Forced action · European Union
Contact harvesting and coerced referrals
The label “Contact harvesting and coerced referrals” describes this recurring design mechanism: the service extracts contact information, sends or prepares unwanted invitations, or ties functionality to recruiting other people. It is a design and research taxonomy, not a standalone legal conclusion. Depending on the complete journey and likely effect, current EU consumer or sector rules may require separate assessment. No published Digital Fairness Act proposal currently creates a pattern-specific prohibition or duty under this label.
- Family
- Forced action
- Also known as
- Journey stages
Definition
What is this pattern?
The service extracts contact information, sends or prepares unwanted invitations, or ties functionality to recruiting other people. The label describes a recurring design mechanism; whether a particular implementation is harmful or unlawful depends on the complete journey, audience, evidence and rules within scope.
How it works
The service extracts contact information, sends or prepares unwanted invitations, or ties functionality to recruiting other people. Progress depends on exposing or contacting other people, turning a referral or address-book permission into the price of access to an unrelated feature.
Warning signs
- Contact access, recipient selection, invitation or referral is involved.
- Consent, recipient choice or downstream use is unclear, defaulted or coerced.
- The behaviour is linked to access, reward or normal progression.
Potential harms
- Contacts who never used the service may be exposed or invited, while the new user loses a meaningful refusal.
- The user is pressured to disclose other people’s contact data and send messages unrelated to the export task.
Learn by comparison
What does this look like?
These fictional examples make the design mechanism easier to recognise. They do not depict a real company and do not establish that an individual interface is unlawful.
Illustrative example 1 · Social app onboarding
A fictional community app stops onboarding at an address-book permission screen and gives no visible way to continue without uploading contacts.
Potential consumer harm: Contacts who never used the service may be exposed or invited, while the new user loses a meaningful refusal.
Illustrative example 2 · Collaboration workspace
A fictional workspace keeps export disabled until the user supplies three colleagues’ addresses and sends invitations from the service.
Potential consumer harm: The user is pressured to disclose other people’s contact data and send messages unrelated to the export task.
Address-book import blocks onboarding
A fictional community app stops onboarding at an address-book permission screen and gives no visible way to continue without uploading contacts.
Find everyone you know. Onboarding cannot continue until contacts are uploaded.. Allow contacts. Skip for now
Find contacts later. Contact discovery is optional and onboarding can continue without it.. Skip for now. Allow contacts. What happens next, expanded: Activating “Skip for now” produces the outcome stated on the control.
Why the first version can mislead: The additional dependency controls access to the signup goal. The panel states: “Onboarding cannot continue until contacts are uploaded.” Reviewers need to establish whether “Allow contacts” is necessary for the selected task or pressures the user into a separable action. Contacts who never used the service may be exposed or invited, while the new user loses a meaningful refusal.
What a fairer design does: Explain the optional discovery benefit, provide a visible skip control and do not prepare invitations without a separate deliberate action.
Show annotated differences (2)
- Skip for nowIn “Address-book import blocks onboarding”, this element shows how contact harvesting and coerced referrals can shape the decision.
- What happens next, expanded: Activating “Skip for now” produces the outcome stated on the control.In “Address-book import blocks onboarding”, this element keeps the clearer alternative visible at the same decision point.
Review questions (3)
- What functional need makes “Allow contacts” necessary for the social app onboarding goal, and can that need be met with less disclosure or commitment?
- Can the dialog be dismissed, what action does each control trigger, and what later state confirms or contradicts “Contact access, recipient selection, invitation or referral is involved”?
- Could the stated purpose make this dependency genuinely necessary under the boundary “Voluntary one-recipient sharing with preview and confirmation”, and what product evidence would demonstrate that necessity?
Feature unlocked by recruiting friends
A fictional workspace keeps export disabled until the user supplies three colleagues’ addresses and sends invitations from the service.
Invite three people to export. The export link stays locked until three invitations are sent.. Add contacts. Unconfirmed state: Add contacts
Export your workspace. Export works independently; inviting collaborators remains optional.. Download export. Saved state: Download export. Persisted account state, expanded: The saved state behind “Download export” remains consistent after refresh and across supported channels.
Why the first version can mislead: The additional dependency controls access to the account management goal. The panel states: “The export link stays locked until three invitations are sent.” Reviewers need to establish whether “Add contacts” is necessary for the selected task or pressures the user into a separable action. The user is pressured to disclose other people’s contact data and send messages unrelated to the export task.
What a fairer design does: Keep export independent of referrals and let users invite collaborators only when collaboration is their chosen goal.
Show annotated differences (2)
- Unconfirmed state: Add contactsIn “Feature unlocked by recruiting friends”, this element shows how contact harvesting and coerced referrals can shape the decision.
- Persisted account state, expanded: The saved state behind “Download export” remains consistent after refresh and across supported channels.In “Feature unlocked by recruiting friends”, this element keeps the clearer alternative visible at the same decision point.
