By Kirti Jain

We open an app for five minutes and find that an hour has passed. Infinite scroll removes the natural end of a page. Autoplay starts the next video before we decide to watch it. Personalised feeds learn what captures our attention and keep serving the next piece of content. These features make scrolling effortless, while stopping requires a conscious choice.

On September 16, 2026, the Delhi High Court asked the Centre whether it was considering a policy to address ‘addiction-causing’ features on social media platforms. The question deserves a clear answer: India should require platforms to assess the behavioural risks of their design, introduce standardised safeguards by default and undergo independent scrutiny.

How platform design keeps users engaged

Many digital platforms operate within the attention economy. Higher engagement gives platforms more opportunities to show advertisements, learn about user preferences and retain users. It also makes them more valuable to advertisers. As a result, metrics such as daily active users, monthly active users and time spent on platforms matter commercially.

These features are not necessarily harmful. Personalisation can help users find relevant information. Autoplay can improve convenience. Notifications can keep users connected. Concerns arise when platforms combine these features primarily to increase the amount of time users spend on their services.

Engagement-driven design aims to build habits that turn occasional users into daily users. This does not mean platforms deliberately intend to harm users. However, users and their families often bear the costs of excessive use, including poor sleep, lost study time, reduced productivity and potential mental health effects.

Meta’s own internal research, cited in an unsealed complaint filed by US states, also raises these concerns. A June 2018 presentation titled ‘Facebook “Addiction”’ recognised that feed consumption and continuous scrolling could make it ‘difficult to limit one’s use’. It also proposed reducing notifications to curb problematic use.

These findings raise an important question: what should platforms do when their own research identifies risks in their design?

How platform design affects user behaviour

Studies have examined how specific design features affect users’ ability to control their engagement.

A 2023 field study by Rixen and colleagues examined how infinite scroll can keep users in “scrolling loops”, extending sessions beyond what they intended. The researchers found that users often stopped scrolling because of external interruptions rather than because they were satisfied with the content.

A 2025 study published in Acta Psychologica found that habitual and unintentional scrolling, described as “scroll immersion”, was associated with self-reported attention difficulties, working-memory disruption and cognitive fatigue.

A 2025 US study on Netflix’s autoplay feature found that disabling autoplay significantly reduced average daily viewing time and session length. This suggests that autoplay can influence how long users consume content without actively deciding to watch another video.

A 2026 systematic review of 23 studies also reported associations between problematic short-form video use and difficulties with attention, self-control and working memory among adolescents and young adults.

Notifications create another problem. A 2015 study by Cary Stothart, Ainsley Mitchum and Courtney Yehnert found that receiving a mobile phone notification disrupted performance on an attention-demanding task, even when participants did not interact with their phones.

Push alerts, red badges and likes can draw users’ attention away from what they are doing. A 2026 experimental study by Fournier and colleagues found that social media notifications temporarily interrupted cognitive processing for about seven seconds. The extent of the disruption depended on the relevance of the notification and how frequently users checked their smartphones.

These findings suggest that platform design can influence how long users stay engaged, how often they return and how easily they stop using a service.

Screen time alone cannot capture these effects. Independent platform audits should therefore examine not just how much people use a service, but also how its design influences their decisions to continue, return or stop.

What India’s existing laws do not cover

India’s Economic Survey 2025-26 recognises digital addiction among adults and young people. It recommends age-appropriate defaults while acknowledging the lack of comprehensive national data on its prevalence and mental health effects.

India already regulates several aspects of digital platforms. However, existing laws do not establish a general requirement for platforms to assess the behavioural risks of engagement-driven design.

The Central Consumer Protection Authority’s (CCPA) Dark Patterns Guidelines address deceptive design practices. However, features such as infinite scroll and algorithmic recommendations are not inherently deceptive. The guidelines do not create a general obligation to assess their behavioural risks.

Section 9 of the Digital Personal Data Protection (DPDP) Act, 2023, prohibits processing children’s personal data in ways likely to harm their well-being. It also restricts tracking, behavioural monitoring and targeted advertising directed at children. Section 10 requires Significant Data Fiduciaries to conduct periodic data protection impact assessments and audits.

These provisions are scheduled to come into effect in May 2027. However, they focus on compliance with data protection requirements rather than the broader behavioural effects of platform design.

For example, a platform could comply with restrictions on targeted advertising while continuing to offer an infinite, engagement-driven feed. Data protection compliance alone would not necessarily address the behavioural risks of such a feature.

India has gone further in online gaming. The Promotion and Regulation of Online Gaming Act, 2025, and the Rules notified in 2026 recognise psychological and behavioural risks and provide for user-safety features.

However, India does not have a general regulatory framework requiring social media platforms to assess and address the behavioural risks of engagement-driven design.

How other countries are regulating platform design

Different countries have adopted different approaches to platform accountability.

The EU’s Digital Services Act requires very large platforms to assess and reduce systemic risks and undergo annual independent audits.

The US agreement with Meta offers another example of how design-related obligations can be enforced.

Approved in August 2026, the multistate settlement provides for default daily limits on covered teen use, overnight restrictions, notification controls and feed choices on Facebook and Instagram.

It also requires an independent auditor to examine compliance and report to state authorities over five annual reporting periods.

