer ends at 18:00 CET","layout":"banner","elements":[{"id":"neutral-1-heading","type":"heading","text":"Offer ends at 18:00 CET"},{"id":"neutral-2-body","type":"text","text":"The deadline is fixed and the stated discount ends at that time.","tone":"default"},{"id":"neutral-3-timer","type":"timer","label":"Displayed time","value":"42 minutes remaining"},{"id":"neutral-4-disclosure","type":"disclosure","summary":"Expiry consequence","content":"The expiry event and resulting reservation or offer state are shown with the timer.","open":true},{"id":"neutral-5-link","type":"link","text":"View the source and period for “42 minutes remaining”","emphasis":"default"}],"annotations":[{"targetId":"neutral-2-body","text":"Fairer design: Use a countdown only for a genuine deadline and explain exactly what changes when it reaches zero."},{"targetId":"neutral-5-link","text":"Review prompt: Record the claim, timestamp, data source and post-claim state; which evidence supports “A decreasing time representation is shown near a choice”?"}]},"whyItMatters":"The message applies immediate pressure at the pricing decision. The cue “14:59” should correspond to a defined operating state and a real consequence. The example instead states: “The timer restarts and has no effect on price or availability.” The timer can manufacture urgency without a corresponding offer deadline.","fairDesignPrinciple":"Use a countdown only for a genuine deadline and explain exactly what changes when it reaches zero.","reviewPrompts":["Which timestamped inventory, reservation, demand or offer event substantiates “14:59”, and what changes when its limit is reached?","Record the claim, timestamp, data source and post-claim state; which evidence supports “A decreasing time representation is shown near a choice”?","What happens when the stated limit is reached, and could the observed message be the legitimate case “Purely informational clock”?"],"altText":"Side-by-side retail promotion interface showing “Sale ends in” and the clearer alternative “Offer ends at 18:00 CET”.","provenance":"Original hypothetical retail promotion example created for this library; no real business, product or interface is depicted."},{"id":"countdown-timer-scenario-2","title":"Reservation timer has no inventory hold","context":"Ticket checkout","journeyStage":"Checkout","summary":"A fictional ticket seller displays “Seats held for 02:00” although no seats are reserved and the timer simply restarts after zero.","problematic":{"label":"Seats held for","layout":"banner","elements":[{"id":"problematic-1-heading","type":"heading","text":"Seats held for"},{"id":"problematic-2-body","type":"text","text":"No inventory state corresponds to the repeating countdown.","tone":"warning"},{"id":"problematic-3-timer","type":"timer","label":"Displayed time","value":"02:00"},{"id":"problematic-4-disclosure","type":"disclosure","summary":"Expiry consequence","content":"No corresponding expiry event or reservation state is shown with the timer.","open":false}],"annotations":[{"targetId":"problematic-2-body","text":"Why this state matters: The message applies immediate pressure at the checkout decision. The cue “02:00” should correspond to a defined operating state and a real consequence. The example instead states: “No inventory state corresponds to the repeating countdown.” A buyer may hurry through payment because the interface represents a protection that does not exist."},{"targetId":"problematic-4-disclosure","text":"Review prompt: Which timestamped inventory, reservation, demand or offer event substantiates “02:00”, and what changes when its limit is reached?"}]},"neutral":{"label":"Reservation valid until 14:32","layout":"banner","elements":[{"id":"neutral-1-heading","type":"heading","text":"Reservation valid until 14:32"},{"id":"neutral-2-body","type":"text","text":"The deadline is tied to the identified seats and releases them at expiry.","tone":"default"},{"id":"neutral-3-badge","type":"badge","text":"01:42 remaining","tone":"default"},{"id":"neutral-4-disclosure","type":"disclosure","summary":"Claim basis","content":"The relevant population, period, inventory or offer state is presented with the message.","open":true},{"id":"neutral-5-link","type":"link","text":"View the source and period for “01:42 remaining”","emphasis":"default"}],"annotations":[{"targetId":"neutral-2-body","text":"Fairer design: Connect the timer to a real reservation record and show a stable exit when no hold exists."},{"targetId":"neutral-5-link","text":"Review prompt: Record the claim, timestamp, data source and post-claim state; which evidence supports “The stated or implied consequence at expiry is material”?"}]},"whyItMatters":"The message applies immediate pressure at the checkout decision. The cue “02:00” should correspond to a defined operating state and a real consequence. The example instead states: “No inventory state corresponds to the repeating countdown.” A buyer may hurry through payment because the interface represents a protection that does not exist.","fairDesignPrinciple":"Connect the timer to a real reservation record and show a stable exit when no hold exists.","reviewPrompts":["Which timestamped inventory, reservation, demand or offer event substantiates “02:00”, and what changes when its limit is reached?","Record the claim, timestamp, data source and post-claim state; which evidence supports “The stated or implied consequence at expiry is material”?","What happens when the stated limit is reached, and could the observed message be the legitimate case “genuine fixed event deadline that produces the represented consequence”?"],"altText":"Side-by-side ticket checkout interface showing “Seats held for” and the clearer alternative “Reservation valid until 14:32”.","provenance":"Original hypothetical ticket checkout example created for this library; no real business, product or interface is depicted."}],"fairAlternative":"Use timers only for genuine deadlines, keep them consistent, and make the represented consequence occur at expiry.","whyProblematic":"A visible countdown applies time pressure, particularly where it resets, is personalised without disclosure or has no corresponding consequence at zero. A visible timer accelerates the decision, but its value, reset behaviour or expiry consequence is detached from a real offer or reservation event. Apply section 28B(2)'s full test and section 28B(6)(d)'s non-exhaustive pressure/obstruction example. The Act does not contain the taxonomy label \"false urgency\". Truth, operational basis, prominence, repetition, consumer vulnerability and resulting decision all matter. Current enforcement uses existing ACL provisions until the new prohibition commences. Final ACCC section 28B guidance and case law were not available at the review date.","contextFactors":["A decreasing time representation is shown near a choice.","The stated or implied consequence at expiry is material.","Controlled replay can test reset and expiry behaviour.","Boundary to test: Purely informational clock","Boundary to test: genuine fixed event deadline that produces the represented consequence","Boundary to test: session timeout required for security and accurately described","What data or rule supports the stock, demand, queue or expiry claim?","Does the offer actually end when the timer or message says it will?","Is