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Law Update
Quick note
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Online businesses in India must get ready for a set of new consumer protection rules. The Central Government amended the Consumer Protection (E-Commerce) Rules, 2020 through the Consumer Protection (E-Commerce) (Amendment) Rules, 2026, which would come into effect from 1 January 2027.
The amendment covers a number of elements that feature in a daily online transaction for consumers. These include the procedure for the platformâs identification, complaints handling process, presentation of the imported goods, sponsored resultsâ disclosure, discountsâ indication, invoice seller name format, as well as description of the marketplaceâs ranking mechanism.
There is also a strong digital-design angle. E-commerce entities will have to comply with the Guidelines for Prevention and Regulation of Dark Patterns, 2023, perform a self-audit annually and display a certificate that the platform is dark-pattern-free. Besides, marketplace entities will also be subject to new provisions concerning consumer information and bundled fees.
For businesses, the work is unlikely to stop at revising a legal policy. Search systems, seller onboarding, pricing databases, customer-support workflows, invoice formats, UX design and advertising placements may all need review.
Consumer Protection Act, 2019
The legal foundation comes from the Consumer Protection Act, 2019. The notification refers to the Central Government's powers under section 101 of the Act for making these amendments.
For an online business, the practical point is simple: these are consumer-protection rules. They deal with the information and experience offered to a consumer when goods or services are searched, promoted, bought, invoiced or complained about.
Consumer Protection (E-Commerce) Rules, 2020
The 2020 Rules continue to constitute the central e-commerce consumer-protection framework.
The 2026 amendment modifies certain provisions of those rules: some prior clauses have been substituted with new formulations, and several requirements have been newly inserted.
Accordingly, in the case of substitution, businesses must rely on the new formulation upon its commencement, and in the case of insertion, the amendment creates an additional explicit requirement of compliance with the new formulation.
Other Laws and Guidelines Referred to in the Amendment
The Gazette also links some provisions to existing regulatory requirements. Like:
Businesses should read the cross-references carefully and not assume that the 2026 amendment includes all the requirements on its own.
The first inquiry a business should make is: what role are we playing in the transaction? The response will determine which aspects of the amendment require closer examination.
| Stakeholder | Main Areas to Review |
| E-commerce entities | Entity disclosure, grievance handling, imported goods, NCH participation, sponsored listings, discounts, invoices and dark patterns |
| Marketplace e-commerce entities | Seller information, ranking, consumer-information restrictions and bundled fees |
| Marketplace sellers | Product information, seller data, pricing information and government-issued identification details |
| Inventory e-commerce entities | Consumer-facing information about returns, refunds, product life, warranty, shipping, payments and grievance redressal |
| Imported-goods sellers | Importer details and country-of-origin information |
| MSME sellers | Seller master data, applicable registration information, product disclosure and pricing records |
E-Commerce Entities
A variety of obligations are worded as âevery e-commerce entity.â
These firms must give special attention to:
Marketplace E-Commerce Entities
Marketplace operators are responsible for additional obligations because they facilitate transactions between consumers and third-party sellers.
Their review needs to go beyond ordinary website information. Seller profiles, ranking systems, use of collected consumer information and fee structures are also covered by the amendment.
Sellers on Online Marketplaces
Sellers will require correct information on the business and products, such as:
Inventory E-Commerce Entities
The amendment also revises information requirements for inventory e-commerce entities. Accurate information concerning return, refund, exchange, product-life dates, warranty, delivery, return shipping, payment and grievance redressal remains important.
MSME and Small Online Sellers
Small sellers should not interpret the reference to an MSME registration number as a new mandatory MSME registration requirement.
The amendment makes reference to identification numbers issued by the Central Government, which include GSTIN or MSME registration number. It does not intend to say that every seller shall obtain MSME registration merely because that number is mentioned.
