Forced action · Australia
Gamified or paid access coercion
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.
- Family
- Forced action
- Also known as
- Journey stages
Definition
What is this pattern?
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.
How it works
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.
Warning signs
- 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.
Potential 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.
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 · Energy gate before a purchased level
A fictional game sells a chapter pass but requires hours of repetitive daily tasks or another payment before the purchased final level becomes playable.
Potential consumer harm: Players may pay twice or spend unplanned time to reach content they reasonably understood was included.
Illustrative example 2 · Reward loop required for document export
A fictional study service makes certificate export depend on completing seven daily streak tasks that were not disclosed when the course was bought.
Potential consumer harm: Learners may be forced into additional engagement or lose a completion record they already earned.
Energy gate before a purchased level
A fictional game sells a chapter pass but requires hours of repetitive daily tasks or another payment before the purchased final level becomes playable.
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
Complete chapter access · $12. All purchased levels are available; optional challenges are labelled separately.. Play purchased level. Unlock boost $6. Price, period and commitment, expanded: The price and material terms associated with “Play purchased level” remain beside this choice.
Why the first version can mislead: 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.
What a fairer design does: State the access conditions before purchase and provide a direct route to purchased content without undisclosed grinding or another charge.
Show annotated differences (4)
- The final level also needs 4,000 energy points or a $6 boost.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.
- Play purchased levelReview 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?
- All purchased levels are available; optional challenges are labelled separately.Fairer design: State the access conditions before purchase and provide a direct route to purchased content without undisclosed grinding or another charge.
- Price, period and commitment, expanded: The price and material terms associated with “Play purchased level” remain beside this choice.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”?
Review questions (3)
- 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?
Reward loop required for document export
A fictional study service makes certificate export depend on completing seven daily streak tasks that were not disclosed when the course was bought.
Keep the streak to export. Seven more daily tasks are required before the certificate link activates.. Return tomorrow. Unconfirmed state: Return tomorrow
Your certificate is ready. Course completion unlocks export immediately; practice streaks remain optional.. Download certificate. Saved state: Download certificate. Persisted account state, expanded: The saved state behind “Download certificate” 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: “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.
What a fairer design does: Provide the earned certificate directly and present streak activities as optional learning support.
Show annotated differences (4)
- Seven more daily tasks are required before the certificate link activates.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.
- Unconfirmed state: Return tomorrowReview prompt: What functional need makes “Return tomorrow” necessary for the learning platform goal, and can that need be met with less disclosure or commitment?
- Course completion unlocks export immediately; practice streaks remain optional.Fairer design: Provide the earned certificate directly and present streak activities as optional learning support.
- Persisted account state, expanded: The saved state behind “Download certificate” remains consistent after refresh and across supported channels.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?
Review questions (3)
- 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?
What is a fairer alternative?
Disclose access conditions before acquisition and avoid making disproportionate repetition or surprise payment the practical path to expected functionality.
Legal and information status
How Australian law may apply
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.
ACL section 28B, inserted by the 2026 Act
Possible risk indicator
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.
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 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.
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
Disclose access conditions before acquisition and avoid making disproportionate repetition or surprise payment the practical path to expected functionality. This is editorial portal guidance, not a statutory duty, regulator safe harbour or compliance certificate.
Context matters
Context and boundary cases
- 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
When a similar design can serve a legitimate purpose
- Ordinary progression intrinsic to a game and transparently described
- clearly disclosed optional cosmetic purchases
Operational review
What teams should review
- Teams
- 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 to retain
- 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
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