Introduction

On September 9, 2026, the Ministry of Consumer Affairs, Food and Public Distribution (Department of Consumer Affairs) notified the Consumer Protection (E-Commerce) (Amendment) Rules, 2026 (“Amendment Rules”), amending the Consumer Protection (E-Commerce) Rules, 2020 (“E-Commerce Rules”). The Amendment Rules will come into force on January 1, 2027.

In India, e-commerce entities are primarily of two types: (a) marketplace e-commerce entity; and (b) inventory e-commerce entity.

Marketplace e-commerce entities provide a technology platform and facilitate transactions between buyers and sellers.

Inventory e-commerce entities own the inventory of goods or services and sell such goods or services directly to consumers.

Under the E-Commerce Rules, “e-commerce entity” is the overarching term that encompasses both “marketplace e-commerce entities” and “inventory e-commerce entities” but does not include a seller offering goods/service on a marketplace platform operated by a marketplace e-commerce entity.

The Amendment Rules introduce several significant changes, relating to:

• duties of e-commerce entities,

• liabilities of marketplace e-commerce entities,

• duties of sellers operating on marketplaces, and

• duties and liabilities of inventory e-commerce entities.

This update sets out the key amendments and their practical implications for the respective stakeholders in the e-commerce ecosystem.

Key highlights

Changes to duties of e-commerce entities

• Copy of Complaint from Grievance Officer: Under Rule 4(5) of the E-Commerce Rules, the grievance officer was required to acknowledge consumer complaints within forty-eight hours and redress them within one month.

The Amendment Rules add a new incremental obligation to this mechanism. The grievance officer now needs to provide the complainant with a copy of the complaint as recorded by the grievance officer.

• Imported Goods Disclosure: Under Rule 4(6) of the E-Commerce Rules, an e-commerce entity offering imported goods was required only to mention the name and details of the importer.

The Amendment Rules now additionally require the entity to provide for identification of goods and mention the full and complete name of the country of origin of such goods imported into India, as provided under the Legal Metrology (Packaged Commodities) Rules, 2011.

• Mandatory Integration with the National Consumer Helpline: Under Rule 4(7) of the E-Commerce Rules, every e-commerce entity was required to “endeavour on a best effort basis” to become a partner in the convergence process of the National Consumer Helpline (“NCH”).

The Amendment Rules substitute this provision to make NCH integration mandatory and provide that every e-commerce entity “shall become a partner” in the NCH convergence process.

• Prohibition on Search Result Manipulation: The Amendment Rules insert a new clause (c) under Rule 4(11), prohibiting e-commerce entities from misleading users by manipulating search results or search indexes having regard to the search query of the user. This creates a distinct regulatory head for enforcement against manipulative search practices.

• Mandatory Disclosure of Sponsored Listings: The Amendment Rules insert a new Rule 4(12), requiring every e-commerce entity to ensure that sponsored listings of products and services are distinctly identified with clear and prominent disclosures. This aligns with international best practices on advertising transparency.

• Price Reduction Transparency – The 30-Day Look-Back Rule: The Amendment Rules insert a new Rule 4(13), requiring that where an e-commerce entity or a seller announces a price reduction for any goods or services on its platform, it shall indicate the prior price of such goods or services along with the reduced price. For this Rule, “prior price” is defined as the lowest price of a good or service thirty days prior to the announcement of the price reduction.

• Seller Name on Invoices: As per the new Rule 4(14), every e-commerce entity is required to display clearly and prominently in its invoice the name of the seller in the same font size as that of the e-commerce entity’s name.

• Dark Patterns Audit: The CCPA’s advisory dated June 5, 2025, had encouraged e-commerce platforms to conduct self-audits for dark patterns and furnish self-declarations.

The Amendment Rules convert such advisory framework into a mandatory compliance obligation under the amended E-Commerce Rules. As per Rule 4(15), e-commerce entities are now required to conduct yearly self-audits to ensure their platforms are free from dark patterns and to prominently display a certificate to this effect.