The amendment is broad because it covers various aspects ranging from the discovery of a product to addressing complaints after purchase.
| Compliance Area | What the 2026 Amendment Does | What Businesses Need to Look At |
| Ranking | Replaces the definition of ranking | How products and sellers receive prominence |
| Entity disclosures | Requires specified legal and contact information | Website/app disclosure pages |
| Complaints | Sets acknowledgement and redressal requirements | Complaint-management systems |
| Imported goods | Requires importer and origin details | Product catalogue and seller data |
| NCH | Requires participation in convergence process | Grievance integration |
| Search | Prohibits misleading search manipulation | Search logic and overrides |
| Sponsored listings | Requires clear identification | Paid result presentation |
| Discounts | Requires prior price with reduced price | Pricing history |
| Invoices | Regulates seller-name prominence | Invoice templates |
| Dark patterns | Requires yearly self-audit | UX and product design |
| Seller disclosures | Expands marketplace seller information | Seller onboarding/master data |
| Ranking disclosure | Requires main parameters and relative importance | Public ranking explanation |
| Consumer information | Restricts specified marketplace uses | Data practices |
| Bundled fees | Restricts charges for unrelated services | Checkout and commercial models |
| Government IDs | Adds identification-number disclosure | Seller compliance records |
The changes are far-reaching because many deal with the mechanics of the platform rather than just legal paperwork.
The notification is dated 9 September 2026. The amended rules will become effective from 1 January 2027.
| Event | Date | What It Means |
| Amendment notified | 9 September 2026 | Businesses can begin reviewing the revised requirements |
| Amendment comes into force | 1 January 2027 | New and substituted provisions become operative |
| Separate transition period | Not expressly stated | Businesses should not assume an additional extension |
A policy update can be completed quickly. Building a reliable 30-day price history, changing invoice logic or reviewing search and UX systems can take longer.
Basic business information should be easy for a consumer to find.
The amended rule requires every e-commerce entity to display specified information clearly, accessibly and prominently at an appropriate place on its platform.
Legal Name
The legal name of the e-commerce website should be presented. While a consumer brand might be recognizable to the target market, the parent company cannot be overlooked.
Headquarters and Branch Addresses
The main geographic address of the head office and all branches are included. For companies having multiple offices or places of business, this may involve a new verification of existing legal information pages.
Website Details
The name and details of the website must also be provided. Companies operating several websites, apps or digital brands should make sure the information is consistent with the relevant legal entity.
Customer Care and Grievance Officer Details
The amendment covers contact details such as:
The compliance examination should include a practical review that verifies the presence and up-to-date nature of the contact details to ensure that they are indeed available to the consumers.
Complaint handling is one of the areas in which the amendment provides specific timelines.
Complaint Must Be Acknowledged Within 48 Hours
The grievance officer must acknowledge receipt of a consumer complaint within 48 hours. That makes accurate timestamps important. Businesses handling complaints through email, app tickets, call centres and chat systems should make sure complaints do not disappear between different channels.
Consumer Must Receive a Copy of the Recorded Complaint
A requirement that is easily missed is that the consumer will have to receive a copy of the complaint as recorded by the grievance officer. This will require businesses to ensure that the internal record of the complaint does not significantly deviate from what the consumer originally complained about. A summary that alters the nature of the problem could lead to new issues.
Complaint Must Be Redressed Within One Month
The grievance officer shall resolve the complaint within a month of receipt. In situations where the business has a number of its own teams, there may be a need to escalate the complaint. Some helpful internal controls in this situation may include:
These are some practical controls that the Gazette does not specify beyond suggesting appropriate ticketing systems or software.
Imported products receive separate treatment under the amendment.
Importer Information
Where an e-commerce entity offers imported goods or services for sale, it has to mention the name and details of the importer from whom such goods or services were purchased, or who may be a seller on the platform.
The wording makes accurate importer data important at both the seller-onboarding and listing stages.
Country-of-Origin Information
E-commerce sites should make sure that buyers know whether a product is imported and its exact country of origin as per Legal Metrology (Packaged Commodities) Rules, 2011. As an online marketplace, you can do this by taking the following steps:
Notably, the requirement does not intend to create more compliance responsibilities than what is already there in legal metrology laws.
National Consumer Helpline Integration Requirement
The amendment requires every e-commerce entity to become a partner in the convergence process of the National Consumer Helpline of the Central Government.
