Dark Patterns and the EU Digital Services Act: Mapping Autonomy Violations and Design Factors

Abstract

Dark patterns are design practices that undermine users' ability to make autonomous and informed choices in digital experiences. The EU Digital Services Act (DSA) seeks to protect users from such designs and their effects, with Article 25 prohibiting three autonomy violation types: deception, manipulation and distortion/impairment. Demonstrating such regulatory violations, however, requires design-oriented reasoning necessary to articulate why an observed design practice constitutes a specific autonomy violation type. This paper maps 59 known dark patterns onto the three autonomy violation types from the DSA and identifies eight new design factors which can help determine when a dark pattern violates autonomy. Our mapping of dark patterns to autonomy violations grounds ongoing regulatory debates in design while opening pathways for translational research that reimagines how HCI engages with the governance of design practices.