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December 10, 2025
Shabori Das, ET Bureau
Dec 10, 2025
India’s social media platforms are powerful marketing tools but not yet retail destinations. Billions scroll and swipe daily, but few buy directly within apps. Unlike China, India faces regulatory hurdles and a lack of integrated payment systems.
A billion Indians scroll, swipe and double tap every day, but barely buy. Despite Instagram and Facebook Marketplace being in India for over a decade, social media here remains a showroom, not a store. Creators and D2C brands are hustling to convert attention into action, but the holy grail of in-app shopping where discovery, live streaming, and purchase happen seamlessly, remains out of reach.
The question is, what’s stopping India from becoming the next China or the US in social commerce?
Influence-to-Commerce Gap
Globally, social commerce is powered by influencers. In China, influencer Li Jiaqi reportedly sold products worth $2 billion on Singles’ Day on Alibaba’s online marketplace Taobao Live in 2021. Another popular influencer Zheng Xiang Xiang, with over 5 million followers on Douyin (the Chinese equivalent of TikTok), reportedly generated $18 million in sales in a week in 2023. These are numbers India’s creator economy can only dream of, for now.
To be clear, influencer marketing in India is booming. EY estimates the sector at over Rs 3,000 crore and yet, due to regulatory restrictions, social media platforms in India can’t host end-to-end transactions. What India has is content commerce, driven by players like Meesho and Myntra, not social commerce. Globally, social commerce is a $1-trillion market. China alone accounts for over $500 billion and the US, $100 billion. India’s share? Around $10 billion — despite being home to the world’s largest Gen Z population and the second-largest base of internet users after China.
What’s Holding India Back
“Just as quick commerce changed how India buys food, social commerce will change how we shop for fashion and lifestyle,” says Anand Ramanathan, partner, consumer industry leader, Deloitte South Asia.
The idea is simple: Social commerce enables an end-to-end purchase journey within a social media app. But in India, the final sale still happens elsewhere — typically on e-commerce platforms.
“In China, live streaming contributes nearly 20% of total e-commerce revenue. In India, it hasn’t taken off,” says Puneet Sehgal, CEO of D2C apparel brand Freakins. He believes in-app checkout could be transformative. “Our Gen Z audience spends over an hour daily on social media. If the purchase could happen right there, it’s one step less for the consumer — and one step closer to a sale.”
The China Contrast
China’s social commerce revolution was built on three forces — speed, scale and seamlessness. Influencer Zheng, for instance, showcases each product for barely three seconds and moves on. That brevity, combined with integrated payments, drives impulse buying at staggering volumes.
India’s influencer-driven commerce, by contrast, is still warming up. Projected to touch $ 55 billion by 2030, it remains largely limited to discovery and advertising.
The barriers aren’t technological, they’re regulatory. India’s payment rules require clear accountability and settlement tracking, making it difficult for global platforms to enable in-app sales. Meta’s 2023 policy shift also directed purchases off-platform, keeping Instagram and Facebook Marketplace confined to discovery and promotion, rather than purchase. For now, social media in India remains a potent marketing engine, not yet a retail destination.
Experiments and Exceptions
Some Indian players are testing new waters. Myntra’s Glamstream, launched this July, lets influencers host live sessions where viewers can “shop the look” in real time — though the final checkout still redirects you to the Myntra app.
“India’s creator economy influences over $300 billion in annual consumer spending,” says Sunder Balasubramanian, chief marketing officer at Myntra.“That could grow to $1 trillion in the next few years, making India one of the fastest-growing creator economies globally,” adds Lakshminarayan Swaminathan, vice president-product management, Myntra.
The potential is clear. In 2021, Taobao Live hosted a 12-hour live streamed sale with influencer Li Jiaqi in China that clocked $2 billion in presales and attracted 250 million viewers.
Closer home, Sujata Biswas, co-founder of Suta Sarees, recalls Instagram’s shortlived Shop Now feature. “We saw an immediate dip in transactions after it was withdrawn,” she says. “Fashion is about instant gratification. You see it, you want it and buy it right away.”
