On September 9, 2026, the Ministry of Consumer Affairs, Food and Public Distribution, Department of Consumer Affairs (“Department”) notified the Consumer Protection (E-Commerce) (Amendment) Rules, 2026 (“2026 Amendment Rules”), further amending the Consumer Protection (E-Commerce) Rules, 2020 (“E-Commerce Rules”), issued under the Consumer Protection Act, 2019 (“CP Act”). The 2026 Amendment Rules will come into force from January 1, 2027.

The E-Commerce Rules were originally notified on July 23, 2020, to establish a dedicated consumer-protection framework for online commerce. Since then, the rapid expansion of the Indian e- commerce ecosystem has given rise to a fresh set of consumer harms which the E-Commerce Rules were not equipped to address, including: the proliferation of ‘dark patterns’, non-transparent discount practices, opaque ranking and search algorithms, indistinct sponsored listings, self-preferencing by marketplace entities in favour of their own private-label brands, misleading country of-origin disclosures, and inadequate grievance redressal timelines. The 2026 Amendment Rules seek to address these concerns by strengthening disclosure and transparency requirements across the consumer journey and introducing additional safeguards against practices which may influence or mislead consumers.

The 2026 Amendment Rules accordingly introduce a number of substantive changes to the existing framework, including enhanced obligations relating to ranking and search results, price reduction claims, sponsored listings, seller identification and disclosures, dark patterns, use of consumer information, bundled fees and pre-purchase information requirements. The key amendments have been detailed below:

Key Amendments:

1. Expansion of the definition of “Ranking”:

Rule 3(1)(j) of the E-Commerce Rules has been substituted to expand the definition of “ranking”. Under the earlier definition, ranking referred to the relative prominence given to goods or services offered through a marketplace e-commerce entity. The revised definition now expressly covers the relative prominence or relevance given not only to goods or services, but also to sellers on the platform, irrespective of the technological means used for presenting, organising or communicating such sellers, goods or services.

This revision assumes significance when read together with the amended Rule 5(3)(f), which requires marketplace e-commerce entities to explain the parameters which are most significant in determining the ranking of goods or sellers, in descending order, together with the relative importance of such parameters. Accordingly, the transparency requirement is no longer confined to product-level ranking and extends to the manner in which sellers themselves are prioritised or made more visible on a marketplace.

2. Enhanced General Obligations of E-Commerce Entities:

Rule 4 of the E-Commerce Rules, which prescribes the general duties applicable to e-commerce entities, has been amended in several respects. The principal changes include the following:

I. Entity and contact disclosures: Rule 4(2) has been revised to require every e-commerce entity to provide, in a clear and accessible manner and at an appropriate and prominent place on its platform, its legal name, the principal geographic address of its headquarters and all branches, the name and details of its website, and the e-mail address, landline and mobile numbers of customer care as well as of the grievance officer.

II. Grievance redressal: Rule 4(5) now requires the grievance officer to acknowledge a consumer complaint within 48 (forty-eight) hours and redress it within 1 (one) month continues, and to provide the complainant with a copy of the complaint as recorded by the grievance officer. This is intended to create a clearer record of the grievance received and reduce ambiguity as to the scope of the complaint being processed.

III. Imported goods and services: Rule 4(6) now requires disclosure of the importer from whom imported goods or services have been purchased, or who may be a seller on the platform. In addition, the amended provision expressly requires identification of imported goods and disclosure of the full and complete name of their country of origin, in accordance with the Legal Metrology (Packaged Commodities) Rules, 2011.

IV. National Consumer Helpline: Rule 4(7), which earlier required e-commerce entities to endeavour, on a best-effort basis, to become partners in the convergence process of the National Consumer Helpline (“NCH”), has been strengthened. Every e-commerce entity will now be mandatorily required to become a partner in the NCH convergence process.

3. Regulation of Search Results and Sponsored Listings:

The 2026 Amendment Rules introduce specific safeguards in relation to how products, services and sellers are surfaced to users on an e-commerce platform. Firstly, a new clause (c) has been inserted in Rule 4(11), prohibiting an e-commerce entity from misleading users by manipulating search results or search indexes having regard to the search query of the user. The existing Rule 4(11) already prohibited manipulation of the price of goods or services to gain unreasonable profit and discrimination between consumers of the same class. This amendment therefore expressly brings misleading search manipulation within the prohibited conduct.

Secondly, the newly inserted Rule 4(12) requires every e-commerce entity to ensure that sponsored listings of products and services are distinctly identified through clear and prominent disclosures. This creates a specific separation between paid or sponsored visibility and organic search or discovery, and will require platforms to ensure that the commercial character of sponsored placements is apparent to consumers, at the point at which such listings are displayed to them.

4. Transparency in Price Reductions and Invoicing:

The 2026 Amendment Rules introduce a new Rule 4(13) governing announced price reductions. Where an e-commerce entity or a seller announces a reduction in the price of any goods or services on the platform, the reduced price must be displayed alongside the “prior price”. For this purpose, the prior price has been defined as the lowest price of the relevant good or service during the 30 (thirty) days preceding the announcement of the price reduction. This requirement is aimed at ensuring that consumers are able to evaluate an advertised discount against a meaningful historical reference price, rather than against an artificially inflated price.

