Saya & Associates
India's 2026 e-commerce rule changes: what marketplace founders should prepare before 2027
What changed, and when
A marketplace can change its consumer-facing obligations without changing its products. A new ranking algorithm, a sponsored result or a crossed-out price may be enough.
On 10 September 2026, the Department of Consumer Affairs announced amendments to the Consumer Protection (E-Commerce) Rules, 2020, made under the Consumer Protection Act, 2019. They take effect on 1 January 2027.
These are upcoming changes. Until then, the 2020 Rules and other consumer-protection duties still apply. The summary below follows the government's announcement. Check the notified text before implementation.
| Area | What the amended Rules provide |
|---|---|
| Complaints | Every e-commerce entity gives the complainant a copy of the complaint as recorded by its grievance officer |
| National Consumer Helpline | Every e-commerce entity joins the Helpline's convergence process as a partner |
| Search results | E-commerce entities may not manipulate results in a way that misleads users or reduces relevance to the query |
| Sponsored listings | Identified through clear and prominent disclosures |
| Price reductions | The reduced price and the prior price are both shown; the prior price is the lowest price in the 30 days before the announcement |
| Dark patterns | Compliance with the 2023 Dark Patterns Guidelines, a yearly self-audit and a displayed certificate of compliance |
| Product information | Marketplace entities provide best-before or use-before dates, returns and refunds, warranty, delivery and payment details |
| Consumer information | Marketplace entities need express and affirmative consent for specified uses |
| Bundled fees | Marketplace entities may not collect bundled fees for unrelated services, except for specified loyalty or membership programmes |
| Imported goods | Importer details and country of origin are disclosed |
The scale explains the focus. The National Consumer Helpline received 17,71,622 grievances in 2025, and 5,11,196 of them, about 29 per cent, concerned e-commerce.
Search and sponsored placement: can the buyer tell what is promoted?
Map every way a listing gains prominence: paid placement, seller subscription, platform-owned inventory, margin, delivery speed, ratings and personalisation. Then compare the ranking logic with what the interface tells the buyer.
A label that appears only after a click may not describe the first impression the results page creates.
This is a product and a commercial question. Someone must decide who approves sponsored labels, who tests their display on mobile, and what happens when the ranking model changes.
Discount claims: keep the price history
Where a price reduction is announced, both the reduced price and the prior price must be shown. The prior price is the lowest price at which the goods or services were offered in the 30 days before the announcement.
An example: a product sold at ₹1,499 for 20 of the last 30 days and at ₹1,199 for the other 10 has a prior price of ₹1,199. A sale at ₹999 is shown against ₹1,199, not ₹1,499.
Treat a crossed-out price as a claim backed by a record, not a design element. Test first-time listings, seller-edited prices, flash campaigns, coupons and products sold in several variants.
Decide who holds the price history: the seller, the marketplace or the pricing vendor. If the platform displays the claim, it needs a way to verify the data behind it.
Product pages: make the seller's information usable
Marketplace entities must provide key information such as best-before or use-before dates, returns and refunds, warranty, delivery and payment details. Imported goods must show importer details and country of origin.
Empty fields in a seller portal are not enough. Decide which fields are mandatory for each category, who verifies them, how changes are logged and whether a listing can go live with a required answer missing.
The seller agreement should allocate responsibility for accurate inputs. The buyer-facing page must still display them clearly.
Consent, fees and complaints: trace what happens after the click
Marketplace entities may not use consumer information for specified purposes without express and affirmative consent. For each use, identify the screen where permission is sought and the evidence of the buyer's choice.
Review membership and service charges too. Bundled fees for services unrelated to the platform are barred, subject to an exception for specified loyalty or membership programmes.
The complainant must receive a copy of the complaint as recorded by the grievance officer. Test whether the description, attachments, acknowledgement, owner and final response can be retrieved as one record.
Every e-commerce entity must also join the National Consumer Helpline convergence process, self-audit for dark patterns each year and display a certificate of compliance.
A practical review before 1 January 2027
- Walk a real buyer journey. On desktop and mobile, search, open a sponsored result, apply a discount, view a listing, order and file a complaint.
- Capture every screen. Record what the buyer sees at each step and which team owns the information behind it.
- Audit the ranking logic. List every factor that lifts a listing and check that the sponsored label reflects it.
- Rebuild the price history. Confirm the 30-day lowest price can be calculated and evidenced for every discount.
- Close the listing gaps. Make required fields mandatory by category, including importer and country of origin.
- Test consent and complaints. Check the evidence of affirmative consent and that a recorded copy of each complaint reaches the buyer.
Then compare the screenshots with the seller agreement, pricing controls, privacy notice, grievance process and release plan. Gaps are easier to fix before they repeat across thousands of listings.
Frequently asked questions
When do India's 2026 e-commerce rule amendments apply?
From 1 January 2027, according to the government's announcement of 10 September 2026. Until then the Consumer Protection (E-Commerce) Rules, 2020 continue to apply, along with other consumer-protection duties.
What is the "prior price" for a discount?
The lowest price at which the goods or services were offered during the 30 days before the price reduction is announced. The reduced price and the prior price must both be displayed.
Do sponsored listings need a label?
Yes. The amended Rules require sponsored listings to be identified through clear and prominent disclosures. Check that the label is visible on the results page itself, on mobile as well as desktop.
Is a dark-pattern audit required?
Yes, from 1 January 2027. E-commerce entities must comply with the Guidelines for Prevention and Regulation of Dark Patterns, 2023, undertake a yearly self-audit and prominently display a certificate of compliance.
Do the new duties apply to every e-commerce business or only to marketplaces?
Some apply to every e-commerce entity, such as complaint copies, search-result integrity and joining the Helpline process. Others, such as consent, product information and bundled fees, are stated for marketplace entities.
Check the notified text against your business model.
The takeaway
The 2026 amendments turn several product decisions into legal ones: how results are ranked, how discounts are shown and how complaints are recorded. Reviewing the actual screens now leaves time to fix them before 1 January 2027.
For marketplaces that also sell into Europe, see EU marketplace seller onboarding under the Digital Services Act. To discuss a specific platform, contact Saya & Associates.
This article provides general information as at 24 September 2026. Application depends on the business model, product, transaction and final notified text. It is not legal advice.