The D2C Advantage
India’s D2C market, valued at $87 billion as of 2025 by Deloitte, could be the biggest gainer if social commerce does take off. Most D2C brands currently pay 25–35% retailer margins to platforms like Myntra and Nykaa. Social commerce could let them bypass intermediaries and sell directly to their audiences.
“Anything that reduces friction between intent and purchase is gold,” says Sehgal. “If that entire journey — from watching to buying — happens within the same app, conversion rates would shoot up.”
Even so, social platforms come with their own costs. TikTok, for instance, charges promotional, marketplace and fulfilment fees. But for Indian D2C players, the larger hurdle isn’t cost — it’s access.
Open vs Closed Ecosystems
“India’s retail market is far more open than China’s,” explains Devangshu Dutta, CEO of ThirdEyesight, a retail consulting firm. “In China, closed ecosystems like WeChat and Douyin created the perfect environment for social commerce to thrive. In India, where consumers can freely move between Google, Meta and e-commerce giants, those closed loops don’t exist.”
Globally, TikTok Shop, Douyin, WeChat, Pinduoduo, and Taobao Live dominate social commerce. According to Business of Apps, a data provider for the global app industry, TikTok earned $23 billion in 2024, with nearly 23% of it from in-app and commerce purchases.
If similar models are launched in India, e-commerce giants would face direct competition from the very platforms that fuel their traffic.
The Wait Continues
From beauty tutorials to thrift stores, social media spawns thriving micro economies. Yet, true social commerce — where discovery leads directly to purchase — hasn’t yet clicked.
The next big leap for India’s e-commerce may not come from deeper discounts or faster delivery but from social media itself. “The idea of instant gratification is key,” says Biswas. “When the ‘Shop Now’ button comes back, we’ll be the first to use it.”
Till then, India scrolls, likes, shares — and waits.
(Published in Economic Times)
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December 7, 2025
Gargi Sarkar, Inc42
7 December 2025
The past year has been nothing short of monumental for LensKart — from reporting another operationally profitable quarter in Q2 FY26 to making the public markets leap in November, and crossing a market capitalisation of INR 70,000 Cr despite a muted stock market debut.
A clear shift this year has been Lenskart’s effort to move beyond the image of a ‘basic D2C eyewear’ brand selling prescription glasses and sunglasses. The company is now working to reposition itself as a new-age tech brand.
Further, Lenskart is rethinking where and how its products are manufactured. Currently, around 20–25% of its frames are reportedly manufactured in India. The company is ramping up its domestic production. As a new manufacturing facility in Telangana is a work in progress, Lenskart intends to gradually shift most of its manufacturing operations from China to India.
In many ways, 2025 has been about scaling up for Lenskart, and as it embarks on a fresh journey as a publicly listed company, let’s take stock of the company in 2025 and where it might be headed in 2026.
Lenskart’s Smart Eyewear Bet
Lenskart began its smart eyewear journey last year with the launch of Phonic, its audio glasses. It later deepened its push into the segment by announcing a strategic investment in Ajna Lens, a Mumbai-based deeptech company that develops AI-powered XR glasses. Back then, Peyush Bansal described the move as the “next chapter” in Lenskart’s smart glasses journey.
Cut to December 2025, the company is all set to launch its AI camera smartglasses, B by Lenskart, by the end of this month.
What makes B by Lenskart noteworthy is that it isn’t being marketed as just another pair of smart glasses. The new eyewear features an integrated Sony camera that enables hands-free photo and video capture. The glasses come with a built-in AI assistant powered by Gemini 2.5 Live. They are designed to offer natural, conversational interactions and pack in a range of advanced features — from hands-free UPI payments and live translation to wellness insights and more.
What makes the move even more significant is Lenskart’s decision to open B by Lenskart to India’s developer ecosystem. By making its AI and camera technology accessible to consumer apps and independent developers, the company is enabling integrations across categories such as food delivery, entertainment, and fitness.