the message personal to a reservation, or shown identically to every visitor?","How prominently and repeatedly is the pressure cue displayed?","Could it cause rushed spending, unsuitable selection or loss of comparison opportunity?"],"affectedTeams":["Marketing","Ecommerce","Product","Data","Engineering","Legal"],"reviewQuestions":["Which timestamped inventory, reservation, demand or offer event substantiates “14:59”, and what changes when its limit is reached?","Record the claim, timestamp, data source and post-claim state; which evidence supports “A decreasing time representation is shown near a choice”?","What happens when the stated limit is reached, and could the observed message be the legitimate case “Purely informational clock”?","Which timestamped inventory, reservation, demand or offer event substantiates “02:00”, and what changes when its limit is reached?","Record the claim, timestamp, data source and post-claim state; which evidence supports “The stated or implied consequence at expiry is material”?","What happens when the stated limit is reached, and could the observed message be the legitimate case “genuine fixed event deadline that produces the represented consequence”?","Can the business reproduce the source data for every urgency or scarcity claim?","Does a countdown alter or expire the offer in practice?","Is any caveat close enough to prevent a misleading overall impression?","Does personalisation exaggerate pressure beyond the underlying fact?","Are stale claims automatically removed when data is unavailable?"],"evidence":["inventory and offer-source logs","promotion start and end approvals","countdown implementation tests","data freshness and failure-state rules","screenshots with timestamps","complaint and conversion-quality analysis","Annotated pricing and checkout screenshots at each responsive breakpoint","The complete state sequence before, during and after the consumer decision","Design-system component, content, default and configuration records for the reviewed release","Operational records substantiating price, availability, timing and eligibility claims","Usability, accessibility, reversal, complaint and support evidence relevant to consumer impact","A dated product and legal review record identifying evidence, uncertainties and release decisions"],"related":["high-demand-claim","limited-time-or-reservation-claim","low-stock-claim","activity-messages"],"sourceIds":["oecd-dark-commercial-patterns-2022","au-act-2026-64","au-acl-2010","au-accc-priorities-2026","au-treasury-exposure-em-2026"],"altText":"Side-by-side retail promotion interface showing “Sale ends in” and the clearer alternative “Offer ends at 18:00 CET”.","provenance":"Original hypothetical interface comparisons from the shared learning library, adapted to Australian-dollar context for this portal; no real business, product or interface is depicted.","author":"Flowlane","datePublished":"2026-08-09","dateModified":"2026-09-14","lastReviewed":"2026-09-14","changeNote":"Source comparison recorded and the current status restated."},{"title":"High-demand claim","slug":"high-demand-claim","preferredName":"High-demand claim","directAnswer":"High-demand claim is a working label for this design mechanism: A claim of unusually high current demand is used to accelerate a decision without a clear or supportable basis. This is editorial implementation guidance for Australian journeys, not a finding of unlawfulness. From 1 July 2027, a similar interface is relevant to ACL section 28B only if the complete consumer-connection, manipulation or unreasonable-distortion and actual-or-likely-detriment test is met. Current ACL rules require a separate assessment.","definition":"A claim of unusually high current demand is used to accelerate a decision without a clear or supportable basis. This is a design and research taxonomy for learning and evidence review, not a statutory offence label or an automatic finding that an interface is unlawful.","synonyms":["selling fast","many people viewing","selling quickly","many shoppers interested","booked repeatedly today","demand message invariant across sessions"],"category":"Urgency","family":"Urgency","journeyStages":["Pricing"],"jurisdiction":"Australia","status":"Editorial implementation guidance","howItWorks":"A claim of unusually high current demand is used to accelerate a decision without a clear or supportable basis. A demand message suggests competition from other buyers without a current, relevant measure connecting that activity to the user’s available offer.","warningSigns":["The claim refers to demand, viewers, purchases or bookings rather than remaining stock.","It is temporally framed and connected to a transaction.","Truth and representativeness require provenance or controlled replay."],"harms":["The unsupported demand cue can create pressure to book before comparing alternatives.","Historical popularity is framed as immediate demand and may rush a decision."],"legitimateUses":["Remaining-stock claim","static aggregate popularity claim","auditable live demand metric with clear definition"],"legalBasis":[{"provision":"ACL section 28B, inserted by the 2026 Act","sourceIds":["au-act-2026-64"],"classification":"Possible risk indicator","explanation":"In pricing journeys, the high-demand claim mechanism may warrant review where it manipulates a consumer or unreasonably distorts the decision environment and causes, or is likely to cause, detriment. The urgency label and an interface similarity do not establish a contravention; the complete section 28B test, scope, facts and evidence must be applied from 1 July 2027."},{"provision":"Dark-pattern research taxonomy","sourceIds":["oecd-dark-commercial-patterns-2022"],"classification":"Editorial analysis","explanation":"The cited research sources support this working pattern within the urgency family. It is editorial implementation guidance, not an Australian statutory category, regulator finding or legal safe harbour."}],"examples":[{"type":"Illustrative example","context":"Fabricated live-viewer count","scenario":"A fictional travel site displays “42 people are viewing this” from a fixed script that runs for every result and visitor.","harm":"The unsupported demand cue can create pressure to book before comparing alternatives."},{"type":"Illustrative example","context":"Old booking spike presented as current demand","scenario":"A fictional seller says “Selling fast today” using sales from the launch week three months earlier.","harm":"Historical popularity is framed as immediate demand and may rush a decision."}],"problematicUi":{"label":"42 people viewing now","copy":"42 people viewing now The number is fixed and unrelated to current viewers. Book before demand rises Claim basis No supporting population, period, inventory or offer event is presented with this message.","annotations":["Why this state matters: The message applies immediate pressure at the pricing decision. The cue “Book before demand rises” should correspond to a defined operating state and a real consequence. The example instead states: “The number is fixed and unrelated to current viewers.” The unsupported demand cue can create pressure to book before comparing alternatives.","Review prompt: Which timestamped inventory, reservation, demand or offer event substantiates “Book before demand rises”, and what changes when its limit is reached?"]