Dark Patterns: How Not to Deceive Your Client and Avoid Legal Trouble
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Dark patterns in the UAE: where the line falls between marketing and breaking the law
Dark patterns are interface and visual design techniques that prompt users to take an action they did not originally intend: subscribe to a mailing list, pay for a service, share data, or miss important information.
Small print in a corner, a bright "Subscribe" button alongside a barely visible "No thanks," pre-ticked checkboxes, a complicated cancellation path: all of these are dark patterns.
The key question is where the line falls between aggressive marketing and breaking the law. In the UAE this line is fairly clearly defined through consumer protection, advertising, and commercial activity regulations.
UAE legislation does not use the term "dark patterns" directly. However, such practices may fall under rules related to:
In particular, Federal Decree-Law No. 16 of 2023 on Combating Commercial Fraud defines commercial fraud as any action aimed at misleading the client, including providing false or incomplete information about a product or service.
misleading the consumer
unfair advertising
commercial fraud
How dark patterns are treated under UAE law:
In practice this means:
— such actions may be treated as misleading.
Liability for such violations may include substantial fines (in some cases up to 1,000,000 AED and above), plus other measures depending on the circumstances.
Liability for such violations may include substantial fines (in some cases up to 1,000,000 AED and above), plus other measures depending on the circumstances.
if important payment or subscription terms are hidden or presented insufficiently clearly
if the user cannot reasonably understand the consequences of their actions
if the interface deliberately distorts the perception of a choice
Federal Law No. 15 of 2020 on Consumer Protection (with updates entering force in 2023) directly regulates several practices characteristic of dark patterns.
Consumer Protection Law: key restrictions
Law
key
restrictions
1. Prohibition on misleading advertising
Advertising must not distort information about a product or service. The supplier is obliged to disclose material terms, including:
● price
● payment terms
● restrictions
If an advertisement states one price but the actual terms are only revealed in a barely visible part of the interface, this may be treated as a violation.
● price
● payment terms
● restrictions
If an advertisement states one price but the actual terms are only revealed in a barely visible part of the interface, this may be treated as a violation.
Но важно: без проработки структуры кампаний и семантики бюджет просто сливается.
Правильно настроенная реклама дает:
Penalties under the consumer protection law may reach 2,000,000 AED, and may increase for repeat violations.
Responsibility
Federal Decree-Law No. 55 of 2023 on Media Regulation covers advertising and digital materials.
Key requirements include:
Key requirements include:
Violations may result in fines of up to 1,000,000 AED and other sanctions.
no false or misleading information
Advertising must not:
contain exaggerations that mislead
create a false sense of scarcity
distort facts about the product
transparency principles must be observed
user rights and data must be respected
Media and advertising law
Pre-ticked boxes or automatic service activation without explicit user consent.
In the UAE such practices may be treated as misleading, especially when linked to financial obligations.
In the UAE such practices may be treated as misleading, especially when linked to financial obligations.
(01) Hidden subscriptions
Critical information presented in a form that is difficult to read. If the user could not reasonably notice the terms, they may be considered undisclosed.
(02) Small print
Wording that places psychological pressure on the user.
There is no direct prohibition, but such practices may be examined in the context of misleading advertising or violations of ethical communication standards.
There is no direct prohibition, but such practices may be examined in the context of misleading advertising or violations of ethical communication standards.
(03) Confirmshaming buttons
Easy sign-up, difficult cancellation. If the cancellation process does not match the stated terms, this may be classified as a consumer rights violation.
(04) Roach Motel
Urgency or scarcity messages that do not reflect reality. These practices fall directly under the prohibition on misleading advertising.
(05) False urgency
Main types of dark patterns and their legal status
In the UAE, dark patterns are not a "grey area" in the conventional sense.
If an interface or advertisement:
If an interface or advertisement:
hides material information
— this may be classified as a legal violation.
What is acceptable:
clear and prominent calls to action
transparent disclosure of terms
genuine time or quantity limitations
simple and understandable user flows
What creates risks:
hiding payment or subscription terms
pre-ticked consents
complicated service cancellation
artificial scarcity
manipulative wording
distorts the perception of terms
makes it harder to cancel a service
The bottom line: where the line falls
In the UAE market, interface transparency and honest communication are not just a matter of reputation; they are a matter of legal compliance. Practices that may seem like "aggressive marketing" can, in certain cases, cross into legal risk territory.
When working on advertising, websites, and funnels, it is important to consider not just conversion, but the integrity of the interaction with the user.
When working on advertising, websites, and funnels, it is important to consider not just conversion, but the integrity of the interaction with the user.
conclusion
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