Issues Concerning Dark Patterns in Competition Policy and Antimonopoly Act

Issues Concerning Dark Patterns in Competition Policy and Antimonopoly Act(2025.5)

HISHINUMA Isao(Senior Economic Analyst, Japan Fair Trade Commission and Researcher of the Competition Policy Research Center)
TANAKA Yuji(Deputy Director, General Affairs Division, Japan Fair Trade Commission and Competition Policy Research Center)
SEKINE Makiko(Deputy Director, General Affairs Division, Japan Fair Trade Commission and Competition Policy Research Center)
UETSUGI Takahiro(Section Chief, General Affairs Division, Japan Fair Trade Commission and Competition Policy Research Center)
YOSHIOKA Mairi(General Affairs Division, Japan Fair Trade Commission and Competition Policy Research Center)

Abstract

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This report reviews the specific practices of "dark patterns" that induce consumers to make unintended choices through the display of websites and applications, as well as the status of regulations in Japan and abroad, and summarizes the competition policy concerns, theory of harm, regarding dark patterns and the scope of applicability of the current Antimonopoly Act to various types of acts that are considered to be dark patterns.

CPDP-101-J(8,959 KB)