From misleading claims by consumer-goods companies to dark patterns on digital platforms, the Central Consumer Protection Authority (CCPA) has widened the areas in which it intervenes to protect consumers.
An analysis of 206 orders and judgements listed by the authority since 2021 shows that its enforcement has moved beyond traditional consumer products and advertisements to cover e-commerce, online travel, education and coaching, healthcare, restaurants, mobility, digital platforms, product safety and other services.
How has enforcement expanded?
The CCPA’s enforcement has widened significantly since 2021, with 206 orders or judgments recorded through 2026. It passed 10 orders in 2021, 20 in 2022, 80 in 2023, 38 in 2024, 19 in 2025 and 39 in 2026, up to 1 September.
Its early orders largely focused on FMCG and consumer goods, including matters involving major companies in the consumer products sector. Over time, enforcement expanded to online travel, e-commerce, education, healthcare, paints, consumer durables, digital payments, mobility, restaurants, beauty and wellness, product safety and direct selling.
Companies named in the orders include major FMCG brands, leading travel aggregators, major e-commerce platforms and others.
How has e-commerce changed consumer protection?
The growth of e-commerce has created a different set of risks for consumers.
In a physical marketplace, a consumer can inspect a product before purchasing it. Online, consumers increasingly depend on product descriptions, ratings, reviews, rankings, advertisements and other information presented by platforms and sellers.
The CCPA has, for instance, taken action involving online platforms over the sale of toys that allegedly did not conform to compulsory BIS standards.
This means consumer protection increasingly extends beyond the physical product to the information and digital interface through which the consumer makes a purchase.
How have dark patterns changed the regulator’s approach
One of the clearest signs of this shift is the CCPA's focus on dark patterns—design practices on digital interfaces that can manipulate or influence consumer choice.
The Department of Consumer Affairs' 2023 guidelines identified 13 types of dark patterns, including false urgency, basket sneaking, confirm shaming, forced action, subscription traps, interface interference, bait and switch, drip pricing and disguised advertisements.
The guidelines were aimed at protecting consumers from deceptive practices in the digital marketplace.
Why are services under scrutiny?
India's consumption economy is increasingly service-driven, and the CCPA's order list reflects that change.
Restaurants, hospitals, IVF providers, airlines, mobility platforms, matchmaking services and education providers all feature among the matters taken up by the authority.
The restaurant cases involving service charges are a good example. This broadens the practical meaning of consumer protection from product quality to the overall transaction between a consumer and a service provider.
What does the expansion mean for consumers?
The evolution of CCPA's enforcement suggests that consumer protection is no longer limited to ensuring that a product is safe or that an advertisement is truthful. It increasingly involves ensuring that consumers receive accurate information, genuine choices, transparent prices, safe products and fair treatment across the transaction.
Who leads the CCPA?
When the CCPA was established, Nidhi Khare, the incumbent secretary of the Department of Consumer Affairs, was the special secretary and chief commissioner of the CCPA, while Anupam Mishra, then joint secretary and now additional decretary, was a commissioner.
Both officers continue to hold the same positions in the CCPA despite their elevation in the bureaucracy.
The CCPA is required to have two commissioners, but it has functioned without the second commissioner for most of the time.
A unique feature of the CCPA’s proceedings is that it conducts hearings virtually and there is no physical interaction during the process. The exchange of documents takes place digitally through email.
Expert’s view
“The widening range of cases shows that consumer protection can no longer be viewed narrowly as a matter of product quality or misleading advertisements. The consumer journey today cuts across digital platforms, e-commerce, travel, education, healthcare and financial transactions," said Vijay Kumar, partner at Fox Mandal, a law firm.
"This makes regulatory scrutiny of how claims are presented, how prices and services are represented, and how consumer choices are influenced increasingly important. The challenge for the regulator will be to ensure that enforcement keeps pace with rapidly evolving business models without creating unnecessary compliance burdens for legitimate businesses,” he added.