“By opening its AI smartglasses to third-party developers, Lenskart is moving from a one-time product-sale model to a platform ecosystem model. In the long run, this could unlock recurring revenue streams and higher margins,” said a product developer.
Besides, the company is aligning itself with a younger customer cohort, aided by affordability, style, and technology.
“That’s what seems to define their current strategy. Over time, they’ve also brought in elements of innovation like virtual try-ons, and any product, feature, or service that brings novelty and appeals to younger customers has become part of their brand approach,” said Devangshu Dutta, the founder of Third Eyesight.
Next, the timing couldn’t be better for Lenskart to place its bet on smart glasses. An IDC report reveals that despite a slowdown in smartwatch and earwear segments in the second half of 2025, smart glass shipments shot off more than 1,000% over the last year.
However, it’s not going to be smooth sailing from here.
At its core, Lenskart is still a consumer-facing company, and it needs new products to keep its revenue growing. But the competition is already heating up. Jio unveiled its own AI-powered smart glasses, Jio Frames, at Reliance Industries’ 48th annual general meeting. And of course, Meta continues to lead the global smart glasses market.
At this point, smart eyewear is a niche category, which comes with a hefty price tag.
“Unless cost drops dramatically, mass adoption is still a distant dream. As of now, the product will only attract early adopters and tech enthusiasts, rather than the mainstream consumer,” Dutta adds.
Lenskart’s Make In India Push
Lenskart is not only widening its product range but also ramping up its manufacturing. The company currently operates centralised manufacturing facilities in India (Bhiwadi in Rajasthan and Gurugram in Haryana), Singapore, and the UAE. It also has manufacturing operations in China.
Back home, Lenskart has also signed a non-binding MoU with the Government of Telangana for setting up a greenfield manufacturing facility for optical glasses. The proposed investment stands at INR 1,500 Cr and will be supported by certain incentives and assistance from the state government.
The new production facility is expected to strengthen Lenskart’s domestic manufacturing capabilities while reducing its exposure to foreign exchange fluctuations and import-related volatility.
However, the expansion comes with its own set of challenges. While the new manufacturing plant in Telangana is expected to strengthen Lenskart’s vertical integration, it will come with a hefty cost burden.
Profitability Still A Troubling Question
The cost structure is becoming increasingly important for Lenskart. Despite its headline-grabbing profitability, the company is still operating on fairly thin margins.
Lenskart reported a net profit of INR 297 Cr in FY25, a notable turnaround from a loss of INR 10 Cr in FY24. However, market analysts caution that the business’ core operations were unprofitable. It was largely “other income” or investment income that drove the FY25 bottom line.
“Though Lenskart has increased its revenue from INR 3,789 Cr in FY23 to INR 6,651 Cr in FY25, the company’s profitability has largely improved due to a rise in other income. While it reported a PAT of INR 297 Cr in FY25, a closer look shows that the profit was driven significantly by an increase in other income, which jumped to INR 356 Cr in FY25,” SimranJeet Singh Bhatia, senior research analyst for equity at Almondz Group.
The point of concern here is that Lenskart turned operationally profitable only after its market debut. Bhatia believes that at least three to four quarters of consecutive profitability will be needed to prove the company’s underlying strength.
However, making matters worse are the company’s climbing expenses, which stood at INR 1,980.3 Cr in Q2 FY26, up 18.5% YoY.
What Lies Ahead?
The year was equally sour for the eyewear major. While its IPO generated significant buzz and saw strong subscription levels, its market debut turned out to be a muted affair.
At the upper end of its INR 382 to INR 402 IPO price band, the public issue implied a price-to-earnings (P/E) multiple of roughly 235–238 times its FY25 profits, placing it among the most expensive consumer tech listings in India.
