Interface interference · Australia
Bundled options
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.
- Family
- Interface interference
- Also known as
- Journey stages
Definition
What is this pattern?
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.
How it works
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.
Warning signs
- 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.
Potential 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.
Learn by comparison
What does this look like?
These fictional examples make the design mechanism easier to recognise. They do not depict a real company and do not establish that an individual interface is unlawful.
Illustrative example 1 · Ticket and travel pass presented as one package
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.
Potential consumer harm: A customer may pay for an unwanted component because two distinct products are presented as one indivisible choice.
Illustrative example 2 · Support and migration locked into one plan
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.
Potential consumer harm: A buyer may pay for unwanted services or misunderstand which components are optional.
Ticket and travel pass presented as one package
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.
Ticket plus city travel. The only visible selection combines entry and an optional transport product.. Selected: Choose package $78. Not selected: Choose ticket only $65
Build your booking. The $65 ticket and optional $13 travel pass have separate controls.. Not selected: Choose ticket only $65. Not selected: Choose package $78. Choice consequences, expanded: The consequence of selecting “Choose ticket only $65” is displayed beside the option.
Why the first version can mislead: 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.
What a fairer design does: Show the event ticket and optional travel pass as separately priced selections before the basket changes.
Show annotated differences (4)
- The only visible selection combines entry and an optional transport product.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.
- Not selected: Choose ticket only $65Review prompt: Do “Choose package $78” and “Choose ticket only $65” receive comparable prominence and explain their consequences before activation?
- The $65 ticket and optional $13 travel pass have separate controls.Fairer design: Show the event ticket and optional travel pass as separately priced selections before the basket changes.
- Choice consequences, expanded: The consequence of selecting “Choose ticket only $65” is displayed beside the option.Review prompt: Capture every peer option, its default state and visual prominence; do those states support “One control has two or more separable consequences”?
Review questions (3)
- 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”?
Support and migration locked into one plan
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.
Complete launch bundle. Core access, support and migration appear as one unavoidable selection.. Displayed amount: $480. Core plan $260/month
Build your plan. Core access and genuinely optional services are priced separately.. Displayed amount: $260. $480/month. Price, period and commitment, expanded: The price and material terms associated with “Core plan $260/month” remain beside this choice.
Why the first version can mislead: 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.
What a fairer design does: Show the core service and separable extras with individual prices and controls, or explain why a bundle cannot be split.
Show annotated differences (4)
- Core access, support and migration appear as one unavoidable selection.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.
- Core plan $260/monthReview prompt: Do “$480/month” and “Core plan $260/month” receive comparable prominence and explain their consequences before activation?
- Core access and genuinely optional services are priced separately.Fairer design: Show the core service and separable extras with individual prices and controls, or explain why a bundle cannot be split.
- Price, period and commitment, expanded: The price and material terms associated with “Core plan $260/month” remain beside this choice.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”?
Review questions (3)
- 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”?
What is a fairer alternative?
Show component consequences and prices and provide granular, equally accessible choices where components are separable.
Legal and information status
How Australian law may apply
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.
ACL section 28B, inserted by the 2026 Act
Possible risk indicator
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.
Dark-pattern research taxonomy
Editorial analysis
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.
Evidence layers and open questions
Applicable law, enforcement records, policy preparation, stakeholder input, editorial analysis and unknown future details remain visibly distinct.
Final Act mappingEditorial implementation guidance
This editorial practice label is not itself an express statutory prohibition. Apply the complete provision and its scope to the facts.
Possible general-test applicationCommences 1 July 2027
ACL section 28B, inserted by the 2026 Act: 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.
Existing ACLCurrent enforcement
Existing ACL provisions continue to apply on their own elements before and after commencement. The 2027 provisions must not be applied early.
Verified enforcement contextCurrent enforcement
No named pattern-specific enforcement example is asserted on this page. Existing ACL analysis remains fact-specific and separate from the 2027 provisions.
RegulationsRegulation pending
Later regulations may affect specified exclusions, matters or exceptions. That uncertainty does not postpone a core enacted rule unless the provision itself depends on prescription.
Regulator implementation materialGuidance pending
Government funding and parliamentary material anticipate regulator education and guidance. No dedicated final ACCC implementation guide is treated here as published.
Journey and evidence recommendationsEditorial implementation guidance
Show component consequences and prices and provide granular, equally accessible choices where components are separable. This is editorial portal guidance, not a statutory duty, regulator safe harbour or compliance certificate.
Context matters
Context and boundary cases
- 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
When a similar design can serve a legitimate purpose
- Genuinely indivisible product
- transparent bundle with equally accessible component options and prices
Operational review
What teams should review
- Teams
- 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 to retain
- 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
Legal map and implementation tools
Evidence base
Sources
- An Ontology of Dark Patterns KnowledgeGray et al.; ACM CHI 2024 · Secondary · checked 2026-09-14 · DOI 10.1145/3613904.3642436; arXiv:2309.09640
- Behavioural study on unfair commercial practices in the digital environmentEuropean Commission, Directorate-General for Justice and Consumers · Secondary · checked 2026-09-14 · DOI 10.2838/859030; ISBN 978-92-76-52316-1
- Competition and Consumer Amendment (Unfair Trading Practices) Act 2026Federal Register of Legislation · Primary · checked 2026-09-14 · C2026A00064
- Competition and Consumer Act 2010, including Schedule 2: Australian Consumer LawFederal Register of Legislation · Primary · checked 2026-09-14 · C2004A00109
- Unfair trading tricks and traps to be bannedTreasury Ministers · Primary · checked 2026-09-14
- Inquiry into the Competition and Consumer Amendment (Unfair Trading Practices) Bill 2026Senate Economics Legislation Committee · Primary · checked 2026-08-09