},"improvedUi":{"label":"Current availability","copy":"Current availability The page uses verifiable inventory rather than invented audience pressure. Rooms available for these dates Claim basis The relevant population, period, inventory or offer state is presented with the message. View the source and period for “Rooms available for these dates”","annotations":["Fairer design: Use a clearly defined live metric only when supported, including the relevant listing and measurement window.","Review prompt: Record the claim, timestamp, data source and post-claim state; which evidence supports “The claim refers to demand, viewers, purchases or bookings rather than remaining stock”?"]},"uiComparisons":[{"id":"high-demand-claim-scenario-1","title":"Fabricated live-viewer count","context":"Travel search result","journeyStage":"Pricing","summary":"A fictional travel site displays “42 people are viewing this” from a fixed script that runs for every result and visitor.","problematic":{"label":"42 people viewing now","layout":"banner","elements":[{"id":"problematic-1-heading","type":"heading","text":"42 people viewing now"},{"id":"problematic-2-body","type":"text","text":"The number is fixed and unrelated to current viewers.","tone":"warning"},{"id":"problematic-3-badge","type":"badge","text":"Book before demand rises","tone":"warning"},{"id":"problematic-4-disclosure","type":"disclosure","summary":"Claim basis","content":"No supporting population, period, inventory or offer event is presented with this message.","open":false}],"annotations":[{"targetId":"problematic-2-body","text":"Why this state matters: The message applies immediate pressure at the pricing decision. The cue “Book before demand rises” should correspond to a defined operating state and a real consequence. The example instead states: “The number is fixed and unrelated to current viewers.” The unsupported demand cue can create pressure to book before comparing alternatives."},{"targetId":"problematic-4-disclosure","text":"Review prompt: Which timestamped inventory, reservation, demand or offer event substantiates “Book before demand rises”, and what changes when its limit is reached?"}]},"neutral":{"label":"Current availability","layout":"banner","elements":[{"id":"neutral-1-heading","type":"heading","text":"Current availability"},{"id":"neutral-2-body","type":"text","text":"The page uses verifiable inventory rather than invented audience pressure.","tone":"default"},{"id":"neutral-3-badge","type":"badge","text":"Rooms available for these dates","tone":"default"},{"id":"neutral-4-disclosure","type":"disclosure","summary":"Claim basis","content":"The relevant population, period, inventory or offer state is presented with the message.","open":true},{"id":"neutral-5-link","type":"link","text":"View the source and period for “Rooms available for these dates”","emphasis":"default"}],"annotations":[{"targetId":"neutral-2-body","text":"Fairer design: Use a clearly defined live metric only when supported, including the relevant listing and measurement window."},{"targetId":"neutral-5-link","text":"Review prompt: Record the claim, timestamp, data source and post-claim state; which evidence supports “The claim refers to demand, viewers, purchases or bookings rather than remaining stock”?"}]},"whyItMatters":"The message applies immediate pressure at the pricing decision. The cue “Book before demand rises” should correspond to a defined operating state and a real consequence. The example instead states: “The number is fixed and unrelated to current viewers.” The unsupported demand cue can create pressure to book before comparing alternatives.","fairDesignPrinciple":"Use a clearly defined live metric only when supported, including the relevant listing and measurement window.","reviewPrompts":["Which timestamped inventory, reservation, demand or offer event substantiates “Book before demand rises”, and what changes when its limit is reached?","Record the claim, timestamp, data source and post-claim state; which evidence supports “The claim refers to demand, viewers, purchases or bookings rather than remaining stock”?","What happens when the stated limit is reached, and could the observed message be the legitimate case “Remaining-stock claim”?"],"altText":"Side-by-side travel search result interface showing “42 people viewing now” and the clearer alternative “Current availability”.","provenance":"Original hypothetical travel search result example created for this library; no real business, product or interface is depicted."},{"id":"high-demand-claim-scenario-2","title":"Old booking spike presented as current demand","context":"Event ticket page","journeyStage":"Pricing","summary":"A fictional seller says “Selling fast today” using sales from the launch week three months earlier.","problematic":{"label":"Selling fast today","layout":"banner","elements":[{"id":"problematic-1-heading","type":"heading","text":"Selling fast today"},{"id":"problematic-2-body","type":"text","text":"The supporting sales period ended three months ago.","tone":"warning"},{"id":"problematic-3-badge","type":"badge","text":"Tickets moving quickly","tone":"warning"},{"id":"problematic-4-disclosure","type":"disclosure","summary":"Claim basis","content":"No supporting population, period, inventory or offer event is presented with this message.","open":false}],"annotations":[{"targetId":"problematic-2-body","text":"Why this state matters: The message applies immediate pressure at the pricing decision. The cue “Tickets moving quickly” should correspond to a defined operating state and a real consequence. The example instead states: “The supporting sales period ended three months ago.” Historical popularity is framed as immediate demand and may rush a decision."},{"targetId":"problematic-4-disclosure","text":"Review prompt: Which timestamped inventory, reservation, demand or offer event substantiates “Tickets moving quickly”, and what changes when its limit is reached?"}]},"neutral":{"label":"Ticket availability","layout":"banner","elements":[{"id":"neutral-1-heading","type":"heading","text":"Ticket availability"},{"id":"neutral-2-body","type":"text","text":"Remaining allocation and refresh time are shown without a stale demand claim.","tone":"default"},{"id":"neutral-3-badge","type":"badge","text":"312 tickets at 14:05","tone":"default"},{"id":"neutral-4-disclosure","type":"disclosure","summary":"Claim basis","content":"The relevant population, period, inventory or offer state is presented with the message.","open":true},{"id":"neutral-5-link","type":"link","text":"View the source and period for “312 tickets at 14:05”","emphasis":"default"}],"annotations":[{"targetId":"neutral-2-body","text":"Fairer design: State the actual period behind a demand claim or remove the claim when it is no longer current."},{"targetId":"neutral-5-link","text":"Review prompt: Record the claim, timestamp, data source and post-claim state; which evidence supports “It is temporally framed and connected to a transaction”?"