Obstruction · Australia
Comparison prevention
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.
- Family
- Obstruction
- Also known as
- Journey stages
Definition
What is this pattern?
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.
How it works
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.
Warning signs
- 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.
Potential 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.
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 · Plans use incompatible pricing units
A fictional provider shows one plan per week, another per four weeks and a third per gigabyte, without a consistent total or usage assumption.
Potential consumer harm: Customers cannot make a meaningful like-for-like comparison and may select a plan with a higher real cost.
Illustrative example 2 · Plan details cannot be retained side by side
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.
Potential consumer harm: A shopper may be unable to compare material dimensions and may default to the plan the interface opens last.
Plans use incompatible pricing units
A fictional provider shows one plan per week, another per four weeks and a third per gigabyte, without a consistent total or usage assumption.
Three ways to save. Prices use weekly, four-week and usage units with no common baseline.. Displayed amount: $8. Open comparison table
Compare monthly cost. Every plan shows the same monthly basis, data allowance, term and total.. Open comparison table. From $8. Price, period and commitment, expanded: The price and material terms associated with “Open comparison table” remain beside this choice.
Why the first version can mislead: 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.
What a fairer design does: Add a consistent billing-period total, usage basis and sortable comparison while preserving original terms.
Show annotated differences (4)
- Prices use weekly, four-week and usage units with no common baseline.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.
- Open comparison tableReview prompt: How many steps, waits and channel changes separate “From $8” from the completed telecom comparison outcome?
- Every plan shows the same monthly basis, data allowance, term and total.Fairer design: Add a consistent billing-period total, usage basis and sortable comparison while preserving original terms.
- Price, period and commitment, expanded: The price and material terms associated with “Open comparison table” remain beside this choice.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”?
Review questions (3)
- 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?
Plan details cannot be retained side by side
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.
Review one plan. Opening another quote removes the earlier plan and changes the order of attributes.. Open next quote. Open comparison table
Compare three quotes. Selected plans remain visible in one consistent table.. Open comparison table. Open next quote. Price, period and commitment, expanded: The price and material terms associated with “Open comparison table” remain beside this choice.
Why the first version can mislead: 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.
What a fairer design does: Provide a durable side-by-side table with consistent price, limit, excess and exclusion fields, while keeping source detail available.
Show annotated differences (4)
- Opening another quote removes the earlier plan and changes the order of attributes.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.
- Open comparison tableReview prompt: How many steps, waits and channel changes separate “Open next quote” from the completed insurance quote comparison outcome?
- Selected plans remain visible in one consistent table.Fairer design: Provide a durable side-by-side table with consistent price, limit, excess and exclusion fields, while keeping source detail available.
- Price, period and commitment, expanded: The price and material terms associated with “Open comparison table” remain beside this choice.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”?
Review questions (3)
- 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?
What is a fairer alternative?
Use consistent units, terminology and side-by-side material totals with accessible supporting detail.
Legal and information status
How Australian law may apply
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.
ACL section 28B, inserted by the 2026 Act
Possible risk indicator
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.
Dark-pattern research taxonomy
Editorial analysis
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.
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 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.
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
Use consistent units, terminology and side-by-side material totals with accessible supporting detail. This is editorial portal guidance, not a statutory duty, regulator safe harbour or compliance certificate.
Context matters
Context and boundary cases
- 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
When a similar design can serve a legitimate purpose
- Inherent differences that cannot be expressed on a shared basis
- optional advanced detail with a complete comparable summary
- minor cosmetic inconsistency
Operational review
What teams should review
- Teams
- 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 to retain
- 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
Legal map and implementation tools
Evidence base
Sources
- Dark commercial patternsOrganisation for Economic Co-operation and Development · Secondary · checked 2026-09-14 · OECD Digital Economy Papers No. 336
- 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