The countdown clock says the deal ends in nine minutes. A hotel room appears to cost $129 until the checkout page adds another $38. A free trial requires a credit card. Signing up takes two clicks, but canceling requires navigating five screens and rejecting three additional offers.

Those are examples of what regulators and researchers call “dark patterns” — website and app designs that steer consumers toward decisions they might not otherwise make.

The techniques can be remarkably ordinary. Instead of directly lying to a customer, a company can bury important information, preselect an option, make one button prominent and another nearly invisible, manufacture urgency, or simply make it harder to say no than to say yes.

The Federal Trade Commission has described dark patterns as design practices that can obscure, subvert or impair consumer decision-making. In an international review of 642 websites and mobile apps offering subscription services, consumer-protection authorities found that nearly 76 percent used at least one possible dark pattern and nearly 67 percent used more than one.

The pressure starts before the purchase

One of the most recognizable techniques is artificial urgency.

“Only two left.”

“Sale ends in 10 minutes.”

“Twenty-three people are viewing this item.”

“Someone near you just purchased this.”

Scarcity and time limits can be legitimate. They can also be engineered to keep a customer from leaving the page, checking another seller or thinking about the purchase overnight.

Another common technique is known as interface interference — designing a page so that the option most profitable to the company is visually obvious while the less profitable option is obscured. Regulators examining subscription sites identified that practice, along with hiding or delaying important information, as among the most common potential dark patterns they encountered.

The large brightly colored button may say “Continue,” “Accept” or “Start free trial.”

The button that avoids a subscription, rejects tracking or declines an additional purchase may be gray, smaller, below the fold or written as plain text.

The consumer still technically has a choice. The page simply makes one choice much easier to make.

The cheap price that gets more expensive

Another familiar technique is drip pricing.

The consumer is shown one price early in the transaction and learns about additional charges later.

A ticket, hotel stay, delivery order or online service can appear inexpensive until service charges, platform fees, processing fees or other mandatory costs appear near the end of checkout.

By then, the customer has already spent time selecting the product, entering information and moving through the purchase process.

The FTC has specifically identified hiding important terms, disguising advertisements, sneaking products into shopping carts and obscuring the full cost of transactions as examples of dark-pattern practices.

Prechecked boxes operate on the same principle.

Shipping protection, warranties, recurring deliveries, marketing permissions or other options can already be selected when a customer reaches the checkout page. Instead of asking the customer to purchase something, the interface requires the customer to notice it and actively remove it.

The subscription trap

The subscription economy has produced another category of pressure tactic: getting customers enrolled easily and making them work to get back out.

The arrangement is often called a negative option.

A consumer accepts a free trial or introductory offer. Unless the consumer later takes action, the company continues the relationship and begins charging.

Negative-option arrangements are not inherently deceptive. They can be convenient when the consumer understands the terms and wants continuing service.

Problems arise when renewal terms are difficult to find, charges begin without clear informed consent or cancellation becomes unnecessarily complicated.

The FTC said this year that consumers continue to encounter practices that prevent them from understanding subscription terms, enroll them without express informed consent or deter them from canceling. The agency is again considering federal rules governing those practices.

The difference between enrollment and cancellation is often where the design becomes most obvious.

Joining may require clicking one button.

Leaving can involve searching account settings, reentering a password, answering questions about why the customer is leaving, rejecting discounted offers, clicking through warnings about lost benefits and then locating a final confirmation button.

That design has sometimes been described as a “roach motel”: easy to get into, much harder to get out.

Washington tried “click to cancel”

The FTC adopted a broad negative-option rule in 2024 that included a requirement intended to make cancellation no more difficult than enrollment.

That regulation became widely known as the “click-to-cancel” rule.

But the rule did not survive.

A federal appeals court vacated the 2024 rule in July 2025. The FTC has since restarted the regulatory process and, in March 2026, requested public comment on whether and how federal rules should address recurring charges, difficult cancellation procedures and other negative-option practices.

Federal enforcement has not disappeared in the meantime.

The FTC continues using existing consumer-protection laws. In one pending case, the agency has accused Uber of enrolling consumers in its Uber One subscription without proper consent and making cancellation difficult despite advertising that users could cancel at any time. The allegations remain pending and have not been finally adjudicated.

Vermont already regulates some automatic renewals

Vermont has its own automatic-renewal law.

Under 9 V.S.A. § 2454a, covered consumer contracts with an initial term of at least one year cannot automatically renew for a period longer than one month unless the automatic-renewal provision is clearly disclosed, the consumer affirmatively opts in and the seller provides advance notice before renewal.

For covered contracts accepted online, Vermont law also requires businesses to allow consumers to terminate them online. Violations are treated as unfair and deceptive acts under Vermont’s Consumer Protection Act. Certain financial institutions, credit unions and insurance contracts are exempt.

The law does not cover every modern monthly subscription arrangement.

A bill introduced this year, H.668, would have expanded the statute to contracts with initial terms of one month or longer and would have required online cancellation to be available in the same, similar or easier manner than online enrollment.

As of the Legislature’s current bill record, H.668 remains in the House Committee on Commerce and Economic Development. Its last recorded action was its January 14 referral to the committee.

Another bill, S.310, dealt with subscription-renewal notifications. It was introduced with 17 Senate sponsors but likewise did not advance beyond committee during the 2025-26 session. Its last recorded action was referral to the Senate Committee on Economic Development, Housing and General Affairs on January 27.

Vermont’s new privacy law also reaches manipulative design

Vermont enacted a broader consumer-data law this year through Act 145, the Vermont Data Privacy and Online Surveillance Act.

The law gives covered consumers rights involving access, deletion, correction and certain uses and sales of personal data. It also requires affirmative consent for some sensitive-data processing and requires businesses to provide a mechanism for withdrawing consent that is at least as easy as the mechanism used to give it.

Most of the law is scheduled to take effect January 1, 2028. Enforcement is assigned to the Vermont Attorney General under the state Consumer Protection Act.

That matters because dark patterns are not limited to getting money.

The same techniques can be used to obtain personal information.

A website may offer one large “Accept all” button while requiring users to navigate several menus to reject tracking. An app may repeatedly ask for location access after the user has declined. Privacy settings may be written so that keeping information private requires substantially more effort than sharing it.

The transaction in those cases is not necessarily dollars. It is data.

Watch the friction

Consumers do not need to memorize the terminology to recognize the pattern.

Watch what happens when the company wants something from you.

If purchasing takes one click but canceling takes six, notice it.

If rejecting an offer requires finding a gray link while accepting requires pressing a giant button, notice it.

If the real price appears only after several checkout screens, notice it.

If a “free” offer requires payment information, check exactly when billing begins.

If a countdown clock resets, the urgency probably was not very urgent.

And before accepting any subscription, search the page for words including renewal, recurring, monthly, annual, trial, cancel and automatic.

The central issue with dark patterns is not that businesses try to sell products. Advertising has always been designed to persuade.

The difference is that persuasion asks a customer to make a decision.

A dark pattern attempts to engineer the decision itself.