}]},"whyItMatters":"The message applies immediate pressure at the pricing decision. The cue “Tickets moving quickly” should correspond to a defined operating state and a real consequence. The example instead states: “The supporting sales period ended three months ago.” Historical popularity is framed as immediate demand and may rush a decision.","fairDesignPrinciple":"State the actual period behind a demand claim or remove the claim when it is no longer current.","reviewPrompts":["Which timestamped inventory, reservation, demand or offer event substantiates “Tickets moving quickly”, and what changes when its limit is reached?","Record the claim, timestamp, data source and post-claim state; which evidence supports “It is temporally framed and connected to a transaction”?","What happens when the stated limit is reached, and could the observed message be the legitimate case “static aggregate popularity claim”?"],"altText":"Side-by-side event ticket page interface showing “Selling fast today” and the clearer alternative “Ticket availability”.","provenance":"Original hypothetical event ticket page example created for this library; no real business, product or interface is depicted."}],"fairAlternative":"Base demand messages on current auditable data and state the metric and period without exaggeration.","whyProblematic":"A claim of unusually high current demand is used to accelerate a decision without a clear or supportable basis. A demand message suggests competition from other buyers without a current, relevant measure connecting that activity to the user’s available offer. These harms describe a review risk, not an automatic legal conclusion. Australian section 28B commences on 1 July 2027 and requires its complete, context-specific test. Existing ACL provisions remain a separate current-law assessment.","contextFactors":["The claim refers to demand, viewers, purchases or bookings rather than remaining stock.","It is temporally framed and connected to a transaction.","Truth and representativeness require provenance or controlled replay.","Boundary to test: Remaining-stock claim","Boundary to test: static aggregate popularity claim","Boundary to test: auditable live demand metric with clear definition"],"affectedTeams":["Product","Design","Engineering","Legal","Compliance"],"reviewQuestions":["Which timestamped inventory, reservation, demand or offer event substantiates “Book before demand rises”, and what changes when its limit is reached?","Record the claim, timestamp, data source and post-claim state; which evidence supports “The claim refers to demand, viewers, purchases or bookings rather than remaining stock”?","What happens when the stated limit is reached, and could the observed message be the legitimate case “Remaining-stock claim”?","Which timestamped inventory, reservation, demand or offer event substantiates “Tickets moving quickly”, and what changes when its limit is reached?","Record the claim, timestamp, data source and post-claim state; which evidence supports “It is temporally framed and connected to a transaction”?","What happens when the stated limit is reached, and could the observed message be the legitimate case “static aggregate popularity claim”?"],"evidence":["Annotated pricing screenshots at each responsive breakpoint","The complete state sequence before, during and after the consumer decision","Design-system component, content, default and configuration records for the reviewed release","Operational records substantiating price, availability, timing and eligibility claims","Usability, accessibility, reversal, complaint and support evidence relevant to consumer impact","A dated product and legal review record identifying evidence, uncertainties and release decisions"],"related":["false-urgency-and-scarcity","limited-time-or-reservation-claim","low-stock-claim","activity-messages"],"sourceIds":["oecd-dark-commercial-patterns-2022","au-act-2026-64"],"altText":"Side-by-side travel search result interface showing “42 people viewing now” and the clearer alternative “Current availability”.","provenance":"Original hypothetical interface comparisons from the shared learning library, adapted to Australian-dollar context for this portal; no real business, product or interface is depicted.","author":"Flowlane","datePublished":"2026-08-10","dateModified":"2026-09-14","lastReviewed":"2026-09-14","changeNote":"Source comparison recorded and the current status restated."},{"title":"Limited-time or reservation claim","slug":"limited-time-or-reservation-claim","preferredName":"Limited-time or reservation claim","directAnswer":"Limited-time or reservation claim is a working label for this design mechanism: A textual deadline or temporary-reservation claim pressures action, particularly where the deadline renews or its stated consequence does not occur. This is editorial implementation guidance for Australian journeys, not a finding of unlawfulness. From 1 July 2027, a similar interface is relevant to ACL section 28B only if the complete consumer-connection, manipulation or unreasonable-distortion and actual-or-likely-detriment test is met. Current ACL rules require a separate assessment.","definition":"A textual deadline or temporary-reservation claim pressures action, particularly where the deadline renews or its stated consequence does not occur. This is a design and research taxonomy for learning and evidence review, not a statutory offence label or an automatic finding that an interface is unlawful.","synonyms":["limited-time message","reservation timeout","offer expires soon","sale ending soon","basket reserved briefly","price held for a stated period","deadline renews on return"],"category":"Urgency","family":"Urgency","journeyStages":["Pricing","Checkout"],"jurisdiction":"Australia","status":"Editorial implementation guidance","howItWorks":"A textual deadline or temporary-reservation claim pressures action, particularly where the deadline renews or its stated consequence does not occur. A stated deadline or hold creates time pressure even though the period renews, the item is not reserved or the represented consequence does not occur.","warningSigns":["The claim describes a time-limited offer, price, availability or reservation.","It is connected to a material decision.","Replay, expiry or backend evidence can test its truth and consequence."],"harms":["A rolling deadline may cause repeated urgency while the offer is effectively permanent.","The user may believe a unique opportunity is protected or will disappear even though the stated reservation has no operational consequence."],"legitimateUses":["Numeric countdown classified separately","genuine disclosed deadline with represented consequence","general seasonal marketing without a concrete temporal claim"],"legalBasis":[{"provision":"ACL section 28B, inserted by the 2026 Act","sourceIds":["au-act-2026-64"],"classification":"Possible risk indicator","explanation":"In pricing and checkout journeys, the limited-time or reservation claim mechanism may warrant review where it manipulates a consumer or unreasonably distorts the decision environment and causes, or is likely to cause, detriment. The urgency label and an interface similarity do not establish a contravention; the complete section 28B test, scope, facts and evidence must be applied from 1 July 2027."},{"provision":"Dark-pattern research taxonomy","sourceIds":["oecd-dark-commercial-patterns-2022"],"classification":"Editorial analysis","explanation":"The cited research sources support this working pattern within the urgency family. It is editorial implementation guidance, not an Australian statutory category, regulator finding or legal safe harbour."