Easy Reservations but Complicated Cancellations: Jeju Rental Cars Suspected of "Dark Patterns"

Korea Consumer Agency Investigates 14 Companies
13 Offer Easy Reservations via Mobile Apps
9 Restrict Cancellations and Changes to Phone Calls or Website Only
Suspected Cases of Cancellation-Obstructing Dark Patterns

The Korea Consumer Agency announced on August 8 that, after investigating the reservation and cancellation practices of major rental car companies in the Jeju region, it found suspected cases of "cancellation-obstructing dark patterns," where reservations can be made easily online, but cancellations are only allowed through limited methods such as phone calls. The agency also pointed out that many companies fail to sufficiently inform customers about transaction conditions such as cancellation fees during the reservation process, highlighting the need for improvement.

A parking lot in Jeju bustling with rental cars. Photo by Yonhap News

Dark patterns refer to online interfaces designed to cause consumer confusion or carelessness. When procedures such as cancellation or contract termination are more difficult or complicated than those for purchase or contract signing, these are classified as "cancellation-obstructing dark patterns."

Among the 14 companies surveyed, 13 allowed customers to make reservations directly through their websites or mobile applications (apps) when using their vehicles. However, 9 companies required customers to contact the company directly via phone or website bulletin boards to cancel or modify reservations. The Korea Consumer Agency explained that this design makes the cancellation process relatively more difficult than the reservation process, which may constitute a cancellation-obstructing dark pattern. Article 21-2, Paragraph 1, Subparagraph 4 of the Electronic Commerce Act, revised last year, prohibits restricting cancellations or terminations to methods different from those used for purchase or contract signing.

According to the Electronic Commerce Act, businesses are required to inform consumers of the deadlines and methods for withdrawal of offer or contract termination before concluding a contract. All 14 companies surveyed provided information on refund policies according to the timing of reservation cancellation through the 'inquiry board,' 'rental guide,' or similar menus on their websites or mobile apps. However, 5 of these companies did not sufficiently inform customers about the criteria for cancellation fees during the reservation process. Of these 5, 2 companies provided different information about cancellation fee criteria depending on the menu, such as 'rental terms' versus 'inquiry board,' even within the same website, indicating a need for improvement.

Based on the results of this investigation, the Korea Consumer Agency recommended that rental car operators in Jeju operate cancellation procedures using the same methods as reservations, and clearly display rules related to reservation cancellations on the reservation screens. The agency also advised consumers to check the methods and timeframes for cancellation or modification before making a reservation, and to review all transaction conditions, including rental terms and cancellation fee criteria.