This is an express requirement. Where the amendment fails to provide specifics in the text , the technical procedure for onboarding will be required. Businesses should therefore separately confirm procedures, system requirements and administrative steps for National Consumer Helpline convergence.
The grievance team should also understand how complaints received through this route will be mapped into the company's ordinary complaint-handling process.
New Rules Against Manipulation of Search Results
Search is no longer only a product or technology matter. The amendment inserts a provision against misleading users by manipulating search results or search indexes while taking into account the user's search query.
What Does the Rule Actually Restrict?
The wording focuses on misleading users. It does not say that an e-commerce company cannot rank products, personalize results or operate a search algorithm. The concern arises when manipulation of search results or indexes misleads the person searching.
Areas That May Need Review
Technology and compliance teams may need to look at:
Why Documentation Matters
A platform should understand the basis for a product appearing where it does. That doesn't mean the Gazette would demand disclosure of source code or algorithms. But the internal control point is that a business ought to be able to explain material interventions in search results if the practice is challenged.
Consumers should be able to recognize when a listing receives paid or sponsored placement.
The amendment requires sponsored listings of products and services to be distinctly identified with clear and prominent disclosure.
What Should Businesses Avoid?
A sponsored placement should not be made to appear the same as an ordinary result if the consumer is unable to recognize any significant difference.
Where Should Platforms Review Sponsored Content?
Depending on the platform design, relevant areas may include:
These are practical review points. The amendment does not provide an exhaustive list of interface locations.
No Fixed Label or Colour Is Prescribed Here
The notification requires clear and prominent disclosure but does not prescribe one particular label, font, colour or icon in the amendment text.
Businesses should prioritize whether the consumer can distinguish between a sponsored and an unsponsored placement.
The pricing amendment deserves particular attention because it can directly affect sale campaigns.
Where an e-commerce entity or seller announces a price reduction, the prior price must be shown along with the reduced price.
What Is the Prior Price?
The rules define prior price as the lowest price of the goods or services during the 30 days before the announcement of the price reduction.
This is a crucial detail.
Businesses should not simply take a higher historical price and use it to make the current discount appear larger.
What the Rule Does Not Say
It does not say:
The 30-day period is used to determine the relevant prior price when a price reduction is announced.
Impact on Festival Sales and Promotional Campaigns
Frequent sales can create challenges for price compliance. Businesses must keep proper records of their previous pricing and thoroughly analyze every discount campaign, especially when frequent price changes are made in offers, promotions, and seasonal sales.
In addition, the identity of the seller must also be disclosed to buyers. The e-commerce entity shall conspicuously display the sellerâs name in a prominent place in the invoice in the same size as the e-commerce entityâs name.
Why Existing Invoice Templates Need Review
Some platforms may display the seller's name already, but that could receive much less visual prominence. Finance and technology teams should therefore investigate:
The amendment specifies requirements in relation to relative font size. Consequently, businesses should ensure to examine the generated invoice itself, not simply the presence of a field for seller name.
Dark patterns move to the centre of e-commerce compliance under the amendment.
Every e-commerce entity must comply with the Guidelines for Prevention and Regulation of Dark Patterns, 2023, conduct a yearly self-audit to ensure its platform remains free from dark patterns and prominently display a certificate to that effect.
What This Means for E-Commerce Platforms
A dark-pattern issue may arise from the way a choice, button, subscription, offer, cancellation path or other consumer interaction is designed.
This means legal compliance cannot be reviewed only through terms and conditions.
The actual screen experience matters.
Yearly Self-Audit
The amendment clearly requires that an annual review is undertaken. A useful self-audit will normally require input from a number of functions:
legal, compliance, product, UX/UI, technology, marketing, and customer experience.
The notification does not prescribe a detailed self-audit template in the text reviewed.
Display of the Certificate
Once the self-audit is conducted, a certificate to the effect that the platform is free from dark patterns must be displayed prominently.
Businesses should be careful with what they assume here.
The amendment does not, in the text reviewed, create:
a fixed certificate format,
a mandatory government filing portal,
a named external certifying authority, or
an express requirement to appoint a third-party auditor.
