What is Dark Pattern? — UK Software Development Guide

4 min readJune 2025ClickMasters Technical TeamReviewed by James Whitmore, CTO
what is a dark pattern software

Direct Answer

A dark pattern (also called a deceptive design pattern) is a user interface design technique that tricks or manipulates users into doing something they didn't intend to — such as signing up for a subscription, sharing more data than they meant to, or being unable to cancel a service. Dark patterns prioritise business metrics (conversion rates, data collection) over genuine user benefit.

Dark-pattern in the UK

Dark patterns have specific UK legal status. The FCA Consumer Duty (July 2023) explicitly prohibits dark patterns for FCA-regulated firms — the "consumer understanding" and "consumer support" outcomes require software UX that does not mislead or manipulate. The ICO issued updated cookie consent guidance (2023) prohibiting deceptive designs that make consent to non-essential cookies easier than declining. The Competition and Markets Authority (CMA) has investigated dark patterns in online retail under consumer protection law. ClickMasters includes dark pattern review as part of our Consumer Duty UX audit — checking all FCA-regulated client interfaces for FCA-prohibited designs.

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