Towards Key Contributing Factors in Identifying Dark Pattern Autonomy Violations under the EU Digital Services Act

Sanju Ahuja; Johanna Gunawan; Nataliia Bielova; Cristiana Teixeira Santos

doi:10.1145/3715668.3736336

Towards Key Contributing Factors in Identifying Dark Pattern Autonomy Violations under the EU Digital Services Act

Sanju Ahuja^*
, Johanna Gunawan
, Nataliia Bielova
, Cristiana Teixeira Santos

^*Corresponding author for this work

Research output: Chapter in Book/Report/Conference proceeding › Conference article in proceeding › Academic › peer-review

Abstract

Dark patterns refer to design practices which undermine users’ ability to make autonomous and informed choices in relation to digital systems. The recent EU Digital Services Act (DSA) aims to protect users from such dark patterns and their effects. DSA Article 25 prohibits three autonomy violation types: deception, manipulation and distortion/impairment. However, for regulation of dark patterns, it is important to reason about why an observed design practice constitutes a particular autonomy violation type, to show that it indeed violates the DSA. In this work-in-progress, two experts (with HCI, CS and legal background) mapped 59 known dark patterns onto these three autonomy violation types. We then analysed our rationale for this mapping to identify eight design factors which can help determine the dark pattern autonomy violation(s). Our analysis aims to situate existing dark patterns knowledge within the DSA legal framework, to support regulation and compliance of such design practices.

Original language	English
Title of host publication	DIS 2025 - Companion Proceedings of the 2025 ACM Designing Interactive Systems Conference
Subtitle of host publication	Designing for a Sustainable Ocean
Editors	Nuno Nunes, Valentina Nisi, Ian Oakley
Place of Publication	New York
Publisher	Association for Computing Machinery
Pages	501-507
Number of pages	7
ISBN (Electronic)	9798400714863
DOIs	https://doi.org/10.1145/3715668.3736336
Publication status	Published - 5 Jul 2025
Event	2025 ACM Conference on Designing Interactive Systems, DIS 2025 Companion - Madiera, Portugal Duration: 5 Jul 2025 → 9 Jul 2025 https://dis.acm.org/2025/

Conference

Conference	2025 ACM Conference on Designing Interactive Systems, DIS 2025 Companion
Abbreviated title	DIS 2025
Country/Territory	Portugal
City	Madiera
Period	5/07/25 → 9/07/25
Internet address	https://dis.acm.org/2025/

Keywords

autonomy violations
dark patterns
deceptive design
Digital Services Act

Access to Document

10.1145/3715668.3736336Licence: CC BY

Cite this

Ahuja, S., Gunawan, J., Bielova, N., & Santos, C. T. (2025). Towards Key Contributing Factors in Identifying Dark Pattern Autonomy Violations under the EU Digital Services Act. In N. Nunes, V. Nisi, & I. Oakley (Eds.), DIS 2025 - Companion Proceedings of the 2025 ACM Designing Interactive Systems Conference : Designing for a Sustainable Ocean (pp. 501-507). Association for Computing Machinery. https://doi.org/10.1145/3715668.3736336

Ahuja, Sanju ; Gunawan, Johanna ; Bielova, Nataliia et al. / Towards Key Contributing Factors in Identifying Dark Pattern Autonomy Violations under the EU Digital Services Act. DIS 2025 - Companion Proceedings of the 2025 ACM Designing Interactive Systems Conference : Designing for a Sustainable Ocean. editor / Nuno Nunes ; Valentina Nisi ; Ian Oakley. New York : Association for Computing Machinery, 2025. pp. 501-507

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title = "Towards Key Contributing Factors in Identifying Dark Pattern Autonomy Violations under the EU Digital Services Act",

abstract = "Dark patterns refer to design practices which undermine users{\textquoteright} ability to make autonomous and informed choices in relation to digital systems. The recent EU Digital Services Act (DSA) aims to protect users from such dark patterns and their effects. DSA Article 25 prohibits three autonomy violation types: deception, manipulation and distortion/impairment. However, for regulation of dark patterns, it is important to reason about why an observed design practice constitutes a particular autonomy violation type, to show that it indeed violates the DSA. In this work-in-progress, two experts (with HCI, CS and legal background) mapped 59 known dark patterns onto these three autonomy violation types. We then analysed our rationale for this mapping to identify eight design factors which can help determine the dark pattern autonomy violation(s). Our analysis aims to situate existing dark patterns knowledge within the DSA legal framework, to support regulation and compliance of such design practices.",

