CCS’ recent enforcement actions signal increased scrutiny of “dark patterns” in online retail

5 January 2026

On 8 December 2025, the Competition and Consumer Commission of Singapore (“CCS”) issued a press release announcing that it has found that two retailers of consumer electronics and home appliances, Courts and PRISM+, have used website design features that mislead consumers.

This article summarises CCS’ findings.

“Sneak into basket”

CCS found that Courts engaged in unfair trade practices by charging consumers for products that they had not selected. During certain promotional periods, Courts’ website included additional items into online shopping carts without the consumer’s consent. For example, after a consumer selected an Apple iPad for purchase, an Acer vacuum cleaner also appeared in the cart.

The CCS press release explains that this practice puts consumers at risk of unknowingly paying for unsolicited items if they fail to notice and remove such items from their online carts before checking out.

CCS intervened in June 2025 and Courts has given an undertaking to cease this practice immediately. In addition to making changes to its website, Courts also agreed to refund customers affected by this unfair trade practice.

“False urgency”

In a separate matter, CCS reviewed certain website design features on PRISM+’s website that were found to create urgency cues during the online purchasing process that could influence consumer purchasing decisions.

The features identified included the following:

• Countdown timers on checkout pages displaying messages such as “Popular items are selling fast! Purchase within the next [timer] minutes to secure stock and avoid losing out”. The timers were not connected to inventory systems and reset automatically upon reaching zero without affecting the checkout process.
• Stock availability indicators stating “In Stock: Running Low” on product pages, even where inventory levels remained substantial. In one instance, the indicator was displayed although monthly sales accounted for only 7% of total available stock. PRISM+ explained that the indicator was applied to products with inventory levels above 100 units; this threshold was not disclosed on the website.
• Statements suggesting market-wide shortages, including references to supply chain disruptions and industry-wide stock shortages. When queried, PRISM+ was unable to substantiate these statements and indicated that they were made in the context of the Covid-19 pandemic.
• Discount representations such as “Up to 67% off” for certain products, where the stated maximum discount was not achievable based on the strikethrough prices shown. In one example, the actual discount amounted to 38%. PRISM+ attributed these discrepancies to technical errors.

PRISM+ has since rectified the relevant website features and provided an undertaking to CCS that it will not engage in unfair trade practices.

CCS advice to businesses and consumers

CCS also encouraged consumers to remain vigilant when shopping online, including reviewing their shopping carts for unexpected items, verifying that payment amounts match intended purchases, and questioning the authenticity of urgency claims before making impulse purchases.

CCS stated that these two interventions form part of its broader enforcement actions against businesses that employ misleading website design features, known as “dark patterns”, to pressure consumers into unintended purchases.

Scott Clements, Partner of Allen & Gledhill’s Competition & Foreign Investment Review Practice, commenting on the expansion of CCS’ regulatory function over consumer protection on 1 July 2025: “The exercise by CCS of its consumer protection powers in the first six months has been noteworthy but unsurprising. CCS had similarly been purposeful in taking on competition infringements since its inception while concurrently setting out its enforcement philosophy. With those foundations, the Commission has, in the last two decades, built on its track record by taking on increasingly sophisticated and complex antitrust cases.”

Reference materials

The following materials are available on the CCS website www.ccs.gov.sg:

• Press release: CCS takes action against Courts and PRISM+ for misleading website features
• Annex A - Screenshots on Courts’ “sneak into basket” conduct on its website
• Annex B - Screenshots of Courts’ cart-out process after changes were made
• Annex C - Screenshots of the features on PRISM+’s website and the changes made