On September 23, 2026, IRDAI released its consultation paper, “Recalibrating Economics of Insurance Distribution”. The consultation paper brings ‘dark patterns’, as defined under the Guidelines for Prevention and Regulation of Dark Patterns, 2023, within its ambit. IRDAI also singles out the practice of collecting personal information before users can access product features and pricing information.

Our client alert offers a preliminary assessment of classification of the practice of collecting personal information as a dark pattern. It also sets out a practical list of dos and don’ts for insurers and distributors. As digital and AI led distribution grows, product and compliance teams need to understand dark patterns. We recommend that businesses review their digital practices now that IRDAI has brought dark patterns within its framework.

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