1.

Criteria for Interpreting Dark Pattern Regulations
 

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Clarifying the Regulatory Scope: Limited to cases where the payment amount has increased, while classifying them into two types: (i) when a recurring subscription fee of a good or service is increased, and (ii) when an initial discount period expires and the standard price applies.

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Requiring Valid Consent: A business operator must obtain consumers’ explicit consent; merely obtaining broad consent during the initial contracting stage and through passive user actions, such as closing the consent window, are not considered valid consent.
 

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Defining Terms: The “first screen” refers to the screen within an online mall where consumers first encounter product and price information; the “total amount” is defined as the sum of all costs that a general consumer must necessarily pay to achieve the goal of purchasing.

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Example: For accommodations and travel products, additional costs arising from consumer opt-ins or special conditions are excluded from the total amount.
 

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Clarifying the Regulatory Scope: Prohibits the act of automatically pre-selecting options that lead to the purchase of additional goods or services before the consumer has made a direct choice during the purchase process.
 

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Clarifying the Regulatory Scope (“Prohibition of Visual Manipulation”): Prohibits displaying the purchasing process in a way that makes it appear as though only paid options can be selected; displaying the sign-up process as if consenting to receive advertisements or agreeing to the user of consumer information is mandatory to complete membership registration; (also prohibited is) when a user is trying to cancel or withdraw from a service, displaying only “account deactivation” or “plan change” as the only alternatives.
 

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Clarifying the Regulatory Scope: Prohibited repetitive demands are specified as “two or more change requests.”

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Exception: Does not apply if the “do not show again for seven days” option is provided at the first change request.
 

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Prohibiting Complex Procedures: Prohibits the act of repeatedly confirming consumer intent or requesting reconsideration two or more times (also prohibits multi-step notifications of lost benefits upon cancellation or withdrawal).

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Requiring to Provide the Same Method: Consumers must be able to cancel or withdraw on the same website or application used for the purchase or subscription.
 

2.

Recommendations Related to Online Interfaces
 

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Clear Disclosure of Price Structure: When product prices are not uniform making it difficult to display the total amount on the first screen (exception to the prohibition on sequential pricing), it is recommended to specify the cost details, pricing methods, and amounts in the price display section of the product detail page.

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Transparent Display of Discount Conditions: If discounts vary depending on transaction conditions, it is recommended to show the pre-discount price (i.e., the regular price) on the first screen and specify detailed discount conditions on the product detail page.

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Accurate Display of Representative Product Price: When advertising a representative product on the first screen while multiple products are included on the detail page, it is recommended that the price of the representative product be displayed accordingly.
 

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Explicit Notice of Additional Expenses: When providing optional items for additional expenses or separate service subscriptions, it is recommended that consumers be informed of additional costs that may be incurred depending on their options.

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Provision of Neutral and Objective Options: When seeking consumer consent, a clear indication of the option that allows consumers to express refusal is recommended.
 

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Enhanced Visual Accessibility: The Guidelines recommend making the cancellation and withdrawal buttons easily distinguishable from other texts so that consumers can quickly find such buttons.

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Intuitive Placement: The Guidelines recommend placing cancellation and withdrawal functions in locations that consumers can intuitively predict (e.g., it is ideal to include the membership withdrawal button in the “Account Management” menu and the purchase cancellation button in the “Purchase History” menu).
 

3.

Implications

The KFTC announced that it would collect opinions from stakeholders, relevant government ministries, and local governments until September 18, 2025. After undergoing the procedures such as review by the Ministry of Government Legislation, the KFTC plans to complete the revision of the Amended Guidelines within the second half of the year.

As the KFTC is expected to actively regulate online dark patterns once the Amended Guidelines are implemented, businesses are advised to promptly inspect their online business operations and practices, and use the Guidelines as a reference when designing new interfaces in the future.