These requirements apply to the specific settlement and do not create a general US audit requirement for all platforms. Meta denies wrongdoing under the agreement.

Meta has argued that teenagers may move to other apps unless competing platforms adopt similar safeguards. This concern deserves attention. Regulators should examine whether such measures actually reduce unwanted use or simply push users towards other services.

Australia has taken a different approach. On October 15, 2026, it introduced legislation to establish a Digital Duty of Care.

Its proposed “My Feed, My Way” initiative would allow users to choose between algorithm-recommended content and a feed showing posts from accounts they follow. The framework remains proposed legislation, with consultation on the accompanying instrument.

Australia also introduced a separate minimum-age regime for social media in December 2025, restricting accounts for children under 16.

This is a more restrictive approach that raises questions about privacy, access and whether young users might move to other services.

My Proposal: A Platform Audit Committee

Drawing inspiration from the EU’s Digital Services Act and the recent US Meta settlement, and in addition to it, since the government of India has already recognised digital addiction as a public-health concern, Ministry of Electronics and Information Technology (MeitY) should propose an amendment to the Information Technology Act, 2000 and Rules made thereunder explicitly addressing the behavioural risks of engagement-maximising platform design. 

The amendment should establish clear definitions and regulatory obligations concerning digital addiction and related behavioural harms. The legislation should also be future-proof with an adaptable framework capable of addressing emerging platform features and evolving behavioural risks without stifling innovation.

The amendment should provide for an independent statutory Platform Architecture Audit Committee with expertise in behavioural science, mental health, algorithmic auditing, and technology and consumer protection, empowering it to conduct behavioural-risk audits, obtain relevant platform information, issue corrective directions and impose proportionate penalties for non-compliance. Its members should be appointed through a transparent and independent selection process, with safeguards against political interference.

The committee should not function as another content moderation authority. Instead, it should assess whether engagement-driven design creates unreasonable behavioural risks, obtain relevant platform information and issue corrective directions and whether platforms take adequate steps to mitigate those risks.

Mandatory Annual independent audits should apply to  Significant Social Media Intermediaries (more than 50 lakh registered users in India). However, user numbers alone should not determine regulatory scrutiny. Smaller platforms could also be selected for risk-based assessments based on their reliance on personalised recommendation systems, engagement-driven business models, exposure of children to potentially harmful design features and evidence of behavioural risks. Where significant risks are identified, independent audits could be required. Auditors should also test whether safeguards actually reduce unintended engagement and interruptions and preserve useful engagement.

Reviews should be annual, and further checks should be made after major changes to engagement features. Auditors should examine design choices and outcomes across age groups. Platforms should not choose or control their reviewers. If a platform fails an audit, the regulator should issue a time-bound compliance notice allowing the platform to adjust its architecture. Continued failure to comply should be penalised proportionate to the platform’s scale, the seriousness and duration of the violation, and repeated non-compliance.

The risks of regulating platform design

Regulating platform design also comes with challenges. Poorly designed rules could restrict useful features, create new privacy risks or impose compliance costs that smaller platforms cannot afford.

Regulators should avoid blanket bans on specific features. Instead, they should consider how a feature works, why it exists and how it affects users.

For example, an earthquake warning serves a clear public interest. Repeated, irrelevant notifications sent at night to encourage users to open an app raise different concerns.

Audits should examine whether users can easily disable such features, whether they encourage unintended engagement and whether they remove natural stopping points.

Age verification also raises privacy concerns. In many cases, platforms only need to know whether users fall within a particular age group rather than collecting their exact date of birth or identity documents.

The European Commission’s age-verification blueprint uses privacy-preserving technologies, including zero-knowledge proofs, to help establish whether users meet an age threshold without revealing their identity to the platform.

In India, the DPDP Rules, 2025 recognise virtual tokens and Digital Locker service providers in the framework for verifying parental identity and age.

However, age verification alone is not enough, particularly because children may use their parents’ devices.

India should therefore require standardised design defaults for all users. These could include quiet hours, autoplay switched off by default and clear stopping cues. Users should be able to change these settings, preserving individual choice.

For minors, platforms could introduce additional safeguards, such as short explanations and confirmation prompts before users disable protective settings. These measures could encourage more conscious decisions.

The proposed committee should also consider the different capacities of large and small platforms.

A tiered system would be more appropriate. Large platforms with substantial user bases, extensive recommendation systems or significant exposure to children could face mandatory independent audits and detailed risk assessments.

Smaller platforms could initially face simpler assessments, basic transparency requirements and longer compliance timelines.

The EU’s Digital Services Act offers a precedent. It exempts micro and small platforms from certain obligations while imposing additional systemic-risk requirements on very large platforms.

Digital platforms have brought enormous benefits to society. Regulation should not restrict their usefulness or innovation.

However, when platforms design the digital environments in which millions of people make everyday choices, they must also take responsibility for the behavioural risks those designs create.

Families, schools and users have a role in promoting digital well-being, but individual self-control cannot replace platform accountability.

India needs a framework that makes large platforms assess and address these risks while preserving user choice, privacy and innovation.

About the author: Kirti Jain is an Academic Associate in the Information Systems area at IIM Ahmedabad. She is pursuing a Graduate Certificate in Public Policy at the Takshashila Institution, specialising in technology and policy.

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