Obstruction · Australia
Intermediate currency
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.
- Family
- Obstruction
- Also known as
- Journey stages
Definition
What is this pattern?
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.
How it works
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.
Warning signs
- 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.
Potential 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.
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 · Gem bundle hides an item’s real-money cost
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.
Potential consumer harm: Players may struggle to understand the real cost and must buy more currency than the item requires.
Illustrative example 2 · Unused tokens remain after a service booking
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.
Potential consumer harm: The customer may spend more than the service price and retain value that is difficult to use or recover.
Gem bundle hides an item’s real-money cost
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.
Legendary item · 1,350 gems. Gem bundles obscure that the smallest sufficient purchase costs $19.99.. Buy more gems. Review $19.99 bundle
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, expanded: The summary shows the line items and total before “Review $19.99 bundle” is activated.
Why the first version can mislead: 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.
What a fairer design does: Show the real-money equivalent, available balance and exact currency shortfall before purchase.
Show annotated differences (4)
- Gem bundles obscure that the smallest sufficient purchase costs $19.99.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 $19.99 bundleReview prompt: How many steps, waits and channel changes separate “Buy more gems” from the completed in-game store outcome?
- Balance, shortfall and actual bundle cost are visible before commitment.Fairer design: Show the real-money equivalent, available balance and exact currency shortfall before purchase.
- Payable total and selected items, expanded: The summary shows the line items and total before “Review $19.99 bundle” is activated.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”?
Review questions (3)
- 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?
Unused tokens remain after a service booking
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.
Book for 84 tokens. Only a 100-token bundle can be purchased and the $ value is remote.. Buy 100 tokens. Pay exact amount
Book for $8.40. Direct payment is available; token use shows conversion and remaining balance.. Pay exact amount. Buy 100 tokens. Price, period and commitment, expanded: The price and material terms associated with “Pay exact amount” 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 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.
What a fairer design does: Allow direct currency payment or explain conversion, residual value and refund options beside the token offer.
Show annotated differences (4)
- Only a 100-token bundle can be purchased and the $ value is remote.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.
- Pay exact amountReview prompt: How many steps, waits and channel changes separate “Buy 100 tokens” from the completed creator marketplace outcome?
- Direct payment is available; token use shows conversion and remaining balance.Fairer design: Allow direct currency payment or explain conversion, residual value and refund options beside the token offer.
- Price, period and commitment, expanded: The price and material terms associated with “Pay exact amount” remain beside this choice.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”?
Review questions (3)
- 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?
What is a fairer alternative?
Show the current real-money equivalent and total before commitment and avoid conversion structures that obscure or strand value.
Legal and information status
How Australian law may apply
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.
ACL section 28B, inserted by the 2026 Act
Possible risk indicator
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.
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 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.
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 the current real-money equivalent and total before commitment and avoid conversion structures that obscure or strand value. This is editorial portal guidance, not a statutory duty, regulator safe harbour or compliance certificate.
Context matters
Context and boundary cases
- 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
When a similar design can serve a legitimate purpose
- Transparent one-to-one or prominently converted loyalty points
- currency conversion required by international payment with total displayed
- non-purchasable game score
Operational review
What teams should review
- Teams
- 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 to retain
- 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
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