Such additional requirements should not be imposed unless separately prescribed through an official source.
Practical Dark Pattern Controls
A business can improve its preparedness through:
periodic UX reviews,
pre-launch review of new consumer flows,
approval records for important design changes,
assessing promotional journeys,
review of subscription and cancellation flows where relevant,
documentation of audit findings, and
tracking of corrective actions.
These are recommended internal controls rather than additional statutory formats.
Marketplace e-commerce entities are expected to provide consumers with enough seller information to make a more informed decision before buying.
The amended provision includes information such as:
Seller Information Before Purchase
The focus at the moment is on transparency. Consumers should be able to get useful information about the vendor before completing the transaction. This might necessitate improved coordination between buyer onboarding and the actual product page for marketplaces.
Seller Information After Purchase
There is an additional requirement following the transaction. Where the consumer makes a written request post-purchase, the marketplace is required to provide certain seller information that will assist in communication and dispute resolution.
This encompasses the principal geographic address of the seller's headquarters and branches, the website, email address, and other available information concerning communication with the seller. Thus, it becomes critical to keep updated seller information even if every detail is not disclosed to the buyer at the pre-purchase stage.
The amendment keeps the focus on information a consumer needs before making a buying decision.
Marketplace-related disclosure covers:
other relevant information needed for an informed decision.
Returns, Refunds and Exchanges
Consumers must be able to comprehend these conditions prior to completing the purchase, rather than encountering them for the first time when something goes wrong.
Marketplaces must ensure that terms provided by sellers are complete and that the marketplace consistently displays them.
Warranty and Guarantee
Where warranty or guarantee terms apply, inaccurate or incomplete information might mislead the consumer. Sellers should, therefore, avoid vague listing data.
Best-Before and Use-Before Information
With regard to food products, the amendment specifically retains this requirement subject to the Food Safety and Standards Act, 2006 and the regulations thereunder.
E-commerce rules and food law requirements should therefore be interpreted together.
Ranking is given a revised definition under the amendment.
It refers to the relative prominence or relevance given to sellers, goods or services on the platform, regardless of the technological means used for presenting, organizing or communicating them.
What Does Ranking Mean in Practice?
For a consumer, ranking is essentially about why one seller or product appears before another.
For a platform, the answer may involve several factors, such as relevance, consumer behaviour, seller metrics or commercial arrangements.
The law does not require businesses to invent an explanation. It requires them to explain the main parameters that actually matter.
Main Parameters Must Be Explained
Marketplace entities shall be required to explain the main parameters that are most significant, alone or in combination, in determining the rank of a good or seller.
Relative Importance Also Matters
The disclosure must go beyond a mere recitation. The amendment speaks of explaining the relative importance of those principal parameters. This is intended to provide a clearer understanding to consumers of what factors substantially affect a particular visibility.
Explanation Must Be Easy to Find and Understand
The description must be:
While practitioners are able to understand the ranking model from within the technical context (i.e., through the use of internally recognized metrics and their associated coding), the explanation that is to be given to consumers must be understood by a non-technical audience.
Businesses should keep these two amendments separate.
Ranking transparency asks:
What factors are important in deciding which products or sellers receive more prominence?
Search manipulation asks:
Has the platform manipulated search results or indexes in a way that misleads the user considering the search query?
A platform can therefore have a ranking system without automatically violating the search-manipulation provision.
The legal concern is how that system operates and what is communicated to the consumer.
Marketplace e-commerce entities also face a new restriction on certain uses of information they collect.
The amendment deals with the use of collected information in connection with the sale of goods carrying a brand or name common with that of the marketplace entity and with the promotion of sellers as being associated with the marketplace.
Common-Brand Goods
Marketplace operators should consider scenarios where consumer information could be utilized in connection with the sale of goods with a brand or name common to the marketplace entity.
This provision should be interpreted based on the precise language of each scenario as well as the business context. This means it should not be taken, or asserted, as a broad rule that marketplaces are never allowed to use consumer information.
Promoting a Seller as Associated With the Marketplace
The amended text also applies to the use of information to promote or advertise a seller as associated with the marketplace entity.
