CCPA Slams PhysicsWallah With Rs 5 Lakh Fine for Dark Patterns [Read Order]

New Delhi: The Central Consumer Protection Authority has imposed a penalty of Rs. 5,00,000 on PhysicsWallah Limited, the ed-tech company operating the PW platform, after finding that it deployed manipulative interface practices amounting to dark patterns, misleading advertisements, and violations of consumer rights on its website and application.

The order dated 1 June 2026, passed by Chief Commissioner Nidhi Khare and Commissioner Anupam Mishra, arose out of a suo motu inquiry initiated by the Authority under the Consumer Protection Act, 2019 into three categories of alleged dark patterns: basket sneaking, interface interference and forced action, and confirm shaming.

On the issue of basket sneaking, the CCPA found that PhysicsWallah’s checkout process displayed a pre-selected donation option titled ‘Donate for PW Foundation’, which automatically added Rs. 10 to the payable amount unless the consumer consciously deselected it. The mechanism remained active from 14 February 2024 to 24 December 2025 and was disabled only after receipt of the Authority’s first notice dated 4 December 2025. PhysicsWallah itself disclosed that during this period approximately Rs. 2.47 crore was collected from more than 21,36,962 users through the pre-ticked mechanism.

The CCPA held that the pre-selected donation checkbox directly contravened Rule 4(9) of the Consumer Protection (E-Commerce) Rules, 2020, which mandates that consumer consent for any purchase on an e-commerce platform must be obtained only through explicit and affirmative action and expressly prohibits the recording of consent through pre-ticked checkboxes. The Authority rejected PhysicsWallah’s contention that the practice was transparent because the donation amount was visible and users retained the ability to opt out, holding that mere visibility does not cure the illegality of obtaining consent by pre-selection. The Authority held that the legal obligation rests upon the platform to obtain express and affirmative consent before including any additional monetary component in a transaction.

On the issue of confirm shaming, the CCPA found that when a user clicked the ‘Know More’ option on the donation prompt, the platform displayed emotionally persuasive messaging referring to PW Foundation’s work in supporting marriages of needy people, education of children, and healthcare of underserved communities. The Authority found that such messaging, when presented simultaneously with a pre-selected donation option during a commercial transaction, had the effect of exerting moral pressure and creating an emotional sense of obligation among consumers to retain the donation amount rather than exercising a free and neutral choice. This practice was held to fall within the definition of ‘confirm shaming’ under Annexure 1 to the Guidelines for Prevention and Regulation of Dark Patterns, 2023.

On the issue of forced action, the CCPA found that access to courses advertised as ‘free’ on the platform was conditioned upon mandatory disclosure of personal information including mobile number and email ID. Upon independent examination of the platform through multiple user accounts, the Authority observed that the free educational content remained identical across accounts and that no element of personalisation or differentiated learning experience was associated with the collection of such information, contrary to the claims made by PhysicsWallah.

The CCPA distinguished this practice from the login requirements on government platforms such as DIKSHA and SWAYAM, noting that neither platform promoted courses as unconditionally ‘free’ while simultaneously conditioning access on personal data disclosure in the manner adopted by the opposite party. The Authority held that the promotional representation of ‘free courses’ without disclosing the mandatory conditions attached thereto amounted to a misleading advertisement under Section 2(28) of the Consumer Protection Act, 2019 and also fell within the prohibited category of ‘Forced Action’ under the Dark Patterns Guidelines.

PhysicsWallah, in its submissions, denied that the practices were exploitative in intent or effect. It contended that the donation feature was optional, prominently visible, and fully within the user’s control; that the messaging about PW Foundation’s activities was factual and not designed to induce guilt or social pressure; and that the requirement of basic personal information for free courses was necessary for operational, academic, security, and anti-piracy purposes and was standard practice across digital educational platforms. It also submitted that the pre-selected donation feature had been proactively removed after receipt of the CCPA notice and that this removal should be considered a mitigating factor.

The CCPA, however, held that post-facto corrective action taken only after the commencement of regulatory proceedings could not absolve the company of liability for violations already committed at scale. The Authority also noted that the platform extensively serves students, including minors preparing for competitive examinations, and that manipulative interface practices deployed within educational services carry heightened potential to impair informed decision-making among a particularly vulnerable class of consumers.

The Authority found that PhysicsWallah had violated Sections 2(9), 2(28), and 2(47) of the Consumer Protection Act, 2019 read with the Consumer Protection (E-Commerce) Rules, 2020 and the Guidelines for Prevention and Regulation of Dark Patterns, 2023. In exercise of powers under Sections 20 and 21 read with Sections 10 and 18 of the Act, the CCPA directed PhysicsWallah to ensure that no dark patterns are employed on any of its digital interfaces and to pay a penalty of Rs. 5,00,000. The company was further directed to submit a compliance report within 15 days of receipt of the order.

Case Title: In the matter of use of dark patterns resulting in unfair trade practice, misleading advertisement, and violation of consumer right by PhysicsWallah Limited (Case No. CCPA-2/94/2025-CCPA).

[Read Order]