Review questions (3)
- What functional need makes “Add contacts” necessary for the collaboration workspace goal, and can that need be met with less disclosure or commitment?
- Test the control across refresh, device and account states; is “Consent, recipient choice or downstream use is unclear, defaulted or coerced” still observable after persistence is considered?
- Could the stated purpose make this dependency genuinely necessary under the boundary “clearly optional referral program with no functional penalty”, and what product evidence would demonstrate that necessity?
What is a fairer alternative?
Make contact access and referrals optional, granular and previewable; require affirmative confirmation for every recipient and message.
Legal and information status
Legal position at a glance
The service extracts contact information, sends or prepares unwanted invitations, or ties functionality to recruiting other people. Progress depends on exposing or contacting other people, turning a referral or address-book permission into the price of access to an unrelated feature. Risk increases where the mechanism changes a material consumer choice, hides a consequence or makes a genuine alternative harder to use. The taxonomy label remains a review prompt and does not establish an infringement.
Dark-pattern research taxonomy
Editorial analysis
The cited research sources support identification and comparison of this recurring interface mechanism. They do not determine that a particular interface is unlawful.
UCPD Articles 5 to 9, where applicable
Possible risk indicator
Depending on the trader, audience, overall presentation, material information and likely transactional effect, the facts may require a separate assessment under the applicable UCPD provisions.
Evidence layers and open questions
Applicable law, enforcement records, policy preparation, stakeholder input, editorial analysis and unknown future details remain visibly distinct.
Current lawCurrent law
The UX label “Contact harvesting and coerced referrals” is not a standalone EU offence. Depending on the trader, audience, complete presentation, omitted information and likely transactional effect, the observed facts may require a separate assessment under the applicable UCPD provisions or another instrument within scope.
Under considerationUnder consideration
The Commission is preparing a Digital Fairness Act initiative, but the call for evidence does not select a final rule for contact harvesting and coerced referrals or establish that this taxonomy term will appear in a proposal.
Editorial analysisEditorial analysis
The pattern definition, variants and examples on this page use the cited research taxonomy sources to support recognition and comparison. That analytical classification is not a legal conclusion about an individual interface.
UnknownUnknown
No published DFA proposal currently establishes a definition, covered actor, legal threshold, duty, remedy, transition rule or application date for contact harvesting and coerced referrals. Those details remain unknown pending primary legislative text.
Context matters
Context and boundary cases
- Contact access, recipient selection, invitation or referral is involved.
- Consent, recipient choice or downstream use is unclear, defaulted or coerced.
- The behaviour is linked to access, reward or normal progression.
- Exclude or qualify the label where voluntary one-recipient sharing with preview and confirmation.
- Exclude or qualify the label where clearly optional referral program with no functional penalty.
When a similar design can serve a legitimate purpose
- A similar design should not be classified this way where voluntary one-recipient sharing with preview and confirmation.
- A similar design should not be classified this way where clearly optional referral program with no functional penalty.
Operational review
What teams should review
- Teams
- What functional need makes “Allow contacts” necessary for the social app onboarding goal, and can that need be met with less disclosure or commitment?
- Can the dialog be dismissed, what action does each control trigger, and what later state confirms or contradicts “Contact access, recipient selection, invitation or referral is involved”?
- Could the stated purpose make this dependency genuinely necessary under the boundary “Voluntary one-recipient sharing with preview and confirmation”, and what product evidence would demonstrate that necessity?
- What functional need makes “Add contacts” necessary for the collaboration workspace goal, and can that need be met with less disclosure or commitment?
- Test the control across refresh, device and account states; is “Consent, recipient choice or downstream use is unclear, defaulted or coerced” still observable after persistence is considered?
- Could the stated purpose make this dependency genuinely necessary under the boundary “clearly optional referral program with no functional penalty”, and what product evidence would demonstrate that necessity?
- Which complete journey evidence supports or contradicts the contact harvesting and coerced referrals classification?
Evidence to retain
- Versioned captures of the Signup and Account Management states before, during and after the relevant decision
- Configuration, content and event records supporting the observed contact harvesting and coerced referrals mechanism
- Responsive, keyboard and assistive-technology review of every material option and consequence
Legal map and implementation tools
Evidence base
Sources
- Dark commercial patternsOrganisation for Economic Co-operation and Development · Secondary · checked 2026-09-14 · OECD Digital Economy Papers No. 336
- Unfair Commercial Practices DirectiveEuropean Parliament and Council of the European Union · Primary · checked 2026-08-09 · Directive 2005/29/EC; CELEX 02005L0029-20220528
- Digital Fairness Act: call for evidence for an impact assessmentEuropean Commission · Primary · checked 2026-08-09 · Initiative 14622; Ares(2025)6275573
- Commission work programme 2026: Europe's Independence MomentEuropean Commission · Primary · checked 2026-09-14 · COM(2025) 870 final; CELEX 52025DC0870; Annex I item 30