Express and Affirmative Consent
With respect to the relevant use, the provision refers to obtaining express and affirmative consent from consumers whose information would be utilized.
Businesses should analyze the nature of the consent process, rather than focusing only on whether the language used might be considered sufficiently broad or otherwise masked.
This provision falls within the e-commerce consumer-protection rules. As such, it should not be asserted as a stand-alone replacement for India's overall data-protection regime.
Marketplace platforms must also consider the bundling of various charges.
A marketplace e-commerce entity shall not collect any bundled charge from a user for providing services which are unrelated to the e-commerce platform, in accordance with the amendment.
Why Fee Structures Need a Review
Businesses should review whether additional services are being imposed on the otherwise charged platform fee without a clear relationship with the e-commerce service
A review could focus on:
A combined charge is not per se restricted. What matters is whether there is a connection between the extra service and the e-commerce platform.
Loyalty and Membership Programmes
The amendment includes a specific exception for loyalty and membership programs. Benefits, services, offers or incentives provided in relation to such programs are outside the scope of the bundled-fee restriction. Businesses should be mindful of the nature of the program before relying on the exception.
In relation to the purchase of a product, consumers have a right to receive the required information about the product before they place an order. As such, the revised provision incorporates a number of details that sellers are expected to provide via the platform. These include:
Product-Origin Information
So far as possible, country-of-origin information should relate to the actual product offered for sale. Misleading or incorrect information may mislead the consumer and the marketplace.
Return and Refund Terms
The terms of return and refund should be disclosed prior to purchase. A buyer should not be required to place an order before clarifying whether the item can be returned and under what conditions.
Return-Shipping Cost
The amendment explicitly mentions the cost of shipping the item back to the seller. Therefore, it is essential to clarify the matter when applicable since it may affect the buyerâs decision.
Delivery and Shipment
The information contained about delivery and shipment must match the actual offer. Besides, sellers and marketplaces must guarantee that the information given on their websites is updated and not identical copies of the same data.
The amendment also speaks about Identification numbers issued by the Central Government.
It includes the following:
What Businesses Should Not Assume
The above does not imply that:
The requirement to obtain GST or MSME registration continues to depend on the law governing that registration. The e-commerce amendment deals with the relevant identification information to be provided where applicable.
What Marketplaces Should Review
Marketplace operators may need to check:
The aim should be to keep seller records accurate rather than collecting information simply as a formality.
The effect of the amendment will not be the same for every business. Marketplace operators may require changes at the platform level, but individual sellers are likely to see more change in the information they provide marketplaces.
Marketplace E-Commerce Platforms
Operators of marketplaces should consider evaluating a number of systems simultaneously, including:
For large marketplaces, an e-commerce compliance gap assessment may be more productive than a review of each policy. It can help identify where a legal requirement will necessitate a change in technology, seller data, or an internal process.
Online Sellers
Sellers may be required to provide more complete or updated information to the marketplace.
This may include:
MSME Sellers
Smaller sellers may have to do additional bookkeeping, particularly if product, pricing, and registration information is managed manually.
The practical requirement is fairly simple: keep seller and product information organized and updated so that marketplace disclosures do not depend on incomplete or outdated records.
Imported-Goods Sellers
Imported-products sellers need to ensure that information about importers and countries of origin is consistent across product listings and on marketplaces.
Large E-Commerce Businesses
For a major marketplace, the challenge is scale.
While one product listing may be easy to update, a uniform policy throughout the company affecting hundreds of thousands of sellersâ listings and pricing, as well as numerous consumer-facing systems, may require greater resources. Accordingly, automated compliance checks may supplement written policies.
Many of the revised requirements appear directly on the consumer-facing platform. Businesses may therefore find it useful to review the website or app area by area.
| Digital Area | What May Need Review |
| Business information pages | Entity name, address and contact details |
| Search results | Search practices and misleading manipulation |
| Sponsored listings | Clear sponsored disclosure |
| Product pages | Seller, origin, warranty, shipping and return information |
| Discount pages | Prior-price display |
| Seller profiles | Business and registration information |
| Checkout | Bundled fees and service presentation |
| Grievance section | Complaint recording and acknowledgement |
| Invoice | Seller-name prominence |
| User interface | Dark-pattern compliance |
Product Pages
Product pages often have multiple requirements at the same time. Seller information, origin details, returns, warranty, shipping, and other purchase-related information should therefore be reviewed in aggregate rather than in isolation.
