On 9 September 2026, the Department of Consumer Affairs, Ministry of Consumer Affairs, Food and Public Distribution, notified the Consumer Protection (E-Commerce) (Amendment) Rules, 2026 (2026 Amendment), amending the Consumer Protection (E-Commerce) Rules 2020 (E-Commerce Rules). The 2026 Amendment would take effect on 1 January 2027 leaving about a quarter for the e-commerce entities to ensure their compliance with the amendments.
The E-Commerce Rules were originally notified on 23 July 2020 and established the foundational consumer-facing conduct regime for e-commerce entities in India. Since then, the sector has grown sharply, and consumer grievances have become more complex. The 2026 Amendment addresses three key areas: (i) how products and prices are presented; (ii) what must be disclosed and by whom; and (iii) how consumers are dealt with after the sale.
What has Changed
How Products and Prices Are Presented
1. Price Transparency: The 2026 Amendment requires all e-commerce entities to display the “prior price” when listing a product at a discount. The “prior price” is the lowest price of the goods or services during the preceding 30 days. This aligns with the European Union’s Omnibus Directive 2019/2161 (EU) (EU Directive), which similarly requires disclosure of the lowest price applied during the preceding 30-day period. As a matter of best practice, businesses may also follow the guidance to the EU Directive set out in the European Commission’s Note dated 29 December 2021, which recommends making such disclosures wherever there is an “impression of a price reduction.”1
2. Prohibition on Dark Patterns: The 2026 Amendment requires all e-commerce entities to comply with the Guidelines for Prevention and Regulation of Dark Patterns 2023 (Dark Pattern Guidelines). All entities must conduct a yearly self-audit confirming that their platform is free from dark patterns and prominently display a certificate to that effect.
The Dark Pattern Guidelines define “dark patterns” as any practice or deceptive design pattern using UI/UX (user interface/user experience) to mislead or trick users into doing something they did not originally intend. Such practices subvert user autonomy, decision-making or choice, and may amount to misleading advertisement, unfair trade practice or violation of consumer rights. The Guidelines list 13 specific dark patterns, including false urgency, confirm shaming, forced action, subscription trap and disguised advertisement.
The 2026 Amendment does not specify the audit methodology, scope, reporting format or who is qualified to conduct it. There is also no stated consequence for a certificate that later proves inaccurate.
Until this is clarified, entities should document their audit trail on the assumption that a regulator may ask to see it, particularly given the recent industry crackdowns.
3. Search, Ranking and Sponsored Listings: Previously, the E-Commerce Rules defined “ranking” with a focus only on the prominence and relevance of goods and services. Marketplace e-commerce entities were required to briefly explain their principal ranking parameters. The 2026 Amendment expands this definition to also cover the prominence given to sellers. Marketplace entities must now disclose their ranking parameters clearly and prominently, in descending order of importance. Platforms must also distinguish organic placements from paid or promoted placements, and misleading or manipulative search results are prohibited. Similarly, the EU Platform-to-Business Regulation (EU) 2019/1150 requires online intermediation services to publish a clear, easily accessible, and intelligible description of the principal parameters used to determine rankings. Businesses may choose to adopt a similar approach as a matter of best practice.2
What Must Be Disclosed, and by Whom
4. Disclosure Obligations
i. E-Commerce Entity Disclosures: The 2026 Amendment requires all e-commerce entities to display their legal name, principal geographic address, website details, and contact details for customer care and the grievance officer at an “appropriate” place. If an e-commerce entity imports goods or services, it must also mention the name and details of any importer, along with the full country of origin.
What counts as an “appropriate” place for disclosures is unclear. The Organisation for Economic Co-operation and Development Recommendation on Consumer Protection in E-commerce suggests that online disclosures should be clear, accurate, easily accessible and conspicuous, considering the limitations or special features of the device or platform.3
ii. Product Disclosures: Previously, sellers on marketplace e-commerce platforms were required to provide relevant details for consumers to make informed decisions. The 2026 Amendment expands “relevant information” to include: best before or use before date, return, refund, exchange, warranty and guarantee terms, delivery and shipment information, cost of return shipping, available payment modes, and any other similar information.
