Consumer Protection (E-Commerce) (Amendment) Rules 2026: From consumer disclosure to platform governance

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

The E-Commerce Rules apply broadly to e-commerce entities, covering both marketplace and inventory models, as well as e-commerce retail activities and unfair trade practices across e-commerce models. They also extend to entities established outside India where they systematically offer goods or services to consumers in India. Read together with the Consumer Protection (E-Commerce) Rules, 2020, the Amending Rules mark a shift in regulatory focus from disclosures addressed to the consumer, to more direct regulation of how e-commerce platforms are built, operated and presented to users. The changes affect search and ranking, sponsored listings, discount pricing, seller and marketplace disclosures, invoicing, dark patterns, and the use of consumer information.

Amended Rule 3(1)(j) widens the definition of “ranking” to cover the prominence given not only to goods and services but to sellers themselves, irrespective of the technology used to present or organise them. Further, new Rule 4(11)(c) separately prohibits manipulating search results or indexes in a manner that misleads users having regard to their search query, and Rule 4(12) requires sponsored listings to be clearly and prominently identified as such.

Rule 5(3)(f) correspondingly requires marketplace entities to explain, in descending order and in plain, intelligible language, the parameters that principally determine ranking, together with their relative weight. Notably, this requirement is limited to explaining the factors that drive visibility, rather than requiring disclosure of an algorithm or source code.

Takeaway: E-commerce entities will need to ensure greater transparency in how products and sellers are ranked and displayed, including by clearly identifying sponsored listings and explaining the principal parameters that determine ranking. The objective is to enable consumers to distinguish between organic search results and commercially influenced placements.

Rule 4(13) requires that any announced price reduction be shown alongside a “prior price”, the lowest price at which the good or service was offered in the thirty days preceding the announcement. The Amending Rules do not address how this requirement would operate for newly listed products, personalised pricing, or layered discount structures, however.

Takeaway: This is a more exacting reference point than a ‘maximum retail price’ or a platform-set ‘original’ price, and it will require reliable price-history data, particularly where prices move frequently or where a discount is funded partly by the seller and partly by the platform.

Rule 4(15) gives statutory force to a hitherto voluntary framework: the Guidelines for Prevention and Regulation of Dark Patterns, 2023. From the enforcement of the Amending Rules, every e-commerce entity will need to carry out a yearly self-audit confirming that its platform is free of such patterns, and to prominently display a certificate to that effect.

Takeaway: The express annual self-audit and certification requirement signals that dark-pattern compliance is now a continuing regulatory focus and cannot be treated as a one-time exercise.  Given that platform interfaces and user journeys may change throughout the year, businesses should build dark-pattern checks into their regular product and compliance reviews rather than rely solely on the annual audit.

Rule 5(3)(a) expands what a marketplace must disclose about its sellers’ business name, registration status, geographic address, customer-care details, website and email address (where available), and ratings or aggregated feedback, and gives consumers a right to request further seller information in writing after a purchase, for effective dispute resolution.

On the seller side, Rule 6(5)(d) adds country of origin, best-before/use-before information, return and payment terms, and return-shipping costs to the mandatory disclosure list, and the new Rule 6(5)(j) requires sellers to furnish government-issued identifiers such as a GSTIN or MSME registration number.

Takeaway: Platforms will need onboarding and data-governance processes that keep this information accurate on an ongoing basis, not only at the point of listing.

Rule 5(6) introduces specific restrictions on how a marketplace e-commerce entity may use consumer information collected through its platform. The provision does not amount to a blanket prohibition on a marketplace using consumer information for all marketing or promotional activities. Instead, it addresses two specific uses.

First, a marketplace cannot use consumer information for the direct or indirect sale of goods by a seller where those goods bear a brand or name common with that of the marketplace, irrespective of whether the seller is related to the marketplace. Second, a marketplace cannot use consumer information to promote or advertise a seller as being associated with the marketplace, unless it has obtained the express and affirmative consent of the relevant consumer.

The distinction is important. The second limb does not prohibit a marketplace from marketing to consumers generally; rather, it places a specific consent requirement where consumer information is being used to represent or promote a seller as being associated with the marketplace. The first limb is more specific still, targeting the use of consumer information in connection with the sale of goods bearing a brand or name common with that of the marketplace.

Takeaway: For marketplaces running private-label businesses, common-brand arrangements, or data-driven promotional programmes, this calls for a careful mapping of how consumer information actually flows through the organisation, rather than treating a general consent as sufficient cover for every downstream use. A general consumer consent should not be assumed to address the specific uses regulated by Rule 5(6).

Rule 4(4) requires an entity’s legal name, the address of its headquarters and branches, its website, and its customer-care and grievance-officer contact details to be displayed prominently. Grievance officers must acknowledge a complaint within 48 hours, provide the complainant with a copy of the complaint as recorded, and resolve it within one month (Rule 4(5)). Invoices must show the seller’s name in the same font size as the platform’s own name (Rule 4(14)). Imported goods require disclosure of the importer and the full country of origin (Rule 4(6)). And participation in the Central Government’s National Consumer Helpline convergence process, previously a best-efforts commitment, is now mandatory (Rule 4(7)).

The practical steps recommended to be taken before the Amending Rules come into effect are:

1. Mapping ranking and search logic against the new disclosure and anti-manipulation requirements, and preparing the plain-language ranking-parameter statement;

2. Building or upgrading price-history systems capable of identifying the correct “prior price” reference and reviewing business practices to ensure that they are compliant;

3. Moving dark-pattern review from an annual exercise to a standing process, with an auditable trail for the yearly certificate;

4. Auditing seller-onboarding workflows and seller-master data against the expanded disclosure list, including GSTIN/MSME capture;

5. Mapping consumer-data flows against the Rule 5(6) restrictions, particularly for private-label and common-brand businesses; and

6. Reviewing invoice templates, grievance workflows, and National Consumer Helpline integration.

Consumer protection is increasingly a question of how a platform is designed and operated, not only what its terms and conditions say. For most businesses, that will mean compliance work running through legal, product, engineering and commercial teams in a multi-functional manner, rather than sitting with legal and compliance alone.

About the authors: Siddhartha George and Harini Sudersan are Partners, Bilal Lateefi is a Principal Associate at Poovayya & Co.

Disclaimer: The opinions expressed in this article are those of the author(s). The opinions presented do not necessarily reflect the views of Bar & Bench.

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