The Digital Fairness Act will regulate dark patterns, addictive design, influencer marketing, and personalisation across all digital products targeting EU consumers. A comprehensive audit now saves costly redesigns later.
The DFA goes far beyond dark patterns. It's the EU's comprehensive answer to manipulative digital practices — and it applies to every business serving EU consumers.
Manipulative UI design: misleading buttons, hidden costs, forced consent, confusing cancellation flows, pre-ticked boxes, and visual misdirection. The DFA will establish a black list of banned practices.
Infinite scroll, autoplay, notification bombardment, reward loops, loot boxes, and engagement mechanics designed to maximise time spent. Especially regulated for minors under 18.
Undisclosed sponsored content, fake reviews, misleading endorsements, and commercial messaging disguised as personal recommendations. Transparency requirements will be mandatory.
Exploiting consumer vulnerabilities through targeted pricing, behavioural profiling, and personalised manipulation. Dynamic pricing practices will face strict transparency obligations.
Unlike the DSA which focuses on platforms, the DFA applies broadly to all B2C digital services. If you serve EU consumers digitally, you're in scope.
Checkout flows, pricing displays, subscription management, cancellation processes, and product recommendation algorithms.
In-app purchases, loot boxes, virtual currencies, engagement mechanics, and monetisation strategies — especially where minors are users.
Sign-up vs cancellation asymmetry, drip pricing, auto-renewal practices, and personalised financial product offers.
Onboarding dark patterns, notification strategies, data collection consent, freemium-to-premium conversion tactics, and usage tracking.
Companies that prepare before the DFA proposal have a 12-18 month head start on competitors scrambling after enforcement.
We assess your entire digital consumer journey against anticipated DFA requirements, existing EU consumer law, and industry best practices.
We map every consumer touchpoint: sign-up flows, consent mechanisms, pricing displays, cancellation processes, notification systems, and personalisation logic. Each element is catalogued against the DFA's four regulatory pillars.
Each practice is scored against the anticipated DFA framework, existing UCPD/CRD/UCTD requirements, and DSA Article 25. We identify high-risk elements that need immediate attention and classify them by severity and remediation effort.
You receive a prioritised action plan: quick wins for immediate compliance gaps, medium-term design improvements, and strategic recommendations for building fairness-by-design into your product development lifecycle.
Our audit methodology is based on official EU legislative documents, not media summaries.
The foundational evidence base identifying gaps in current EU consumer law for digital practices.
Read the Fitness Check →Official Parliament tracking of the DFA legislative initiative and its progress through institutions.
Track the DFA →Parliament's December 2023 resolution calling for legislation against addictive design and regulatory gap closure.
Read the Resolution →Von der Leyen's mandate to Commissioner McGrath to develop the Digital Fairness Act.
View Commissioner Mandate →Tell us about your digital product and we'll scope a tailored audit. Response within 24 hours.