The 2026 Amendment references the Legal Metrology (Packaged Commodities) Rules, 2011 for labelling of imported products. Imported packages must display the country of origin, manufacture or assembly. The rules require all e-commerce platforms to display all mandatory declarations applicable to packaged commodities listed on their platforms. From 1 July 2027, all e-commerce entities are required to provide a searchable and sortable country of origin filter for imported product listings. Sellers must also provide the country of origin, best before or use before date, return and refund terms, warranty and guarantee information, delivery details, return shipping cost and available payment modes. Note that the best before and use before date disclosures were already required under the Food Safety and Standards Act, 2006 (FSSA) and hence the rules only require FSSA to be adhered to.
iii. Seller Disclosures: Marketplace e-commerce entities must require sellers to provide their government-issued identification number, such as a Goods and Services Tax identification number or Micro, Small and Medium Enterprises registration number, and prominently display such details, together with the seller’s website and email address, on the platform or website. All e-commerce entities must also clearly and prominently display the seller’s name on invoices, in the same font size as the e-commerce entity’s own name.
After the Sale: Complaints, Consent and Fees
5. Grievance Redressal:
i. National Consumer Helpline (NCH): Under the E-Commerce Rules, all e-commerce entities were required to make their best efforts to converge with the NCH. The 2026 Amendment now makes this mandatory.
To converge, an e-commerce entity must file a Convergence Company Registration Form along with an authorisation letter and a company undertaking letter. Upon registration, the entity must execute a memorandum of understanding with the Department of Consumer Affairs, integrate with the NCH Information Technology system for automated complaint routing, designate a nodal officer to receive complaints and commit to resolving complaints within prescribed timelines.
ii. Complaint Procedure: Previously, the grievance officer was required to acknowledge receipt of any consumer complaint within 48 hours and resolve it within one month. The 2026 Amendment adds a new requirement: when a customer raises a complaint, the grievance officer of the e-commerce entity must provide the customer with a copy of the recorded complaint. This gives customers full visibility over their communications with the platform.
6. Data Use: The 2026 Amendment prohibits marketplace e-commerce entities from using consumer information for common-brand sales without the consumer’s express and affirmative consent or to promote an associated seller. Since e-commerce entities are also “data fiduciaries” under the Digital Personal Data Protection Act 2023 (the DPDPA), such consent must also be free, specific, informed, unconditional and unambiguous. Note that the DPDPA, although already enacted, comes into effect from May 2027.
7. Bundled Fees: Marketplace entities must not collect bundled fees for services unrelated to the e-commerce platform, except for loyalty or membership programmes.
Concluding Remarks
The Central Consumer Protection Authority’s enforcement activity is likely to intensify after 1 January 2027, given its recent track record of penalising platforms and issuing sector-wide advisories on dark patterns, misleading advertisements and non-compliance. Contraventions of the E-Commerce Rules attract the same penalties as those under the Consumer Protection Act, 2019. Entities across the e-commerce value chain should take note of the amendments and seek to comply with the 2026 Amendment in earnest.
Footnotes
1. European Commission. (2021). Commission Notice: Guidance on the interpretation and application of Article 6a of Directive 98/6/EC of the European Parliament and of the Council on consumer protection in the indication of the prices of products offered to consumers (2021/C 526/02). Official Journal of the European Union, C 526, 130-140, 29 December 2021 eur-lex.europa.eu/legal-content/EN/TXT/PDF/?uri=CELEX:52021XC1229(06)
2. Regulation (EU) 2019/1150 of the European Parliament and of the Council of 20 June 2019 on promoting fairness and transparency for business users of online intermediation services [2019] OJ L186/57.
3. OECD (2016), OECD Recommendation of the Council on Consumer Protection in E-Commerce, OECD Publishing, Paris, https://doi.org/10.1787/9789264255258-en.
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