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author = "Sanju Ahuja and Johanna Gunawan and Nataliia Bielova and Santos, \{Cristiana Teixeira\}",

note = "Funding Information: This work has been supported by the ANR 22-PECY-0002 IPoP (Interdisciplinary Project on Privacy) project of the Cybersecurity PEPR, Inria DATA4US Exploratory Action project, and the Inria International Chair funding. Publisher Copyright: {\textcopyright} 2025 Copyright held by the owner/author(s); 2025 ACM Conference on Designing Interactive Systems, DIS 2025 Companion, DIS 2025 ; Conference date: 05-07-2025 Through 09-07-2025",

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Ahuja, S, Gunawan, J, Bielova, N & Santos, CT 2025, Towards Key Contributing Factors in Identifying Dark Pattern Autonomy Violations under the EU Digital Services Act. in N Nunes, V Nisi & I Oakley (eds), DIS 2025 - Companion Proceedings of the 2025 ACM Designing Interactive Systems Conference : Designing for a Sustainable Ocean. Association for Computing Machinery, New York, pp. 501-507, 2025 ACM Conference on Designing Interactive Systems, DIS 2025 Companion, Madiera, Portugal, 5/07/25. https://doi.org/10.1145/3715668.3736336

Towards Key Contributing Factors in Identifying Dark Pattern Autonomy Violations under the EU Digital Services Act. / Ahuja, Sanju; Gunawan, Johanna; Bielova, Nataliia et al.
DIS 2025 - Companion Proceedings of the 2025 ACM Designing Interactive Systems Conference : Designing for a Sustainable Ocean. ed. / Nuno Nunes; Valentina Nisi; Ian Oakley. New York: Association for Computing Machinery, 2025. p. 501-507.

Research output: Chapter in Book/Report/Conference proceeding › Conference article in proceeding › Academic › peer-review

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AU - Bielova, Nataliia

AU - Santos, Cristiana Teixeira

N1 - Funding Information: This work has been supported by the ANR 22-PECY-0002 IPoP (Interdisciplinary Project on Privacy) project of the Cybersecurity PEPR, Inria DATA4US Exploratory Action project, and the Inria International Chair funding. Publisher Copyright: © 2025 Copyright held by the owner/author(s)

PY - 2025/7/5

Y1 - 2025/7/5

N2 - Dark patterns refer to design practices which undermine users’ ability to make autonomous and informed choices in relation to digital systems. The recent EU Digital Services Act (DSA) aims to protect users from such dark patterns and their effects. DSA Article 25 prohibits three autonomy violation types: deception, manipulation and distortion/impairment. However, for regulation of dark patterns, it is important to reason about why an observed design practice constitutes a particular autonomy violation type, to show that it indeed violates the DSA. In this work-in-progress, two experts (with HCI, CS and legal background) mapped 59 known dark patterns onto these three autonomy violation types. We then analysed our rationale for this mapping to identify eight design factors which can help determine the dark pattern autonomy violation(s). Our analysis aims to situate existing dark patterns knowledge within the DSA legal framework, to support regulation and compliance of such design practices.

AB - Dark patterns refer to design practices which undermine users’ ability to make autonomous and informed choices in relation to digital systems. The recent EU Digital Services Act (DSA) aims to protect users from such dark patterns and their effects. DSA Article 25 prohibits three autonomy violation types: deception, manipulation and distortion/impairment. However, for regulation of dark patterns, it is important to reason about why an observed design practice constitutes a particular autonomy violation type, to show that it indeed violates the DSA. In this work-in-progress, two experts (with HCI, CS and legal background) mapped 59 known dark patterns onto these three autonomy violation types. We then analysed our rationale for this mapping to identify eight design factors which can help determine the dark pattern autonomy violation(s). Our analysis aims to situate existing dark patterns knowledge within the DSA legal framework, to support regulation and compliance of such design practices.

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KW - deceptive design

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DO - 10.1145/3715668.3736336

M3 - Conference article in proceeding

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EP - 507

BT - DIS 2025 - Companion Proceedings of the 2025 ACM Designing Interactive Systems Conference

A2 - Nunes, Nuno

A2 - Nisi, Valentina

A2 - Oakley, Ian

PB - Association for Computing Machinery

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T2 - 2025 ACM Conference on Designing Interactive Systems, DIS 2025 Companion

Y2 - 5 July 2025 through 9 July 2025

ER -

Ahuja S, Gunawan J, Bielova N, Santos CT. Towards Key Contributing Factors in Identifying Dark Pattern Autonomy Violations under the EU Digital Services Act. In Nunes N, Nisi V, Oakley I, editors, DIS 2025 - Companion Proceedings of the 2025 ACM Designing Interactive Systems Conference : Designing for a Sustainable Ocean. New York: Association for Computing Machinery. 2025. p. 501-507 doi: 10.1145/3715668.3736336

Towards Key Contributing Factors in Identifying Dark Pattern Autonomy Violations under the EU Digital Services Act

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