Australia has finally put the dark pattern on the priority list.

In its 2026–27 compliance and enforcement priorities, the Australian Competition and Consumer Commission said it would prioritise manipulative and false practices in digital markets. It specifically named subscription traps and other dark patterns that manipulate consumer behaviour and unfairly affect choice.

That language matters because the harm is often distributed across ordinary screens: a pre-ticked extra, a cancellation route hidden behind account menus, an offer that quietly becomes a higher plan. No single screen looks like a scandal. The customer experiences the system as a route with all the exits moved.

The design is the conduct

Consumer protection cannot only inspect the final charge or the terms document. It has to inspect the sequence: how someone is enrolled, what they see before payment, how a renewal is announced and whether the cancellation state is immediate and provable.

The practical standard is simple. Joining, understanding and leaving should each take a similar amount of effort. If the path suddenly becomes longer after a card is on file, the interface is telling on the business model.