Editorial implementation analysis
Journey evidence worksheet
Use the existing learning taxonomy to choose an evidence question. This worksheet is our implementation interpretation. It does not turn research terms into legal rules or classify a real business.
- Record the journey, release, date, user context and available starting state.
- Capture the complete sequence, visible options, wording, defaults and outcomes.
- Identify the applicable rule, scope, status and each element separately.
- Record evidence supporting and challenging the concern, legitimate explanations and unobserved steps.
- Assign a responsible decision maker, preserve the evidence and test the fairer alternative.
Regulatory claims and source revisions · Readiness checklist
| Research term and journey | Legal mapping and status | Evidence to retain | Fairer alternative |
|---|---|---|---|
| Account deletion obstruction: definition, examples and fairer design Account Management | 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. |
| Offer a clear self-service deletion route, distinguish deletion from deactivation, and confirm the resulting state. |
| Activity messages: definition, examples and fairer design Pricing | 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. |
| Use accurate, auditable and appropriately time-bounded activity data and explain what the metric represents. |
| Automatic attention capture: definition, examples and fairer design Account Management, Pricing | 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. |
| Require deliberate continuation or provide clear, persistent pause and disable controls with natural stopping cues. |
| Bait and switch: definition, examples and fairer design Account Management, Checkout | 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. |
| Make the action produce its represented result or disclose and obtain assent to any material change before commitment. |
| Bundled options: definition, examples and fairer design Checkout, Pricing | 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. |
| Show component consequences and prices and provide granular, equally accessible choices where components are separable. |
| Obstruction and cancellation friction Subscription, Account Management, Cancellation | UCPD Articles 5 to 9: Possible risk indicator. The full cancellation journey may be relevant to unfair, misleading or aggressive-practice analysis depending on professional diligence, material information and undue influence. DSA Article 25: Possible risk indicator. For online platforms, interface choices that materially distort or impair free and informed decisions require assessment under the specific provision and Commission guidance, including Article 25(2) where the UCPD or GDPR covers the practice. |
| Offer an easily found cancellation route in a channel proportionate to signup, disclose the effective date and consequences, permit review before confirmation and give an immediate durable receipt. Retention offers should be optional and easy to bypass. |
| Choice or information overload: definition, examples and fairer design Pricing, Signup | 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. |
| Structure choices around comparable dimensions, surface key consequences and avoid using volume to hide a default or preferred outcome. |
| Comparison prevention: definition, examples and fairer design Pricing | 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. |
| Use consistent units, terminology and side-by-side material totals with accessible supporting detail. |
| Complex or inaccessible language: definition, examples and fairer design Cancellation, Checkout | 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. |
| Use the user's selected language, plain structure and explained terminology for material consequences. |
| Confirmshaming and manipulative wording Signup, Checkout, Subscription, Cancellation | UCPD Articles 5 and 8 to 9: Possible risk indicator. Wording and pressure can be relevant to professional-diligence and aggressive-practice analysis, including harassment, coercion or undue influence in context. DSA Article 25: Possible risk indicator. On online platforms, wording is part of interface organisation and operation when assessing deception, manipulation or material impairment of decisions; Article 25(2) must be checked where the UCPD or GDPR applies. |
| Label choices with neutral, parallel verbs and state factual consequences in the same tone. If a material risk genuinely follows, explain it specifically and proportionately rather than attaching a moral judgement to refusal. |
| Contact harvesting and coerced referrals: definition, examples and fairer design Signup, Account Management | 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. |
| Make contact access and referrals optional, granular and previewable; require affirmative confirmation for every recipient and message. |
| Customer-support obstruction: definition, examples and fairer design Account Management, Pricing | 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. |
| Provide a discoverable support route, preserve context, and offer viable escalation for unresolved material issues. |
| Dead end: definition, examples and fairer design Account Management, Cancellation | 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. |
| Provide a functional completion route, preserve progress, and surface recoverable errors equally across options. |
| Disguised advertisement or action: definition, examples and fairer design Pricing | 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. |
| Label advertising and action outcomes clearly before interaction and avoid mimicking unrelated controls or editorial content. |
| Drip pricing and hidden mandatory charges Pricing, Checkout, Subscription | UCPD Articles 6 to 7 and Annex I: Express rule. Price and the manner in which it is calculated can be material information; misleading actions, omissions and specified bait practices require assessment. CRD Article 6: Express rule. Before a distance contract, traders must provide the total price inclusive of taxes and, where it cannot reasonably be calculated, the calculation method and additional charges. |
| Display the total including mandatory charges as soon as the necessary information is available, explain any genuinely variable component, and separate optional extras without preselection. Preserve an itemised breakdown so users can understand rather than reconstruct the total. |
| False hierarchy in digital interfaces Signup, Pricing, Checkout, Subscription | UCPD Articles 5 to 7: Possible risk indicator. Presentation can matter when assessing professional diligence, misleading action or omission and effects on the average consumer's transactional decision. DSA Article 25: Express rule. For providers of online platforms, interface design must not deceive, manipulate or otherwise materially distort or impair recipients' ability to make free and informed decisions. Article 25(2) must also be checked where the UCPD or GDPR already covers the practice. |
| Present materially different choices with comparable prominence, plain labels and consequences close to the control. Hierarchy can still guide reading order, but should not hide or de-emphasise a genuine refusal or lower-cost path. |