On its first day of trading, Lenskart Solutions Ltd. was listed on the NSE at INR 395 per share, a discount of 1.74% to the issue price of INR 402. The stock, however, fell close to 9% shortly thereafter. On the BSE, it debuted at INR 390, marking a discount of nearly 3%.
After the IPO, Bhatia adds, the biggest concern surrounding Lenskart is the store-level unit economics, particularly because a significant share of the IPO proceeds is being directed toward expanding its company-owned, company-operated store network.
Entering the new year as a public company, Lenskart will have to prove that its scale-up plans are justified and that it has greater control over its balance sheet. 2026 will be a critical juncture for the company, as the next three to four quarters will be closely watched for signs of sustainable growth, improved margins, and stronger operational discipline.
[Edited by Shishir Parasher]
(Published in Inc42)
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December 1, 2025
Priyamvada C, Mint
1 Dec 2025
A wave of investor capital is flowing into India’s laboratory-grown diamond (LGD) segment, as fastscaling brands tap rising consumer adoption in a market now worth well over $300 million. New-age brands have raised multiple rounds of capital on the back of growing market share and improving margins.
Actor Shilpa Shetty-backed Limelight, which is in talks to raise its second round of capital this year, joins the growing list of other small brands such as Onya, Giva, Jewelbox, Lucira Jewellery and Aukera, among others, who have snagged monies in recent months. Limelight has appointed Ambit Capital to raise about $20 million to fund its expansion plans, two people familiar with the matter said.
Confirming the fundraise, the six year-old company’s co-founder Pooja Madhavan said the funds will be used towards store expansion and brand building as it looks to touch 100 stores over the next year. “We are in final talks with growth PE funds and reputed family offices (for the fundraise),” she told Mint.
Other similar fundraises include Onya’s ₹5.5 crore in a pre-seed round led by Zeropearl VC last week, Aukera’s $15 million raise led by Peak XV Partners and Aditya Birla Ventures-backed Giva raised ₹530 crore in an internal round led by Premji Invest, Epiq Capital and Edelweiss Discovery Fund, as it looks to scale up its lab-grown diamond offerings.
Nine pure-play lab grown diamond startups collectively raised a record $26.4 million in 2025, compared with $4.7 million across eight startups last year, data from market intelligence provider Tracxn showed.
The development comes as India’s lab-grown diamond jewellery market, valued at about $300-350 million in 2024, expects to grow at a compound annual growth rate (CAGR) of 15% over the next decade, as per consultancy firm Redseer’s estimates. As the market evolves, several prominent jewellery brands will gradually pivot from exclusively natural/mined diamonds in favour of lab-grown alternatives, alongside high-end jewellers incorporating the lab-growns into their select collections, which will drive sales volumes and act as an affordable entry point for consumers.
This segment has particularly picked pace in the last five years, with millennials and gen Z leading this shift, driven by better value, trendier designs from new-age brands, and growing comfort with lab-grown diamonds as a certified, high-quality product. This category has also widened beyond occasional fashion to gifting, daily wear and increasingly bridal, reflecting sustained consumer confidence and a willingness to treat them as a mainstream jewellery option, Rohan Agarwal, partner at Redseer told Mint in an emailed statement.
He further added that new-age brands have steadily gained market share in the mid-ticket gifting and daily wear segment with many trying to push into premium ranges. While the competitive landscape is still evolving, incumbents have already started responding by launching LGD lines of their own, although the extent to which they can challenge remains to be seen.
Major Indian brands that are considering a foray into this category include Malabar Gold & Diamonds, Senco Gold, which has launched the subbrand Sennes and Tata’s Trent, which launched its brand Pome in Westside stores.
Devangshu Dutta, founder and chief executive officer at Delhi-based consulting firm Third Eyesight, echoed the sentiment. He explained that new-age lab grown diamond players are forcing traditional jewellers to introduce LGD options or risk losing younger customers. “Not just precious jewellery brands, even those that started as fashion jewellery are expanding their range with LGD designs.”
