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Dark patterns in insurance

A regulatory wake-up call

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The Insurance Regulatory and Development Authority of India (IRDAI) has extended its focus on dark patterns to digital insurance distribution.

In its 2 April 2026 communication, IRDAI directed insurers to comply with the Central Consumer Protection Authority (CCPA) guidelines on dark patterns, aligning with broader concerns also raised by the Reserve Bank of India (RBI) on manipulative digital design.

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How leading organisations are responding

Embedding trust into design

  • Independent reviews: Conduct third-party audits of digital journeys
  • Ethical design standards: Define clear internal guardrails for UI/UX
  • Journey redesign: Identify and fix trust-eroding touchpoints using test-and-learn approaches
  • Capability building: Train teams across product, design, legal and marketing
 
The bottom line

Dark pattern regulation signals a shift from conversion-led design to trust-led design.

Insurers that act early will not just meet regulatory expectations but build a sustainable competitive advantage.

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Get in touch

Aakash Sharma

Aakash Sharma

Partner - Forensic & Financial Crime | Strategy, Risk & Transactions, Deloitte India
Suchintan Chatterjee

Suchintan Chatterjee

Partner – Customer Strategy & Design Technology & Transformation Deloitte India
Debashish Banerjee

Debashish Banerjee

Partner and Insurance sector leader, Deloitte India

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