Search Results
Search pages require two distinct sets of verification:
Discount Pages
The screen price is only part of the problem; businesses must also ensure that the systems supporting the page are correctly programmed with prior-price information.
Complaint Interfaces
Complaint forms should connect properly with the grievance process. A 48-hour acknowledgement can become difficult if complaints from one channel are not being monitored or recorded properly.
The amendment doesnât specify a cost to implement these changes. Thereâs a difference in the effort required for implementation based on the scale of the platform and the systems it uses.
Technology Changes
Depending on the current capabilities of your platform, there may be technical changes necessary related to:
A platform that makes extensive use of structured data will require fewer modifications versus one where manual processes predominate.
Yearly Dark Pattern Review
The self-audit process will be required to be undertaken every year, as businesses will have to ensure that the UI/UX framework, design elements, and consumer touchpoints are up-to-date and do not contain any dark patterns.
Seller Data
Large seller bases require additional time to update incorrect or outdated information, which might become a critical implementation factor.
Promotional Pricing
In businesses where prices are subject to frequent changes, appropriate documentation is required to indicate the previous price level applicable to a promotional price.
MSME Impact
In smaller companies, fewer staff members are available to support the implementation and compliance efforts. In addition, marketplaces should standardize information-related requests on the seller side and reduce the burden of redundant requirements.
The amendment contains enhanced consumer protection provisions, but implementation of the provisions will entail challenges for businesses.
| Consumer Benefit | Possible Business Effort |
| More transparent discounts | Price-history systems may need changes |
| Clearer sponsored listings | Advertising interfaces need review |
| Better seller information | Seller records must stay updated |
| Stronger grievance handling | Complaint processes need closer tracking |
| Dark-pattern oversight | Yearly self-audit creates recurring work |
| Ranking transparency | Technical information must be explained simply |
| Clearer invoices | Billing formats may need changes |
Consumer Perspective
Most consumers make purchasing decisions on the platform quickly and without spending much time on the process. What they see affects their decisions: the availability of the product, its price (especially when it is presented as a discount), the seller, and whether the ad is promoted. The provisions in the amendment focus on the consumerâs perspective of shopping online, which reflects their concerns rather well.
Business Perspective
Implementation of the new rules will create challenges for businesses, although it is unclear if the language of the provisions themselves contains any complexity. Some changes may require updates to the sellerâs software, changes to the data collected by the company, the introduction of new controls, and collaboration with several departments within the company.
Impact on Smaller Businesses
MSMEs may find some of the more administrative aspects of the change to be more taxing, given their smaller team sizes. At the same time, several responsibilities at the platform level remain with the e-commerce or marketplace entity.
Balanced View
Apart from providing more information to consumers, the amendment also imposes more responsibility on platforms to present it correctly.
For businesses, analysis at an early stage can help to determine which changes require technical implementation and which could be accommodated through record-keeping or other means.
The amendment does not specify a separate fine for each newly inserted requirement. Therefore, businesses should not quote penalties that are not included in the notification.
Regulatory Risk
Failure to follow an applicable requirement may create issues under the broader consumer-protection framework. The exact consequence will depend on the provision and the facts involved.
Consumer Complaint Risk
The provision of incorrect discounts, the absence of relevant seller data, or ineffective methods of addressing consumer grievances may result in consumer complaints and disputes.