“Down the road, there is potentially scope for consolidation as investors tend to prefer a handful of scaled platforms with strong brand recall and robust economics. So, as the category matures, there may be strategic acquisitions by large jewellery houses and corporates, as well as mergers among funded startups,” he added.
Those startups that can combine in-house manufacturing, design capabilities and data-driven retail expansion would be at an advantage, Dutta said. “Key future growth areas for LGD startups include omnichannel retail presence within India, with offline stores especially in demand-dense locations such as the metros and Tier 1 cities, export markets both with potential cost advantages and brand expansion, and extending into fashion jewellery, everyday wear, coloured lab grown stones and even luxury collaborations that position lab grown as aspirational rather than merely budget friendly.”
(Published in Mint)
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November 27, 2025
Viveat Susan Pinto, Financial Express
November 27, 2025
Several of the country’s top retailers, malls and brands have kicked off a shopping extravaganza on the occasion of Black Friday, offering steep discounts across product categories.
A Western import, the day which symbolises the beginning of the Christmas shopping season in the US, the UK and Europe, gained popularity in India over the past two years as a crucial sale window after Diwali.
Domestic retailers, say experts, are using this period to exhaust existing inventory at steep discounts as they gear up for the winter season.
This year, discounts are up to 60-80% across fashion, lifestyle, electronics and cosmetics, higher than the 50% seen last year. E-tailers such as Ajio have pushed the pedal even harder, offering as much as 85-90% on denims, jackets and select products during the sale this year.
Bigger Deals, Longer Duration
“Retailers in India are building Black Friday as an important off-season peak. The participation of brands is growing, deals are getting bigger and the sale days are more,” Devangshu Dutta, founder and chief executive of Third Eyesight, a Gurugram-based retail consultancy, said. That is visible from the intense promotional activity this year. What began as a flash sale event a couple of years ago has now extended to a week-long sale period this year, experts said.
Pushpa Bector, senior executive director and business head, DLF Retail, said that brands this year are ready with strong offers, driven in part by GST cuts and a stable economic outlook. “Early trends show healthy interest across categories by consumers. We expect a strong double-digit uplift over the Black Friday period, setting us up for a strong close to the year,” she said.
Retailer Strategies
While Black Friday typically falls on the last Friday of November, some retailers such as Flipkart, Croma, Vijay Sales, Nykaa and Tata Cliq have kicked off their Black Friday sales last week itself to build on the excitement. For electronic retailers, said Nilesh Gupta, director, Vijay Sales, Black Friday will extend into Cyber Monday next week (falling on December 1), making it even more relevant for them to focus on the occasion.
“We’ve been building Black Friday as a retail property in the last few of years as it fills the post-Diwali void quite well. Black Friday also extends well into Cyber Monday which comes immediately after. While we started with a few categories in the initial years, we now have offers across all our segments. Discounts are up to 45-50% this year in line with last year,” he said.
Rival Croma is also offering up to 50% discount on products this year, executives said.
“Black Friday has become one of India’s most anticipated shopping moments. At Croma, we are focused on delivering value across categories with steal deals, bundled savings, and limited-time offers,” Croma’s CEO & MD Shibashish Roy said.
Croma will also introduce a special late-night shopping window on November 28 at select stores across India. For two hours—from 10 pm to 11:59 pm —these stores will remain open with exclusive additional discounts on some of the season’s most in-demand products.
Nishank Joshi, chief marketing officer, Nexus Select Malls, said it is elevating the Black Friday experience with bigger assured gifts, giveaways and reward points if consumers upload their bills on their Nexus One apps.
Mayank Lalpuria, director, marketing (north, central & west) at Phoenix Mills, which operates Phoenix malls, said that it was expecting double-digit year-on-year growth and strong footfalls during the Black Friday period.
Tanu Prasad, CEO – Malls, Oberoi Realty, said that the firm was seeing far more planned purchases towards premium products and a rise in family-oriented outings. “We are anticipating an encouraging response at the (Black Friday) weekend resulting in a strong kick-off to the (December) shopping season,” Prasad said.
