Forced action · Australia
Contact harvesting and coerced referrals
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.
- Family
- Forced action
- Also known as
- Journey stages
Definition
What is this pattern?
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.
How it works
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.
Warning signs
- 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.
Potential 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.
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 · Address-book import blocks onboarding
A fictional community app stops onboarding at an address-book permission screen and gives no visible way to continue without uploading contacts.
Potential consumer harm: Contacts who never used the service may be exposed or invited, while the new user loses a meaningful refusal.
Illustrative example 2 · Feature unlocked by recruiting friends
A fictional workspace keeps export disabled until the user supplies three colleagues’ addresses and sends invitations from the service.
Potential consumer harm: The user is pressured to disclose other people’s contact data and send messages unrelated to the export task.
Address-book import blocks onboarding
A fictional community app stops onboarding at an address-book permission screen and gives no visible way to continue without uploading contacts.
Find everyone you know. Onboarding cannot continue until contacts are uploaded.. Allow contacts. Skip for now
Find contacts later. Contact discovery is optional and onboarding can continue without it.. Skip for now. Allow contacts. What happens next, expanded: Activating “Skip for now” produces the outcome stated on the control.
Why the first version can mislead: 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.
What a fairer design does: Explain the optional discovery benefit, provide a visible skip control and do not prepare invitations without a separate deliberate action.
Show annotated differences (4)
- Onboarding cannot continue until contacts are uploaded.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.
- Skip for nowReview 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?
- Contact discovery is optional and onboarding can continue without it.Fairer design: Explain the optional discovery benefit, provide a visible skip control and do not prepare invitations without a separate deliberate action.
- What happens next, expanded: Activating “Skip for now” produces the outcome stated on the control.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”?
Review questions (3)
- 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?
Feature unlocked by recruiting friends
A fictional workspace keeps export disabled until the user supplies three colleagues’ addresses and sends invitations from the service.
Invite three people to export. The export link stays locked until three invitations are sent.. Add contacts. Unconfirmed state: Add contacts
Export your workspace. Export works independently; inviting collaborators remains optional.. Download export. Saved state: Download export. Persisted account state, expanded: The saved state behind “Download export” remains consistent after refresh and across supported channels.
Why the first version can mislead: 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.
What a fairer design does: Keep export independent of referrals and let users invite collaborators only when collaboration is their chosen goal.
Show annotated differences (4)
- The export link stays locked until three invitations are sent.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.
- Unconfirmed state: Add contactsReview prompt: What functional need makes “Add contacts” necessary for the collaboration workspace goal, and can that need be met with less disclosure or commitment?
- Export works independently; inviting collaborators remains optional.Fairer design: Keep export independent of referrals and let users invite collaborators only when collaboration is their chosen goal.
- Persisted account state, expanded: The saved state behind “Download export” remains consistent after refresh and across supported channels.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?
Review questions (3)
- 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?
What is a fairer alternative?
Make contact access and referrals optional, granular and previewable; require affirmative confirmation for every recipient and message.
Legal and information status
How Australian law may apply
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.
ACL section 28B, inserted by the 2026 Act
Possible risk indicator
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.
Dark-pattern research taxonomy
Editorial analysis
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.
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 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.
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
Make contact access and referrals optional, granular and previewable; require affirmative confirmation for every recipient and message. This is editorial portal guidance, not a statutory duty, regulator safe harbour or compliance certificate.
Context matters
Context and boundary cases
- 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
When a similar design can serve a legitimate purpose
- Voluntary one-recipient sharing with preview and confirmation
- clearly optional referral program with no functional penalty
Operational review
What teams should review
- Teams
- 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 to retain
- 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
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