Operational Risk
Businesses should watch for issues such as:
Reputational Risk
Such regulations concern information that the consumer may see. A conspicuous pricing discrepancy, advertisement issue, or complaint may affect consumer confidence before any regulatory agency intervenes.
| Compliance Area | What to Check | Nature | Suggested Team |
| Entity details | Legal name and addresses | Mandatory | Legal |
| Contact information | Customer care and grievance details | Mandatory | Compliance |
| Complaints | 48-hour acknowledgement | Mandatory | Customer Support |
| Complaint record | Copy provided to complainant | Mandatory | Grievance Team |
| Resolution | One-month redressal | Mandatory | Grievance Team |
| Imported goods | Importer details | Where applicable | Seller Team |
| Country of origin | Correct display | Where applicable | Catalogue Team |
| National Consumer Helpline | Convergence participation | Mandatory | Compliance |
| Search | Check misleading manipulation risk | Supporting control | Product/Technology |
| Sponsored listings | Clear disclosure | Mandatory | Marketing/Product |
| Discounts | Correct 30-day prior price | When reduction is announced | Pricing/Technology |
| Invoice | Seller-name font size | Mandatory | Finance |
| Dark patterns | Yearly self-audit | Mandatory | Compliance/UX |
| Certificate | Prominent display | Mandatory | Product/Compliance |
| Seller information | Required seller details | Mandatory | Seller Management |
| Ranking | Plain-language explanation | Mandatory | Product/Compliance |
| Consumer information | Review restricted uses | Marketplace requirement | Legal |
| Bundled fees | Review unrelated charges | Marketplace requirement | Finance/Product |
| Product information | Return, warranty and shipping details | Where applicable | Seller/Product |
| Government IDs | Applicable GSTIN/MSME details | Where applicable | Seller Management |
The proposed internal team is a useful recommendation; however, the amendment does not specify how exactly the duties should be distributed among the companyâs employees.
Step 1: Check the Business Model
First, determine the type of business, for instance, whether it is a marketplace e-commerce entity, inventory e-commerce entity, marketplace seller, or other business covered by the regulations. This prevents businesses from applying every provision in the same way.
Step 2: Prepare a Compliance Gap List
Compare the amended provisions with the current rules used by the platforms and indicate whether each requirement is met.
Step 3: Start With Changes That Need Technology Support
Items such as price history, sponsored listings, search systems, invoice formats, and complaint-management functions may need more preparation time.
Step 4: Check Seller and Product Information
Verify that the information required by the amended provisions is included in the onboarding records of sellers and the product records.
Older seller accounts should be reviewed for missing information.
Step 5: Prepare for Dark Pattern Self-Audit
Review the primary consumer journeys and determine how the annual self-audit will be handled and recorded.
Step 6: Test Grievance Handling
Make sure the current process can support:
Step 7: Review Pricing and Promotions
Teams responsible for giving away discounts should understand the previous pricing rule before announcing lower prices.
Step 8: Review Ranking and Search Separately
Ranking disclosure must describe the most relevant parameters used to influence prominence. The search review must raise the possibility that manipulation may mislead customers.
Step 9: Complete a Final Readiness Review
Before 1 January 2027, businesses should ensure the necessary legal, technical and operational changes have been made.
These are preparatory steps rather than a government-prescribed compliance process.
There are several simple control points that can make compliance management easier to implement and monitor.
Single Compliance Repository
Ensure that requirements are centralized and standardized across teams.
Responsibility Distribution
Designate particular compliance-related responsibilities for prices, complaints, invoices, sellersâ personal information, and other details.
Approving the Systemâs Important Updates
Scrutinize website or application updates before their release if they can impact consumer operations.
Maintenance of Applicable Records
Always update the selling price and other personal information about the seller to disclose relevant information.
Walkthrough of Complaints Mechanism
Check the complaint mechanism from time to time to make sure that all consumer complaints have been documented and acknowledged accordingly.
The 2026 amendment highlights the fact that the e-commerce compliance landscape goes beyond the mere terms and conditions that can be found on a companyâs website. The new requirements touch actual platform functions such as:
For businesses that operate online, this means that compliance must be taken into account when designing a particular feature or practice, and not when a certain tool is already in use. Any future amendment, deadline, or enforcement measure should, however, be assessed only when it is officially announced.
Navigating the ever-evolving regulatory landscape requires a deep understanding of the intricacies of the law, as well as the technical and procedural nuances of the industry. Corpseed helps e-commerce marketplaces and merchants with relevant compliance:
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