Direct-to-consumer brands such as Inc.5 footwear and NEWME said that they have rolled out big deals for Black Friday. “We’re looking at a 30x surge in orders across both offline and online for Black Friday,” NEWME Co-founder & CEO Sumit Jasoria said.
“Our customers look forward to Black Friday, and this year, we’re excited to bring fresh new launches, curated edits, and our widest range yet,” Rajesh Kadam, CEO, Inc.5 Footwear, said.
(Published in Financial Express)
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November 26, 2025
Aakriti Bansal, Medianama
November 26, 2025
MediaNama’s Take: The Central Consumer Protection Authority’s (CCPA) decision to publish 18 self-declarations confirms only a partial picture of its dark pattern(s) identifying exercise. The authority has stated that 26 platforms have filed their declarations, but it has made only 18 of them public. This gap means the public still cannot see what eight major platforms submitted or whether those filings contain any meaningful detail. Moreover, even among the published declarations, several are one-paragraph statements that offer almost no insight into the scope or accuracy of the companies’ internal audits.
LocalCircles’ new survey adds further complications, reporting that 21 of the 26 platforms that submitted declarations still display at least one dark pattern. This finding suggests that the CCPA’s reliance on voluntary self-assessment may not be enough to shift platform behaviour at scale. It also raises questions about what the unpublished declarations contain and whether the missing submissions are similarly sparse or incomplete.
Notably, the CCPA has not clarified how it plans to verify the accuracy of any of the declarations, whether published or unpublished. If filings remain unverified for months, compliance risks turning into a box-ticking exercise rather than a meaningful regulatory process. Therefore, the next phase matters far more than the publication of select declarations, because the current approach raises more questions than it answers.
What’s the News
The CCPA has made 18 dark pattern self-declarations public, despite stating that 26 platforms have filed their compliance letters. The publication follows an RTI filed by MediaNama that revealed which companies had submitted their declarations, and pointed out that none of the filings had been available to the public at the time.
These declarations stem from the Ministry’s June 5 advisory, which required e-commerce and quick commerce companies to conduct internal audits under the 2023 Guidelines for Prevention and Regulation of Dark Patterns and submit compliance letters within 90 days.
For context, Moneycontrol reported that Amazon has still not filed its declaration and has asked for additional time. A senior government official told the publication that the government “has done what it had to” and does not plan further discussions.
The official also said that any punitive action would depend on consumer complaints routed through channels such as the national consumer helpline. This indicates that the enforcement approach continues to be reactive rather than compliance-driven.
What Did The CCPA Ask Platforms To Do?
The June 5 advisory set out a simple compliance framework for digital platforms. It asked every e-commerce and quick commerce company to complete a self-audit of its website and mobile app within 90 days and check their interfaces for the 13 dark patterns listed in the 2023 guidelines. Platforms were required to file a self-declaration confirming compliance once this internal review was complete.
However, the advisory did not specify how the audit should be conducted. Companies were free to choose any methodology, and the CCPA did not prescribe a standard format, a uniform checklist, or a minimum evidence requirement. Also, the advisory did not require independent audits or third-party validation.
Furthermore, there was no explanation of how the CCPA planned to verify whether the declarations were accurate or complete. In effect, the responsibility for defining the scope, depth, and rigour of the audit rested entirely with each platform.
What the CCPA Has Done With the Declarations
As mentioned before, the CCPA has now published 18 self-declarations on its website. The release confirms that companies submitted their compliance letters, but it does not indicate whether the authority evaluated the accuracy or depth of the filings.
Several platforms submitted very short statements that simply assert compliance without describing any checks or findings. BigBasket, Zomato, Blinkit and Swiggy were among the companies that filed especially minimal disclosures. The CCPA has not explained why these filings were accepted or whether any follow-up questions were asked. Therefore, asking for and disclosing self-declarations shows some administrative progress, but it does not reflect any regulatory scrutiny.