In addition, the newly inserted Rule 4(14) requires every e-commerce entity to display the name of the seller clearly and prominently on the invoice in the same font size as the name of the e-commerce entity. The amendment therefore seeks to make the identity of the seller more apparent to the consumer at the transaction and post-purchase stage and reduces possible confusion between the role of the platform and that of the seller.

5. Statutory Recognition of Dark Pattern Compliance and Annual Self-Audit:

The newly inserted Rule 4(15) expressly requires every e-commerce entity to comply with the Dark Patterns Guidelines and to conduct a yearly self-audit to ensure that its platform is free from dark patterns. The e-commerce entity must also prominently display a certificate to this effect. This is a material development since the 2025 advisory by the Central Consumer protection Authority (“CCPA”) had only called upon e-commerce platforms to undertake self-audits as a regulatory compliance measure, and the 2026 Amendment Rules now incorporate an annual self-audit requirement directly into the E-Commerce Rules. Accordingly, dark-pattern compliance is likely to become an ongoing platform-governance requirement rather than a one-time or event-driven exercise. E-commerce entities will need to periodically review user journeys, default settings, subscription and cancellation flows, advertisements, checkout design, fee disclosures, consent interfaces and other design elements against the Guidelines for Prevention and Regulation of Dark Patterns, 2023, and maintain an auditable basis for the certificate displayed on the platform.

6. Enhanced Disclosures by Marketplace E-Commerce Entities:

The 2026 Amendment Rules have also strengthened the obligations of marketplace e-commerce entities under Rule 5. In particular, Rule 5(3) has been amended in relation to seller disclosures, product and transaction information, and ranking transparency:

I. Seller information: Marketplace e-commerce entities are required to provide details of sellers offering goods or services, including the name of the business, whether it is registered or not, geographic address, customer-care number, name and details of the seller’s website and e-mail address where available, ratings or other aggregated feedback and any other information necessary to enable informed decisions at the pre-purchase stage. The post-purchase right of a consumer to seek seller information in writing has also been updated to expressly include the seller’s website and e-mail address, along with its principal geographic address and branches and other information necessary for effective dispute resolution.

II. Product and transaction disclosures: Rule 5(3)(c) now expressly includes the best-before or use-before date among the information relating to a product or service that must be made available to consumers, in addition to information on return, refund, exchange, warranty and guarantee, delivery and shipment, modes of payment and grievance redressal. In relation to food products, the requirement to display best-before or use-before dates will remain subject to the Food Safety and Standards Act, 2006 (“FSS Act”) and the regulations made thereunder.

III. Ranking parameters: Rule 5(3)(f) now requires the main parameters which individually or collectively are most significant in determining the ranking of goods or sellers to be set out in descending order, together with an explanation of their relative importance through an easily and publicly available description drafted in plain and intelligible language. This strengthens the existing ranking-transparency obligation by requiring a clearer indication of the relative hierarchy of the principal ranking factors.

7. Restrictions on Use of Consumer Information by Marketplace E-Commerce Entities:

A new Rule 5(6) places substantive restrictions on the use of information collected by a marketplace e-commerce entity. The provision states that such information shall not be used for the sale of goods, directly or indirectly, by any seller (whether related or unrelated) where such goods bear a brand or name common with that of the marketplace e-commerce entity. Separately, the information cannot be used to promote or advertise any seller as being associated with the marketplace e-commerce entity unless the marketplace has obtained the express and affirmative consent of the consumer or consumers to whom the information pertains. The new restriction is particularly relevant for marketplaces which use consumer-level information for targeted merchandising or promotion. Marketplace entities will need to assess the sources, purposes and downstream use of consumer information, and ensure that promotional uses falling within the second limb of Rule 5(6) are supported by the prescribed express and affirmative consent.

8. Prohibition on Bundled Fees for Unrelated Services:

Under the newly inserted Rule 5(7), a marketplace e-commerce entity is prohibited from collecting bundled fees from users, in connection with services provided on the e-commerce platform, for any other services that are unrelated to the e-commerce platform. The restriction does not apply to a loyalty or membership programme, or to any benefit, service, offer or incentive provided in connection with or pursuant to such loyalty or membership programme. The amendment therefore requires greater separation and transparency in relation to platform fees and charges for ancillary or unrelated offerings. Marketplace entities will need to review checkout flows, fee descriptions and bundled offerings to determine whether charges are sufficiently connected with the e-commerce service or fall within the loyalty or membership programme exception.

9. Enhanced Obligations of Sellers on Marketplace Platforms:

Rule 6(5)(d), which governs information that sellers are required to provide to marketplace e-commerce entities for display to consumers, has been expanded. Sellers must now provide all relevant details concerning the goods and services offered for sale, including country of origin, best-before or use-before date, return, refund and exchange information, warranty and guarantee, delivery and shipment, cost and return shipping, modes of payment, and other information necessary to enable an informed pre-purchase decision. As in the marketplace disclosure provision, the requirement relating to best-before or use-before dates for food products remains subject to the FSS Act and the regulations made thereunder.

