The EU and UX Dark Patterns – Manipulative Design Practices Under Regulation

Author

Ella Killinen

“UX dark pattern” refers to a manipulative design practice within a digital service’s user interface. Like accessibility and cybersecurity, these design practices have become a focus of EU regulation. The regulation addresses how websites and applications may guide users in unethical ways. The goal is to protect the user’s sense of autonomy when using online services.

What are Dark Patterns and why are they being addressed?

Although the field of user experience (UX) lacks a single, unified theoretical framework, its general understanding is largely based on fundamental human psychological needs: autonomy, relatedness and competence.

Regulation targeting manipulative design practices – dark patterns – specifically aims to protect the user’s need for autonomy. Dark patterns are design techniques intended to steer, pressure or deceive users into making decisions that benefit the service provider – often at the expense of the user’s own interests.

What the EU regulation addresses

EU regulation focusing on manipulative design practices aims to make digital services fairer for users. However, a report published by the EU in early 2025 notes that the regulation still requires further clarification and more precise legal definitions.

Below are examples of design practices considered manipulative toward users.

Pushing purchase decisions with fake urgency and fake scarcity

Online stores are not allowed to create a false sense of urgency. For example, notifications about low stock levels or an ending sales campaign are only allowed if the information is true and up to date.

No pressuring, hiding or deception

Cancelling a service or ending a subscription must be as easy as starting one. Users must not be misled or exhausted by complex processes.

Acceptance and rejection options should also be balanced. The user interface must not strongly pressure users toward a single choice – such as by making the acceptance button significantly more prominent while making the rejection option hard to notice.

Preselected choices

The user interface must not make choices on behalf of the user. For example, consent for cookies or newsletters must be actively selected by the user – preselected options are not allowed.

Hiding crucial information

Information related to payments, terms of use or other essential matters must not be hidden in fine print or made difficult to find. The information must be easily accessible and understandable.

Hiding sponsored content

Paid content, such as sponsored blog posts, must be clearly labeled as advertisements. Users must be able to easily distinguish between editorial content and advertising.

Guild-tripping

Interfaces should not use guilt-inducing or emotionally manipulative language to steer users toward a desired choice. Emotional manipulation – such as buttons labeled “No thanks, I don’t want to save money” – are prohibited.

Users want to feel that they have control over how they interact with a digital service.

The user’s autonomy should be supported

Users want to feel that they have control over how they interact with a digital service. A good user experience supports this sense of autonomy.

This feeling of autonomy arises from elements such as a clear user interface, intuitive navigation, easily accessible and understandable content and, when needed, guidance through tooltips and instructions.

EU regulation aims to protect this experience, even though a single legal framework has not yet been fully established. Digital services play a central role in everyday life that using them should be not only easy, but also ethically sustainable.