}],"examples":[{"type":"Illustrative example","context":"Weekend offer continues every week","scenario":"A fictional service says an annual discount ends Sunday, then automatically replaces the date each Monday while keeping the same price.","harm":"A rolling deadline may cause repeated urgency while the offer is effectively permanent."},{"type":"Illustrative example","context":"Reservation claim persists without a hold","scenario":"A fictional booking page says “This room is reserved for you while you complete booking”, although no inventory is held and the message persists indefinitely.","harm":"The user may believe a unique opportunity is protected or will disappear even though the stated reservation has no operational consequence."}],"problematicUi":{"label":"Offer ends Sunday","copy":"Offer ends Sunday The displayed date rolls forward and the price remains unchanged. Claim discount now Claim basis No supporting population, period, inventory or offer event is presented with this message.","annotations":["Why this state matters: The message applies immediate pressure at the pricing decision. The cue “Claim discount now” should correspond to a defined operating state and a real consequence. The example instead states: “The displayed date rolls forward and the price remains unchanged.” A rolling deadline may cause repeated urgency while the offer is effectively permanent.","Review prompt: Which timestamped inventory, reservation, demand or offer event substantiates “Claim discount now”, and what changes when its limit is reached?"]},"improvedUi":{"label":"Current annual price","copy":"Current annual price No artificial expiry is shown; any future promotion has a fixed recorded period. Choose annual plan Claim basis The relevant population, period, inventory or offer state is presented with the message. View the source and period for “Choose annual plan”","annotations":["Fairer design: Use an end date only where the offer genuinely changes and retain evidence of the stated consequence.","Review prompt: Record the claim, timestamp, data source and post-claim state; which evidence supports “The claim describes a time-limited offer, price, availability or reservation”?"]},"uiComparisons":[{"id":"limited-time-or-reservation-claim-scenario-1","title":"Weekend offer continues every week","context":"Subscription landing page","journeyStage":"Pricing","summary":"A fictional service says an annual discount ends Sunday, then automatically replaces the date each Monday while keeping the same price.","problematic":{"label":"Offer ends Sunday","layout":"banner","elements":[{"id":"problematic-1-heading","type":"heading","text":"Offer ends Sunday"},{"id":"problematic-2-body","type":"text","text":"The displayed date rolls forward and the price remains unchanged.","tone":"warning"},{"id":"problematic-3-badge","type":"badge","text":"Claim discount now","tone":"warning"},{"id":"problematic-4-disclosure","type":"disclosure","summary":"Claim basis","content":"No supporting population, period, inventory or offer event is presented with this message.","open":false}],"annotations":[{"targetId":"problematic-2-body","text":"Why this state matters: The message applies immediate pressure at the pricing decision. The cue “Claim discount now” should correspond to a defined operating state and a real consequence. The example instead states: “The displayed date rolls forward and the price remains unchanged.” A rolling deadline may cause repeated urgency while the offer is effectively permanent."},{"targetId":"problematic-4-disclosure","text":"Review prompt: Which timestamped inventory, reservation, demand or offer event substantiates “Claim discount now”, and what changes when its limit is reached?"}]},"neutral":{"label":"Current annual price","layout":"banner","elements":[{"id":"neutral-1-heading","type":"heading","text":"Current annual price"},{"id":"neutral-2-body","type":"text","text":"No artificial expiry is shown; any future promotion has a fixed recorded period.","tone":"default"},{"id":"neutral-3-badge","type":"badge","text":"Choose annual plan","tone":"default"},{"id":"neutral-4-disclosure","type":"disclosure","summary":"Claim basis","content":"The relevant population, period, inventory or offer state is presented with the message.","open":true},{"id":"neutral-5-link","type":"link","text":"View the source and period for “Choose annual plan”","emphasis":"default"}],"annotations":[{"targetId":"neutral-2-body","text":"Fairer design: Use an end date only where the offer genuinely changes and retain evidence of the stated consequence."},{"targetId":"neutral-5-link","text":"Review prompt: Record the claim, timestamp, data source and post-claim state; which evidence supports “The claim describes a time-limited offer, price, availability or reservation”?"}]},"whyItMatters":"The message applies immediate pressure at the pricing decision. The cue “Claim discount now” should correspond to a defined operating state and a real consequence. The example instead states: “The displayed date rolls forward and the price remains unchanged.” A rolling deadline may cause repeated urgency while the offer is effectively permanent.","fairDesignPrinciple":"Use an end date only where the offer genuinely changes and retain evidence of the stated consequence.","reviewPrompts":["Which timestamped inventory, reservation, demand or offer event substantiates “Claim discount now”, and what changes when its limit is reached?","Record the claim, timestamp, data source and post-claim state; which evidence supports “The claim describes a time-limited offer, price, availability or reservation”?","What happens when the stated limit is reached, and could the observed message be the legitimate case “Numeric countdown classified separately”?"],"altText":"Side-by-side subscription landing page interface showing “Offer ends Sunday” and the clearer alternative “Current annual price”.","provenance":"Original hypothetical subscription landing page example created for this library; no real business, product or interface is depicted."},{"id":"limited-time-or-reservation-claim-scenario-2","title":"Reservation claim persists without a hold","context":"Accommodation checkout","journeyStage":"Checkout","summary":"A fictional booking page says “This room is reserved for you while you complete booking”, although no inventory is held and the message persists indefinitely.","problematic":{"label":"Room reserved for you","layout":"banner","elements":[{"id":"problematic-1-heading","type":"heading","text":"Room reserved for you"},{"id":"problematic-2-body","type":"text","text":"The claim persists without an inventory record or release event.","tone":"warning"},{"id":"problematic-3-badge","type":"badge","text":"Reserved while you book","tone":"warning"},{"id":"problematic-4-disclosure","type":"disclosure","summary":"Claim basis","content":"No supporting population, period, inventory or offer event is presented with this message.","open":false}],"annotations":[{"targetId":"problematic-2-body","text":"Why this state matters: The message applies immediate pressure at the checkout decision. The cue “Reserved while you book” should correspond to a defined operating state and a real consequence. The example instead states: “The claim persists without an inventory record or release event.” The user may believe a unique opportunity is protected or will disappear even though the stated reservation has no operational consequence."