Dark Patterns in Ride-Hailing Platforms: The Rapido Case

In a notable development in dark pattern regulation in India, the Central Consumer Protection Authority (‘CCPA’) has taken action against Roppen Transportation Services Private Limited, the operator of ride-hailing platform Rapido, for deploying manipulative pre-ride tipping prompts and a deceptively designed pricing interface. In its order dated 31 August 2026 (Case No. CCPA-2/53/2025-CCPA), the CCPA held these practices to be in violation of the Consumer Protection Act, 2019 (‘Act’) and the Guidelines for Prevention and Regulation of Dark Patterns, 2023 (‘Dark Patterns Guidelines’). A penalty of ₹10 lakh was imposed alongside directions to immediately discontinue the impugned practices.

The order forms part of the CCPA’s broader scrutiny of ride-hailing and bike-taxi aggregator platforms over pre-ride tipping and dynamic pricing practices.

The Rapido Case

The matter originated from a May 2025 representation alleging unfair trade practices through manipulative pre-ride tipping features and exploitative dynamic pricing on ride-hailing platforms. Upon examining multiple cab and bike-taxi aggregator platforms, the CCPA found the impugned practices on the Rapido platform. After the show cause notice was issued, Rapido submitted its reply, following which a hearing was held and the matter was referred to the Director General (Investigation) for detailed inquiry. The Director General submitted its report in January this year, and after a hearing in May, the Authority found the platform in violation of various provisions of the Act.

Impugned Practices:

• Tipping Prompts: While booking, Rapido’s app displayed prompts such as ‘Higher the price, higher the chance of getting a ride’ and ‘Captains aren’t accepting at ₹60. Try adding +10, +20, +30,’ creating an impression that ride confirmation was contingent on paying above the quoted fare. These prompts appeared after the consumer had already committed to the booking, at a point where the consumer’s bargaining position was weakest.
• Price Slider Design: The ‘Set your price’ interface used colour-coded visual cues — green text with an upward arrow when the price was raised (‘Higher chance of getting a ride’) and red/orange warnings when lowered (‘Captains are unlikely to accept orders at this price’). The slider was also designed asymmetrically, offering limited decrements below the suggested fare but multiple progressively larger increments above it.

Provisions Violated

The CCPA held Rapido in violation of the following:

• Misleading Advertisement — Section 2(28) of the Act: The prompts conveyed an unsubstantiated implied guarantee that paying more would lead to faster ride confirmation, despite Rapido’s own admission that its algorithm continues to operate irrespective of tip amounts. No data or verifiable basis was placed on record to substantiate the claim.
• Unfair Contract — Section 2(46) of the Act: The prompts unilaterally altered the terms of the concluded fare contract to the consumer’s detriment, by seeking additional payment beyond the fare already quoted and accepted.
• Unfair Trade Practice — Section 2(47) of the Act: The prompts conditioned timely service upon additional undisclosed payment, psychologically pressuring consumers at the point of maximum vulnerability — when they had already committed to the booking and were awaiting ride confirmation.
• Dark Patterns — Clause 2(e) of the Dark Patterns Guidelines: The impugned practices fell within the definition of ‘dark patterns’ under Clause 2(e), i.e., practices or deceptive design patterns using UI/UX interactions designed to mislead or trick users, subverting consumer autonomy and decision-making.
• Confirm Shaming — Clause 3, Illustration (a) of the Annexure to the Dark Patterns Guidelines: The tipping prompts induced a sense of urgency and fear of service denial, nudging consumers to pay more to avoid perceived delay or loss of an already-booked ride — characteristic of ‘confirm shaming.’
• Interface Interference — Clause 6 of the Annexure to the Dark Patterns Guidelines: The colour-coded slider design actively shaped consumer perception through visual cues, steering riders towards higher fares independent of the textual prompts, thereby manipulating consumer choice through interface architecture.
• Guidelines for Prevention of Misleading Advertisements and Endorsements for Misleading Advertisements, 2022: The practices also fell foul of these guidelines given the unsubstantiated and misleading nature of the representations.

Directions

The CCPA, inter alia, directed Rapido to:

• Immediately discontinue the use of all prompts, messages, interface designs, or any other dark pattern elements that nudge, coerce or psychologically pressure consumers into paying amounts above the upfront fare displayed at the time of booking.
• Ensure strict compliance with the Act, the Dark Pattern Guidelines, 2023, the Misleading Advertisements Guidelines, 2022, and the Consumer Protection (E-Commerce) Rules, 2020.
• Pay a penalty of ₹10 lakh.
• Submit a compliance report within 15 days of receipt of the order.

Points to Note

• Motor Vehicle Aggregator Guidelines, 2025 — Clause 14.15: Introduced by the Ministry of Road Transport and Highways in December 2025, this clause requires that voluntary tipping features on aggregator apps be visible only after completion of the journey. Last month, the Ministry directed all motor vehicle aggregators to comply with this provision.
• E-Commerce Rules Amendment: The Consumer Protection (E-Commerce) (Amendment) Rules, 2026, notified on 9 September 2026, require every e-commerce entity to comply with the Dark Pattern Guidelines, conduct yearly self-audits to ensure that the platform is free from dark patterns, and prominently display a certificate to this effect. These amendments come into force on 1 January 2027.
• Other Platforms Being Looked Into: The CCPA had issued notices to Uber, Ola, Rapido and Namma Yatri, directing compliance with the Dark Pattern Guidelines. Its examination of Uber and Ola remains ongoing. Namma Yatri, which voluntarily discontinued the impugned features, was directed (vide order dated 1 September 2026) to remain compliant, with no penalty imposed.

Concluding Thoughts

Dark patterns across digital platforms remain pervasive — the cancellation interfaces on several ride-hailing apps, for instance, continue to employ design choices that could face similar scrutiny. With compliance with the Dark Patterns Guidelines now mandated under the Consumer Protection (E-Commerce) (Amendment) Rules, 2026 (coming into force on 1 January 2027), platforms across sectors would be well advised to undertake proactive interface audits.