| Countdown timer: definition, examples and fairer design Pricing, Checkout | 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. |
| Use timers only for genuine deadlines, keep them consistent, and make the represented consequence occur at expiry. |
| Feedforward ambiguity: definition, examples and fairer design Checkout, Account Management | 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. |
| Name the material consequence in the action label or immediately adjacent disclosure before activation. |
| Forced disclosure or excessive data request: definition, examples and fairer design Pricing | 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. |
| Request only data necessary for the current goal, make secondary uses optional, and explain purpose and consequences clearly. |
| Forced or bundled consent: definition, examples and fairer design Signup, Checkout | 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. |
| Separate distinct purposes, make optional uses genuinely optional, and provide an equally accessible refusal path. |
| Forced registration: definition, examples and fairer design Checkout, Pricing | 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. |
| Provide a clearly visible guest or no-account path unless registration is genuinely necessary, and explain necessity before collecting data. |
| Gamified or paid access coercion: definition, examples and fairer design Account Management | 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. |
| Disclose access conditions before acquisition and avoid making disproportionate repetition or surprise payment the practical path to expected functionality. |
| Hidden information and concealed consequences Pricing, Checkout, Subscription, Cancellation | UCPD Articles 6 to 7: Express rule. Misleading actions and omissions can include unclear, unintelligible, ambiguous or untimely presentation of material information. CRD Articles 6 and 8: Express rule. Distance-contract information duties require specified information in a clear and comprehensible manner before the consumer is bound. |
| Put material price, duration, renewal, limitation and cancellation information beside the relevant decision, using specific headings and readable contrast. Progressive disclosure can organise detail, but the first layer should expose facts likely to change the decision. |
| Hidden subscription or forced continuity: definition, examples and fairer design Subscription, Checkout | 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. |
| Present every material subscription, renewal and exit term clearly before assent and satisfy current notice rules. |
| High-demand claim: definition, examples and fairer design Pricing | 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. |
| Base demand messages on current auditable data and state the metric and period without exaggeration. |
| Intermediate currency: definition, examples and fairer design Checkout | 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. |
| Show the current real-money equivalent and total before commitment and avoid conversion structures that obscure or strand value. |
| Limited-time or reservation claim: definition, examples and fairer design Pricing, Checkout | 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. |
| Use genuine fixed time limits, state the consequence accurately, and stop displaying the claim when it expires. |
| Low-stock claim: definition, examples and fairer design Pricing, Checkout | 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. |
| Use current inventory data, avoid false precision, and remove or update the claim promptly when stock changes. |
| Misleading reference pricing: definition, examples and fairer design Pricing | 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. |
| Use a truthful, representative comparison basis and explain the reference period or basis close to the claim. |
| Negative option or unauthorised transaction: definition, examples and fairer design Subscription, Cancellation | 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. |
| Obtain clear, specific assent before any paid consequence and do not treat silence or inactivity as a new authorisation. |
| Obstructed alternative: definition, examples and fairer design Checkout, Signup | 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. |
| Place equivalent alternatives in the same decision context with comparable discoverability and no unnecessary steps. |
| Popularity claims: definition, examples and fairer design Pricing | 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. |
| Use popularity claims only with a defined population, period and metric; document the calculation beside the claim or replace it with factual product information. |
| Preselection and commercially preferred defaults Signup, Checkout, Subscription, Account Management | CRD Article 22: Express rule. Additional payments require express consent; the Directive addresses consent inferred through default options the consumer must reject. GDPR Articles 4(11) and 7: Possible risk indicator. Where consent is the legal basis, it must be freely given, specific, informed and unambiguous and demonstrated by the controller. |
| Use a neutral initial state for optional payments or consent-dependent choices and require an affirmative selection. For convenience defaults that are permitted, explain the effect, provide a nearby alternative and make later reversal straightforward. |
| Pressured upselling: definition, examples and fairer design Subscription, Checkout | 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. |
| Present price and commitment alternatives comparably and avoid preselecting or obscuring the more expensive outcome. |
| Privacy maze: definition, examples and fairer design Account Management | 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. |
| Provide a coherent privacy-control overview, consistent labels and direct controls for common restrictive choices. |
| Repeated prompting: definition, examples and fairer design Signup, Checkout | 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. |
| Respect decline and dismissal, provide a durable preference, and limit reminders to justified, transparent intervals. |
| Sneak into basket: definition, examples and fairer design Checkout | 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. |
| Add an item only after a deliberate selection, preserve removal through every recalculation and show the updated line item and total before commitment. |
| Testimonials or endorsements: definition, examples and fairer design Pricing | 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. |
| Use authentic, supportable testimonials and clearly disclose material commercial connections and limitations. |
| Trick question: definition, examples and fairer design Signup, Cancellation | 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. |
| Use explicit action labels that name the resulting state, remove double negatives and verify that each response produces the consequence a user can reasonably predict. |