},{"targetId":"problematic-4-disclosure","text":"Review prompt: Which timestamped inventory, reservation, demand or offer event substantiates “Reserved while you book”, and what changes when its limit is reached?"}]},"neutral":{"label":"Room availability checked","layout":"banner","elements":[{"id":"neutral-1-heading","type":"heading","text":"Room availability checked"},{"id":"neutral-2-body","type":"text","text":"No hold is claimed; the user can refresh current availability before payment.","tone":"default"},{"id":"neutral-3-badge","type":"badge","text":"Check availability again","tone":"default"},{"id":"neutral-4-disclosure","type":"disclosure","summary":"Claim basis","content":"The relevant population, period, inventory or offer state is presented with the message.","open":true},{"id":"neutral-5-link","type":"link","text":"View the source and period for “Check availability again”","emphasis":"default"}],"annotations":[{"targetId":"neutral-2-body","text":"Fairer design: State a reservation only when inventory is actually held, identify what event releases it and show the post-release state truthfully."},{"targetId":"neutral-5-link","text":"Review prompt: Record the claim, timestamp, data source and post-claim state; which evidence supports “It is connected to a material decision”?"}]},"whyItMatters":"The message applies immediate pressure at the checkout decision. The cue “Reserved while you book” should correspond to a defined operating state and a real consequence. The example instead states: “The claim persists without an inventory record or release event.” The user may believe a unique opportunity is protected or will disappear even though the stated reservation has no operational consequence.","fairDesignPrinciple":"State a reservation only when inventory is actually held, identify what event releases it and show the post-release state truthfully.","reviewPrompts":["Which timestamped inventory, reservation, demand or offer event substantiates “Reserved while you book”, and what changes when its limit is reached?","Record the claim, timestamp, data source and post-claim state; which evidence supports “It is connected to a material decision”?","What happens when the stated limit is reached, and could the observed message be the legitimate case “genuine disclosed deadline with represented consequence”?"],"altText":"Side-by-side accommodation checkout interface showing “Room reserved for you” and the clearer alternative “Room availability checked”.","provenance":"Original hypothetical accommodation checkout example created for this library; no real business, product or interface is depicted."}],"fairAlternative":"Use genuine fixed time limits, state the consequence accurately, and stop displaying the claim when it expires.","whyProblematic":"A textual deadline or temporary-reservation claim pressures action, particularly where the deadline renews or its stated consequence does not occur. A stated deadline or hold creates time pressure even though the period renews, the item is not reserved or the represented consequence does not occur. These harms describe a review risk, not an automatic legal conclusion. Australian section 28B commences on 1 July 2027 and requires its complete, context-specific test. Existing ACL provisions remain a separate current-law assessment.","contextFactors":["The claim describes a time-limited offer, price, availability or reservation.","It is connected to a material decision.","Replay, expiry or backend evidence can test its truth and consequence.","Boundary to test: Numeric countdown classified separately","Boundary to test: genuine disclosed deadline with represented consequence","Boundary to test: general seasonal marketing without a concrete temporal claim"],"affectedTeams":["Product","Design","Engineering","Legal","Compliance"],"reviewQuestions":["Which timestamped inventory, reservation, demand or offer event substantiates “Claim discount now”, and what changes when its limit is reached?","Record the claim, timestamp, data source and post-claim state; which evidence supports “The claim describes a time-limited offer, price, availability or reservation”?","What happens when the stated limit is reached, and could the observed message be the legitimate case “Numeric countdown classified separately”?","Which timestamped inventory, reservation, demand or offer event substantiates “Reserved while you book”, and what changes when its limit is reached?","Record the claim, timestamp, data source and post-claim state; which evidence supports “It is connected to a material decision”?","What happens when the stated limit is reached, and could the observed message be the legitimate case “genuine disclosed deadline with represented consequence”?"],"evidence":["Annotated pricing and checkout screenshots at each responsive breakpoint","The complete state sequence before, during and after the consumer decision","Design-system component, content, default and configuration records for the reviewed release","Operational records substantiating price, availability, timing and eligibility claims","Usability, accessibility, reversal, complaint and support evidence relevant to consumer impact","A dated product and legal review record identifying evidence, uncertainties and release decisions"],"related":["false-urgency-and-scarcity","high-demand-claim","low-stock-claim","activity-messages"],"sourceIds":["oecd-dark-commercial-patterns-2022","au-act-2026-64"],"altText":"Side-by-side subscription landing page interface showing “Offer ends Sunday” and the clearer alternative “Current annual price”.","provenance":"Original hypothetical interface comparisons from the shared learning library, adapted to Australian-dollar context for this portal; no real business, product or interface is depicted.","author":"Flowlane","datePublished":"2026-08-10","dateModified":"2026-09-14","lastReviewed":"2026-09-14","changeNote":"Source comparison recorded and the current status restated."},{"title":"Low-stock claim","slug":"low-stock-claim","preferredName":"Low-stock claim","directAnswer":"Low-stock claim is a working label for this design mechanism: A claim that few units remain applies purchase pressure, especially where inventory basis or persistence is unsupported. This is editorial implementation guidance for Australian journeys, not a finding of unlawfulness. From 1 July 2027, a similar interface is relevant to ACL section 28B only if the complete consumer-connection, manipulation or unreasonable-distortion and actual-or-likely-detriment test is met. Current ACL rules require a separate assessment.","definition":"A claim that few units remain applies purchase pressure, especially where inventory basis or persistence is unsupported. This is a design and research taxonomy for learning and evidence review, not a statutory offence label or an automatic finding that an interface is unlawful.","synonyms":["scarcity stock message","only a few left","only two left","last item","stock badge unchanged over time","per-user fabricated inventory"],"category":"Urgency","family":"Urgency","journeyStages":["Pricing","Checkout"],"jurisdiction":"Australia","status":"Editorial implementation guidance","howItWorks":"A