Further, the newly inserted Rule 6(5)(j) requires sellers to provide an identification number issued by the Central Government, including the Goods and Services Tax Identification Number or Micro, Small and Medium Enterprises registration number, as applicable. Marketplace entities would therefore be required to make corresponding changes to seller-onboarding, seller-master data and product-information systems so that such information can be collected, verified and made available in accordance with the E-Commerce Rules.

10. Enhanced Obligations of Inventory E-Commerce Entities:

Rule 7(1)(a), which applies to inventory e-commerce entities, has also been expanded. Inventory e-commerce entities will be required to provide accurate information relating to return, refund and exchange, best-before or use-before date, warranty and guarantee, delivery and shipment, cost of return shipping, modes of payment, grievance redressal mechanism and other similar information required for an informed consumer decision. The display of best-before or use-before dates for food products will similarly be subject to the Food Safety and Standards Act, 2006 and the regulations made thereunder.

Implications and Analysis:

1. Shift towards platform-level and design-based compliance

The 2026 Amendment Rules marks a significant shift from general principles of transparency and prohibition of unfair trade practices towards specific and more prescriptive regulation of how e-commerce platforms are designed and operated. Search results, ranking, sponsored content, discount presentation and dark patterns are now expressly regulated, requiring e-commerce entities to look beyond their terms and policies and assess whether the functioning of their platform itself complies with the amended framework. Accordingly, compliance is likely to become increasingly cross-functional, requiring e-commerce entities to work closely on their product, engineering, advertising, seller-management and customer-service functions. This amendment reflects the Government's stated objective of addressing emerging consumer concerns arising from evolving digital practices while improving transparency in e-commerce.

2. Greater scrutiny of search, ranking and promotional practices

Marketplace e-commerce entities using algorithmic search or recommendation systems will need to exercise greater oversight over how products and sellers are ranked and promoted. While the amendments do not require disclosure of the underlying algorithm, they require disclosure of the principal ranking parameters and their relative importance, prohibit misleading manipulation of search results, and require sponsored listings to be clearly distinguishable. In practice, platforms will need to maintain a defensible distinction between organic rankings, sponsored placements and other forms of promoted visibility, and ensure that their public disclosures accurately reflect how ranking systems actually operate. This may also require stronger internal governance over changes to search and recommendation models, particularly where commercial considerations influence product visibility.

The requirement to display the lowest price during the preceding 30 days as the “prior price” whenever a price reduction is announced, is similarly likely to require material changes to pricing systems. Platforms will need reliable price-history records and clear rules for determining the reference price where prices are frequently changed or where discounts are funded through different mechanisms. Since the amendments do not specifically address circumstances such as newly listed products, personalised offers or combinations of seller-funded and platform-funded discounts, these areas may present implementation challenges and may require further regulatory clarification.

3. Increased responsibility for marketplace data and consumer information

The amendments also place greater responsibility on marketplace e-commerce entities for the accuracy and use of information available on their platforms. Enhanced seller, product, invoice and pre-purchase disclosures will require platforms to ensure that the information collected during seller onboarding remains complete and updated throughout the seller relationship. Seller agreements and internal onboarding processes may therefore need to be revisited to ensure timely availability of information relating to seller identity, government-issued identification numbers, country of origin, shelf-life, return-shipping costs and other prescribed particulars.

The restrictions on use of consumer information under Rule 5 are particularly significant for marketplaces operating private labels, common-brand products or data-driven promotional programmes. Notably, the prohibition on using marketplace-collected information for sale of goods bearing a brand or name common with the marketplace appears, on the language of the amendment, to operate independently of the consent-based exception applicable to promotion of sellers as being associated with the marketplace. Marketplace entities would therefore need to carefully map the purposes for which consumer information is presently used, rather than treating consumer consent as a general basis for all such uses.

4. Dark patterns: From advisory self-regulation to recurring compliance

The annual dark-pattern self-audit requirement is a particularly important development. In 2025, the CCPA had urged e-commerce platforms to undertake self-audits and eliminate dark patterns. The 2026 Amendment Rules now convert this approach into an express recurring obligation, together with a requirement to prominently display a certificate of compliance. This assumes greater significance in light of the CCPA's recent enforcement actions against digital platforms for dark-pattern practices, indicating that interface design is already being subjected to active regulatory scrutiny.

For e-commerce entities, an annual exercise alone may therefore be insufficient. Since platform interfaces are continuously modified through product releases, experiments and personalised user journeys, entities may need ongoing controls to ensure that new design features do not introduce prohibited patterns between audit cycles. The period before January 1, 2027, should accordingly be used for a coordinated review of ranking systems, sponsored-content labelling, price-history architecture, seller and invoice disclosures, consumer-data use, grievance workflows and dark-pattern controls. However, the key implementation challenge will be ensuring that these requirements are translated into consistent operational and technical practices across evolving platform systems, business processes and consumer facing interfaces.

Please find attached a copy of the 2026 Amendment Rules, here.

This update has been contributed by Jitendra Soni (Partner) and Samia Haider (Associate).

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