Obstruction · European Union
Intermediate currency
The label “Intermediate currency” describes this recurring design mechanism: a proprietary currency makes the real monetary cost or remaining value unnecessarily hard to understand. 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.
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Definition
What is this pattern?
A proprietary currency makes the real monetary cost or remaining value unnecessarily hard to understand. 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
A proprietary currency makes the real monetary cost or remaining value unnecessarily hard to understand. A proprietary unit separates the displayed item cost from real money and bundle constraints, obscuring both the required spend and residual value.
Warning signs
- The user exchanges real value for a proprietary unit or spends that unit.
- The current real-money equivalent is not shown clearly at the purchase decision.
- Conversion structure materially impairs cost comprehension or creates unavoidable remainder.
Potential harms
- Players may struggle to understand the real cost and must buy more currency than the item requires.
- The customer may spend more than the service price and retain value that is difficult to use or recover.
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 · In-game store
A fictional game prices an item at 1,350 gems but sells gems only in uneven bundles, with no euro equivalent near the purchase action.
Potential consumer harm: Players may struggle to understand the real cost and must buy more currency than the item requires.
Illustrative example 2 · Creator marketplace
A fictional marketplace sells 100 tokens for €10 while a booking costs 84 tokens and no service costs a multiple that uses the remaining balance.
Potential consumer harm: The customer may spend more than the service price and retain value that is difficult to use or recover.
Gem bundle hides an item’s real-money cost
A fictional game prices an item at 1,350 gems but sells gems only in uneven bundles, with no euro equivalent near the purchase action.
Legendary item · 1,350 gems. Gem bundles obscure that the smallest sufficient purchase costs €19.99.. Buy more gems. Review €19.99 bundle
Legendary item · 1,350 gems (€13.50 value). Balance, shortfall and actual bundle cost are visible before commitment.. Amount affected: €19.99: Review €19.99 bundle. Review €19.99 bundle. Buy more gems. Payable total and selected items, expanded: The summary shows the line items and total before “Review €19.99 bundle” is activated.
Why the first version can mislead: The route adds avoidable effort between the user’s stated intention and completion. In this in-game store example, the obstacle is: “Gem bundles obscure that the smallest sufficient purchase costs €19.99.” Evidence should show whether the alternative remains usable and whether “Review €19.99 bundle” reaches the represented state. Players may struggle to understand the real cost and must buy more currency than the item requires.
What a fairer design does: Show the real-money equivalent, available balance and exact currency shortfall before purchase.
Show annotated differences (2)
- Review €19.99 bundleIn “Gem bundle hides an item’s real-money cost”, this element shows how intermediate currency can shape the decision.
- Payable total and selected items, expanded: The summary shows the line items and total before “Review €19.99 bundle” is activated.In “Gem bundle hides an item’s real-money cost”, this element keeps the clearer alternative visible at the same decision point.
Review questions (3)
- How many steps, waits and channel changes separate “Buy more gems” from the completed in-game store outcome?
- Compare the basket before and after the action, including total and line items; does the mutation satisfy “The user exchanges real value for a proprietary unit or spends that unit”?
- Measure the same task through the clearest available route: does the effort difference persist once “Transparent one-to-one or prominently converted loyalty points” is accounted for?
Unused tokens remain after a service booking
A fictional marketplace sells 100 tokens for €10 while a booking costs 84 tokens and no service costs a multiple that uses the remaining balance.
Book for 84 tokens. Only a 100-token bundle can be purchased and the € value is remote.. Buy 100 tokens. Pay exact amount
Book for €8.40. Direct payment is available; token use shows conversion and remaining balance.. Pay exact amount. Buy 100 tokens. Price, period and commitment, expanded: The price and material terms associated with “Pay exact amount” remain beside this choice.
Why the first version can mislead: The route adds avoidable effort between the user’s stated intention and completion. In this creator marketplace example, the obstacle is: “Only a 100-token bundle can be purchased and the € value is remote.” Evidence should show whether the alternative remains usable and whether “Pay exact amount” reaches the represented state. The customer may spend more than the service price and retain value that is difficult to use or recover.
What a fairer design does: Allow direct currency payment or explain conversion, residual value and refund options beside the token offer.
Show annotated differences (2)
- Pay exact amountIn “Unused tokens remain after a service booking”, this element shows how intermediate currency can shape the decision.
- Price, period and commitment, expanded: The price and material terms associated with “Pay exact amount” remain beside this choice.In “Unused tokens remain after a service booking”, this element keeps the clearer alternative visible at the same decision point.
Review questions (3)
- How many steps, waits and channel changes separate “Buy 100 tokens” from the completed creator marketplace outcome?
- Place the compared prices, billing periods and material terms on one evidence sheet; where does it support “The current real-money equivalent is not shown clearly at the purchase decision”?
- Measure the same task through the clearest available route: does the effort difference persist once “currency conversion required by international payment with total displayed” is accounted for?
What is a fairer alternative?
Show the current real-money equivalent and total before commitment and avoid conversion structures that obscure or strand value.
Legal and information status
Legal position at a glance
A proprietary currency makes the real monetary cost or remaining value unnecessarily hard to understand. A proprietary unit separates the displayed item cost from real money and bundle constraints, obscuring both the required spend and residual value. 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 “Intermediate currency” 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 intermediate currency 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 intermediate currency. Those details remain unknown pending primary legislative text.
Context matters
Context and boundary cases
- The user exchanges real value for a proprietary unit or spends that unit.
- The current real-money equivalent is not shown clearly at the purchase decision.
- Conversion structure materially impairs cost comprehension or creates unavoidable remainder.
- Exclude or qualify the label where transparent one-to-one or prominently converted loyalty points.
- Exclude or qualify the label where currency conversion required by international payment with total displayed.
- Exclude or qualify the label where non-purchasable game score.
When a similar design can serve a legitimate purpose
- A similar design should not be classified this way where transparent one-to-one or prominently converted loyalty points.
- A similar design should not be classified this way where currency conversion required by international payment with total displayed.
- A similar design should not be classified this way where non-purchasable game score.
Operational review
What teams should review
- Teams
- How many steps, waits and channel changes separate “Buy more gems” from the completed in-game store outcome?
- Compare the basket before and after the action, including total and line items; does the mutation satisfy “The user exchanges real value for a proprietary unit or spends that unit”?
- Measure the same task through the clearest available route: does the effort difference persist once “Transparent one-to-one or prominently converted loyalty points” is accounted for?
- How many steps, waits and channel changes separate “Buy 100 tokens” from the completed creator marketplace outcome?
- Place the compared prices, billing periods and material terms on one evidence sheet; where does it support “The current real-money equivalent is not shown clearly at the purchase decision”?
- Measure the same task through the clearest available route: does the effort difference persist once “currency conversion required by international payment with total displayed” is accounted for?
- Which complete journey evidence supports or contradicts the intermediate currency classification?
Evidence to retain
- Versioned captures of the Checkout states before, during and after the relevant decision
- Configuration, content and event records supporting the observed intermediate currency mechanism
- Responsive, keyboard and assistive-technology review of every material option and consequence
- Price-component, offer-version and calculation records linked to the captured screen
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