CCS enforcement action against “dark patterns”: Three online retailers used false urgency tactics and misleading claims to pressure shoppers

9 June 2026

On 18 May 2026, the Competition and Consumer Commission of Singapore (“CCS”) issued a media release announcing that three online retailers had utilised “dark patterns”. “Dark patterns” describes user interface designs that manipulate users into taking unintended actions such as mis-purchasing, ruse sign-ups, and other deceitful user experiences.

Reacting to the CCS media release, Allen & Gledhill Partner Scott Clements, observed that CCS has identified “dark patterns” as an enforcement priority, a pattern of regulation observable also in the UK and Australia.

This article sets out CCS’ findings.

Fake numbers and fabricated countdown timers

The media release notes that investigations had revealed misleading website features used to pressure consumers into making quick purchase decisions:

• Online retailer Boarding Gate’s website: A message on the website stating “XX people are looking at this product right now” gave shoppers the illusion of real-time visitor activity and high demand. Upon examining the website’s source code, CCS discovered that these numbers were randomly generated. The site also claimed “XX people added this item to cart” without any evidence to support these assertions.
• Online retailer Origin Sleep’s website: Similar misleading tactics as that found on Boarding Gate’s website were found on mattress retailer Origin Sleep’s website including misleading cart activity claiming “Other people want this. XX people have this in their carts now” without any real-time data to back up these statements. The website checkout pages featured countdown timers warning “Hurry! Your order is reserved for xx:xx minutes”, implying purchases had to be completed before the time expired. In reality, these messages and timers had no impact on product availability or shoppers’ ability to buy.

Continuing sales disguised as time-limited

In addition to the misleading tactics set out above, Origin Sleep ran what appeared to be a time-limited sale offering “Up to 40% off” which investigators found continued for nearly two years under rotating names. For instance, a “Flash Sale” that started in January that was supposed to last for only a week seamlessly became a “Valentine’s Day Sale” in February, then a “CNY Sale,” followed by a “3.3 Mega Sale,” and so on, revealing the time-limited nature to be entirely fictional.

False scarcity

Demonstrating how misleading practices can span multiple countries, CCS was alerted to Light In The Box’s conduct by a European regulator. The retailer displayed “Almost sold out” warnings on products to suggest scarcity but operated on a made-to-order procurement model and maintained minimal or no standing inventory. In reality, these scarcity labels were applied randomly for promotional effect. The company also showed discounted prices against higher “original” prices that were never actually offered, creating false impressions of savings.

Template defence rejected

In response to a retailer’s claims that its website design was based on a template purchased from an overseas vendor, CCS stressed that businesses cannot disclaim responsibility for their obligations to consumers regardless of whether they purchased third-party templates or designed the websites themselves.

Enforcement action

All three retailers have provided formal undertakings to CCS, ceased their misleading practices, and committed to avoiding unfair trade practices in the future. Light In The Box has also removed misleading claims from its Singapore-facing and European-facing website and mobile application.

This enforcement action signals Singapore’s commitment to protecting consumers from misleading practices that create false impressions of popularity, scarcity, and urgency. These cases also highlight how misleading practices can spread across borders through off-the-shelf templates and multi-market platforms.

Consumers who encounter unfair trade practices can report them to the Consumers Association of Singapore at 6277 5100 or through their online complaints portal.

Reference materials

The media release is available on the CCS website www.ccs.gov.sg.

For more on “dark patterns”, please also see our earlier article “CCS’ recent enforcement actions signal increased scrutiny of “dark patterns” in online retail”.