claim that few units remain applies purchase pressure, especially where inventory basis or persistence is unsupported. A quantity statement implies imminent unavailability without identifying the relevant variant, location or auditable stock state behind the number.","warningSigns":["The claim refers to remaining inventory quantity.","It appears near a transactional decision.","Falsity or misleading persistence requires replay or inventory evidence."],"harms":["A shopper may rush or skip comparison because a broad scarcity claim appears precise.","The scope of the claim can exaggerate scarcity and accelerate purchase."],"legitimateUses":["High demand without remaining quantity","A genuine time-limited offer that makes no claim about remaining inventory quantity","Accurate live stock count with auditable basis","A fulfilment limitation that states the relevant location, variant and current inventory source"],"legalBasis":[{"provision":"ACL section 28B, inserted by the 2026 Act","sourceIds":["au-act-2026-64"],"classification":"Possible risk indicator","explanation":"In pricing and checkout journeys, the low-stock claim mechanism may warrant review where it manipulates a consumer or unreasonably distorts the decision environment and causes, or is likely to cause, detriment. The urgency label and an interface similarity do not establish a contravention; the complete section 28B test, scope, facts and evidence must be applied from 1 July 2027."},{"provision":"Dark-pattern research taxonomy","sourceIds":["oecd-dark-commercial-patterns-2022"],"classification":"Editorial analysis","explanation":"The cited research sources support this working pattern within the urgency family. It is editorial implementation guidance, not an Australian statutory category, regulator finding or legal safe harbour."}],"examples":[{"type":"Illustrative example","context":"Generic “only one left” across every variant","scenario":"A fictional store displays “Only one left” for every size and colour even though the warning is not linked to variant-level inventory.","harm":"A shopper may rush or skip comparison because a broad scarcity claim appears precise."},{"type":"Illustrative example","context":"Warehouse stock used to imply online scarcity","scenario":"A fictional retailer says “Last item online” by counting one local warehouse while identical inventory is available through its normal fulfilment network.","harm":"The scope of the claim can exaggerate scarcity and accelerate purchase."}],"problematicUi":{"label":"Only one left","copy":"Only one left The same warning appears for all sizes regardless of stock. 1 remaining Claim basis No supporting population, period, inventory or offer event is presented with this message.","annotations":["Why this state matters: The message applies immediate pressure at the pricing decision. The cue “1 remaining” should correspond to a defined operating state and a real consequence. The example instead states: “The same warning appears for all sizes regardless of stock.” A shopper may rush or skip comparison because a broad scarcity claim appears precise.","Review prompt: Which timestamped inventory, reservation, demand or offer event substantiates “1 remaining”, and what changes when its limit is reached?"]},"improvedUi":{"label":"Stock for selected size","copy":"Stock for selected size The message reflects the chosen variant and current inventory. Size M · 4 available Claim basis The relevant population, period, inventory or offer state is presented with the message. View the source and period for “Size M · 4 available”","annotations":["Fairer design: Tie stock messages to the selected item and timestamped inventory, or omit them when the basis is unavailable.","Review prompt: Record the claim, timestamp, data source and post-claim state; which evidence supports “The claim refers to remaining inventory quantity”?"]},"uiComparisons":[{"id":"low-stock-claim-scenario-1","title":"Generic “only one left” across every variant","context":"Fashion product page","journeyStage":"Pricing","summary":"A fictional store displays “Only one left” for every size and colour even though the warning is not linked to variant-level inventory.","problematic":{"label":"Only one left","layout":"banner","elements":[{"id":"problematic-1-heading","type":"heading","text":"Only one left"},{"id":"problematic-2-body","type":"text","text":"The same warning appears for all sizes regardless of stock.","tone":"warning"},{"id":"problematic-3-badge","type":"badge","text":"1 remaining","tone":"warning"},{"id":"problematic-4-disclosure","type":"disclosure","summary":"Claim basis","content":"No supporting population, period, inventory or offer event is presented with this message.","open":false}],"annotations":[{"targetId":"problematic-2-body","text":"Why this state matters: The message applies immediate pressure at the pricing decision. The cue “1 remaining” should correspond to a defined operating state and a real consequence. The example instead states: “The same warning appears for all sizes regardless of stock.” A shopper may rush or skip comparison because a broad scarcity claim appears precise."},{"targetId":"problematic-4-disclosure","text":"Review prompt: Which timestamped inventory, reservation, demand or offer event substantiates “1 remaining”, and what changes when its limit is reached?"}]},"neutral":{"label":"Stock for selected size","layout":"banner","elements":[{"id":"neutral-1-heading","type":"heading","text":"Stock for selected size"},{"id":"neutral-2-body","type":"text","text":"The message reflects the chosen variant and current inventory.","tone":"default"},{"id":"neutral-3-badge","type":"badge","text":"Size M · 4 available","tone":"default"},{"id":"neutral-4-disclosure","type":"disclosure","summary":"Claim basis","content":"The relevant population, period, inventory or offer state is presented with the message.","open":true},{"id":"neutral-5-link","type":"link","text":"View the source and period for “Size M · 4 available”","emphasis":"default"}],"annotations":[{"targetId":"neutral-2-body","text":"Fairer design: Tie stock messages to the selected item and timestamped inventory, or omit them when the basis is unavailable."},{"targetId":"neutral-5-link","text":"Review prompt: Record the claim, timestamp, data source and post-claim state; which evidence supports “The claim refers to remaining inventory quantity”?"}]},"whyItMatters":"The message applies immediate pressure at the pricing decision. The cue “1 remaining” should correspond to a defined operating state and a real consequence. The example instead states: “The same warning appears for all sizes regardless of stock.” A shopper may rush or skip comparison because a broad scarcity claim appears precise.","fairDesignPrinciple":"Tie stock messages to the selected item and timestamped inventory, or omit them when the basis is unavailable.","reviewPrompts":["Which timestamped inventory, reservation, demand or offer event substantiates “1 remaining”, and what changes when its limit is reached?","Record the claim, timestamp, data source and post-claim state; which evidence supports “The claim refers to remaining inventory quantity”?","What happens when the stated limit is reached, and could the observed message be the legitimate case “High demand without remaining quantity”?"],"altText":"Side-by-side fashion product page interface showing “Only one left” and the clearer alternative “Stock for selected size”.","provenance":"Original hypothetical fashion product page example created for this library; no real business, product or interface is depicted."