Changes to liabilities of marketplace e-commerce entities

• Expanded Definition of “Ranking” and Order of Display: Under the E-Commerce Rules, “ranking” was defined under Rule 3(1)(j) as the relative prominence or relevance given to the goods or services offered through a marketplace e-commerce entity.

The Amendment Rules substitute this definition to also include the relative prominence or relevance given to the “sellers on the platform.” Further, in a connected amendment, Rule 5(3)(f) has been amended to strengthen the ranking-transparency requirement by requiring that the main parameters determining ranking for goods or sellers, be listed in “descending order” of significance.

• Display of Seller Information: Rule 5(3)(a) of the E-Commerce Rules requires marketplace e-commerce entities to display specified seller information in a clear and accessible manner, including the seller’s name and geographical address. The Amendment Rules expand these disclosure requirements to include, where available, the seller’s website details and email address.

• Restrictions on Data Use and Self-Preferencing: Earlier, the E-Commerce Rules did not contain any specific restriction on how marketplace entities use consumer data collected through their platforms.

The Amendment Rules insert a new sub-Rule 5(6), prohibiting any marketplace e-commerce entity from using information collected by it for:

(a) sale of goods, directly or indirectly by any seller (whether related or not), bearing a brand or name common with that of the marketplace e-commerce entity; or

(b) promoting or advertising any seller as being associated with the marketplace e-commerce entity unless the marketplace entity has obtained the express and affirmative consent for such use from the consumer(s) to whom such information pertains.

• Prohibition on Bundled Fees: The E-Commerce Rules did not regulate the charging of fees for services unrelated to the e-commerce platform.

The Amendment Rules insert a new sub-Rule 5(7), prohibiting any marketplace e-commerce entity from collecting bundled fees from users for services provided on the e-commerce platform for any other services that are unrelated to the e-commerce platform. A proviso carves out loyalty or membership programmes, and any benefit, service, offer, or incentive provided in connection with or pursuant to such programmes, from the scope of this prohibition.

Changes to duties of sellers on marketplace

• Expanded Seller Disclosure Obligations: Under Rule 6(5)(d) of the E-Commerce Rules, sellers were required to provide “all relevant details” about goods and services, including country of origin.

The Amendment Rules substitute this clause with an expanded, enumerated list of the mandatory disclosures by the sellers to e-commerce entities, including the following disclosures:

(a) country of origin;
(b) best before or use before date;
(c) information related to return, refund, exchange, warranty and guarantee, delivery and shipment, cost and return shipping, mode of payment; and
(d) any other information necessary for informed consumer decisions.

• Mandatory Government Identification Numbers: The E-Commerce Rules, under Rule 6(4)(d), required sellers to provide their Goods and Services Tax Identification Number (“GSTIN”) and Permanent Account Number (“PAN”) details where applicable.

A new clause (j) is inserted under Rule 6(5), requiring sellers to provide any identification number issued by the Central Government, including GSTIN or Micro, Small and Medium Enterprises registration number for being displayed by the e-commerce marketplace entity on its platform or website.

Changes to duties and liabilities of inventory e-commerce entities

• Expanded Inventory Entity Disclosure: Under Rule 7(1)(a) of the E-Commerce Rules, inventory e-commerce entities were required to provide accurate information related to return, refund, exchange, warranty and guarantee, delivery and shipment, cost of return shipping, mode of payments, and grievance redressal mechanism.

The Amendment Rules add “best before or use before date” to this list, with the food-product proviso.

Way Forward

E-commerce stakeholders should review their platform practices, disclosure frameworks, grievance mechanisms, advertising policies, and data-use practices ahead of the Amendment Rules taking effect on January 1, 2027. The changes cover pricing transparency, sponsored listings, search manipulation, dark patterns, and data usage, potentially requiring updates to both consumer-facing practices and internal controls. Given the breadth of these requirements, early compliance planning will be important to identify gaps and implement necessary changes before the effective date.