This lack of verification aligns with concerns raised by Devangshu Dutta, Founder of business consulting firm Third Eyesight. He told MediaNama that self-declarations “do not change things much” when regulators do not audit submissions or impose consequences.
Further, Dutta remarked that most companies comply at the minimum level required if their claims are not examined and are not made public in full. According to him, revenue-driving design choices such as forced add-ons, confusing checkout flows or misleading scarcity claims will not be voluntarily removed sans oversight.
What Independent Evidence Shows
LocalCircles’ latest audit presents a sharply different picture from the companies’ filings. The organisation found that 21 of the 26 platforms that submitted “dark pattern free” declarations still use one or more manipulative design practices. The assessment relied on feedback from more than 250,000 consumers across 392 districts along with AI-assisted testing.
The most common violations include forced action, subscription traps, bait and switch, basket sneaking, interface interference and disguised advertisements. In practice, these dark patterns respectively mean that users are pushed into steps they did not choose, face hidden or hard-to-cancel subscriptions, see offers change during checkout, encounter fees added at the last moment, get nudged toward platform-favoured choices, and come across ads that appear as regular listings.
LocalCircles also identified drip pricing (gradually adding mandatory fees during the checkout process) on 11 of the 26 companies, including Flipkart, Myntra, Cleartrip, MakeMyTrip, BigBasket, Zomato and Blinkit, among others. The organisation said that many platforms appear to misunderstand what qualifies as drip pricing, which has led to incomplete corrections.
Trust Can Erode Due To Gap Between Declarations And User Experience
Sachin Taparia, Founder of LocalCircles, said that the problem begins with the absence of any verification. “Our understanding is that CCPA is wanting that companies submit a self-declaration at the earliest. However, there is no cross checking of claims that is being done by the CCPA, and as a result the companies are not being as thorough with their dark-pattern detection and resolution,” he said.
Taparia added that discrepancies between declarations and user experience could harm trust. “LocalCircles has found dark patterns on 21 of the 26 platforms submitting self-declarations. If this exercise is not done with high accuracy, both platforms doing so and CCPA could see consumer trust being impacted,” he said.
Importantly, Dutta echoed this concern, saying that the absence of penalties or reputation-related consequences allows companies to self-declare compliance while keeping revenue-generating patterns intact. He described the current process as “more an administrative formality [rather] than a behaviour-changing regulatory tool”.
Why This Matters
The gap between self-declarations and independent audits in the true sense of the word brings the real enforcement question into focus. What should the next phase of regulation look like?
In this context, Dutta said that regulators need to move beyond self-certifications and mandate detailed user experience (UX) audit reports that map every user journey, including pop-ups, onboarding, search, checkout, cancellations and returns.
He explained that regulators should reinforce this by demanding substantive evidence instead of brief compliance letters. This evidence can include screenshots and screen recordings of key flows, version histories that show how an interface changed over time, and product design documents or A/B testing results that reveal why specific nudges were introduced. To explain, A/B testing is essentially a method for comparing two versions of something to see which one performs better.
Furthermore, Dutta noted that platforms already collect extensive data on user complaints and drop-off points, which can help identify harmful or confusing design choices. He also said that independent third-party attestations, similar to security or accessibility audits, can provide a credible external check and increase the cost of non-compliance.
Multiple Annual Audits For Apps that Change Interface Frequently
Notably, Dutta stressed that most dark pattern categories appear across e-commerce, quick commerce and Direct-to-Consumer (D2C) websites, which means regulators can create a baseline audit standard that works across sectors instead of relying on platform-specific interpretations. He also suggested that audits should occur at least once a year, and companies that frequently modify their interfaces may need to report two or three times annually.
The larger concern now is whether the CCPA plans to move toward such a structured framework. Without independent verification and clear audit expectations, companies can continue declaring compliance even when manipulative designs remain embedded in their interfaces.
(Published in Medianama)