},{"id":"low-stock-claim-scenario-2","title":"Warehouse stock used to imply online scarcity","context":"Appliance checkout","journeyStage":"Checkout","summary":"A fictional retailer says “Last item online” by counting one local warehouse while identical inventory is available through its normal fulfilment network.","problematic":{"label":"Last one available","layout":"banner","elements":[{"id":"problematic-1-heading","type":"heading","text":"Last one available"},{"id":"problematic-2-body","type":"text","text":"The warning omits that other normal fulfilment stock exists.","tone":"warning"},{"id":"problematic-3-badge","type":"badge","text":"Buy before it is gone","tone":"warning"},{"id":"problematic-4-disclosure","type":"disclosure","summary":"Claim basis","content":"No supporting population, period, inventory or offer event is presented with this message.","open":false}],"annotations":[{"targetId":"problematic-2-body","text":"Why this state matters: The message applies immediate pressure at the checkout decision. The cue “Buy before it is gone” should correspond to a defined operating state and a real consequence. The example instead states: “The warning omits that other normal fulfilment stock exists.” The scope of the claim can exaggerate scarcity and accelerate purchase."},{"targetId":"problematic-4-disclosure","text":"Review prompt: Which timestamped inventory, reservation, demand or offer event substantiates “Buy before it is gone”, and what changes when its limit is reached?"}]},"neutral":{"label":"Local delivery availability","layout":"banner","elements":[{"id":"neutral-1-heading","type":"heading","text":"Local delivery availability"},{"id":"neutral-2-body","type":"text","text":"The message names the location and alternative fulfilment option.","tone":"default"},{"id":"neutral-3-badge","type":"badge","text":"1 local · delivery stock available","tone":"default"},{"id":"neutral-4-disclosure","type":"disclosure","summary":"Claim basis","content":"The relevant population, period, inventory or offer state is presented with the message.","open":true},{"id":"neutral-5-link","type":"link","text":"View the source and period for “1 local · delivery stock available”","emphasis":"default"}],"annotations":[{"targetId":"neutral-2-body","text":"Fairer design: State the relevant inventory scope and delivery constraint in language the buyer can understand."},{"targetId":"neutral-5-link","text":"Review prompt: Record the claim, timestamp, data source and post-claim state; which evidence supports “It appears near a transactional decision”?"}]},"whyItMatters":"The message applies immediate pressure at the checkout decision. The cue “Buy before it is gone” should correspond to a defined operating state and a real consequence. The example instead states: “The warning omits that other normal fulfilment stock exists.” The scope of the claim can exaggerate scarcity and accelerate purchase.","fairDesignPrinciple":"State the relevant inventory scope and delivery constraint in language the buyer can understand.","reviewPrompts":["Which timestamped inventory, reservation, demand or offer event substantiates “Buy before it is gone”, and what changes when its limit is reached?","Record the claim, timestamp, data source and post-claim state; which evidence supports “It appears near a transactional decision”?","What happens when the stated limit is reached, and could the observed message be the legitimate case “time-limited offer”?"],"altText":"Side-by-side appliance checkout interface showing “Last one available” and the clearer alternative “Local delivery availability”.","provenance":"Original hypothetical appliance checkout example created for this library; no real business, product or interface is depicted."}],"fairAlternative":"Use current inventory data, avoid false precision, and remove or update the claim promptly when stock changes.","whyProblematic":"A claim that few units remain applies purchase pressure, especially where inventory basis or persistence is unsupported. A quantity statement implies imminent unavailability without identifying the relevant variant, location or auditable stock state behind the number. These harms describe a review risk, not an automatic legal conclusion. Australian section 28B commences on 1 July 2027 and requires its complete, context-specific test. Existing ACL provisions remain a separate current-law assessment.","contextFactors":["The claim refers to remaining inventory quantity.","It appears near a transactional decision.","Falsity or misleading persistence requires replay or inventory evidence.","Boundary to test: High demand without remaining quantity","Boundary to test: A genuine time-limited offer that makes no claim about remaining inventory quantity","Boundary to test: Accurate live stock count with auditable basis","Boundary to test: A fulfilment limitation that states the relevant location, variant and current inventory source"],"affectedTeams":["Product","Design","Engineering","Legal","Compliance"],"reviewQuestions":["Which timestamped inventory, reservation, demand or offer event substantiates “1 remaining”, and what changes when its limit is reached?","Record the claim, timestamp, data source and post-claim state; which evidence supports “The claim refers to remaining inventory quantity”?","What happens when the stated limit is reached, and could the observed message be the legitimate case “High demand without remaining quantity”?","Which timestamped inventory, reservation, demand or offer event substantiates “Buy before it is gone”, and what changes when its limit is reached?","Record the claim, timestamp, data source and post-claim state; which evidence supports “It appears near a transactional decision”?","What happens when the stated limit is reached, and could the observed message be the legitimate case “time-limited offer”?"],"evidence":["Annotated pricing and checkout screenshots at each responsive breakpoint","The complete state sequence before, during and after the consumer decision","Design-system component, content, default and configuration records for the reviewed release","Operational records substantiating price, availability, timing and eligibility claims","Usability, accessibility, reversal, complaint and support evidence relevant to consumer impact","A dated product and legal review record identifying evidence, uncertainties and release decisions"],"related":["false-urgency-and-scarcity","high-demand-claim","limited-time-or-reservation-claim","activity-messages"],"sourceIds":["oecd-dark-commercial-patterns-2022","au-act-2026-64"],"altText":"Side-by-side fashion product page interface showing “Only one left” and the clearer alternative “Stock for selected size”.","provenance":"Original hypothetical interface comparisons from the shared learning library, adapted to Australian-dollar context for this portal; no real business, product or interface is depicted.","author":"Flowlane","datePublished":"2026-08-10","dateModified":"2026-09-14","lastReviewed":"2026-09-14","changeNote":"Source comparison recorded and the current status restated."}]}