Seller Disclosures Under India’s New E-Commerce Rules: What Marketplaces Must Verify, Display and Answer For
Introduction : For the average consumer, buying a product online involves placing a trust in two parties simultaneously: the platform on which the product is shown and the seller who is actually responsible for delivering it. For many years the law has focused more on regulating the first of these two relationships than the second. The Consumer Protection (E-Commerce) (Amendment) Rules, 2026 (the "2026 Amendment") alter this situation. The amendment was notified by the Department of Consumer Affairs on 9 September 2026 and will come into force on 1 January 2027; it modifies the Consumer Protection (E-Commerce) Rules, 2020 (the "2020 Rules") and makes it necessary to clearly and specifically regulate seller identity, product information and the handling of post-sale complaints. Platforms are required to get sellers to give their government-issued identification number, show the seller's contact information in a prominent way, display the seller's name on the invoice, and make product-level data such as the country of origin and the best-before dates available to customers before the purchase is made.
The Statutory Framework
The 2020 Rules were notified on 23 July 2020 under the Consumer Protection Act, 2019 (the “CP Act”) and established the first dedicated consumer-protection regime for online commerce in India.They apply to e-commerce entities generally, covering both the marketplace model and the inventory model, and distinguish between the duties of all e-commerce entities (Rule 4), marketplace e-commerce entities (Rule 5), sellers on marketplaces (Rule 6) and inventory e-commerce entities (Rule 7). The 2026 Amendment has been issued under the rule-making power of the CP Act and sits within this same architecture.
A “marketplace e-commerce entity” is a platform that provides an information technology platform on a digital or electronic network to facilitate transactions between buyers and sellers. That structural position, a facilitator that does not own the inventory, is exactly why seller disclosures carry so much weight: the platform controls the interface through which the seller’s identity, goods and promises reach the consumer.
The changes introduced by the 2026 Amendment
The amendment affects a number of aspects of the 2020 Rules, the clauses most pertinent to seller disclosures, as indicated in the legal firm's comments on the version that has been notified, are listed below.
Rule 3(10(j)): Has been expanded so as to include not only goods and services but also sellers in terms of the prominence or relevance they receive; platforms are required to be able to explain how sellers, not just products, are displayed.
Rule 4(2): Requires every e-commerce business to clearly show its legal name, its principal geographical address (that is, its head office and branches), information about its website, and the email addresses as well as the landline and mobile phone numbers for both customer service and the grievance officer. This establishes the basic identity of the platform, with the details of the sellers displayed alongside it.
Rule 4(5): Requires the grievance officer to acknowledge complaints within 48 hours, to provide redress within one month, and is now making copies of the complaints as recorded by the officer This results in a verifiable complaint record.
Rule 4(6): The name of the importer and the full name of the country of origin of imported goods must be disclosed in accordance with the Legal Metrology (Packaged Commodities) Rules, 2011; this relates the data to the labelling law.
Rule 4(7): Requires convergence with the National Consumer Helpline (previously it had been merely a best-effort endeavour). Complaints may be submitted to the platform via a government channel.
Rule(11)(c), 4(12): It is prohibited to engage in misleading manipulation of search results and sponsored listings must be clearly identified. Paid seller listings must be clearly separated from the organic rankings.
Rule 4(13): When a price reduction is announced the reduced price must be displayed together with the 'prior price', which is defined as the lowest price obtained in the previous 30 days; listing prices must be supported by records of price history.
Rule 4(14): The seller's name must be clearly displayed on the invoice in the same font size as that of the e-commerce entity. This ensures that the seller's identity is visible after the purchase.
Rule 4(15): Carrying out a self-audit each year in accordance with the Dark Patterns Guidelines, 2023, and displaying a certificate. The design of the interface then becomes something that must comply.
Rule 5(6): States that consumer information gathered by a marketplace must not be used in the sale of goods bearing a brand or name that is common with the marketplace, or for promoting a seller as being associated with the marketplace, without obtaining specific and clear consent. This rule sets a limit on the promotion of seller relationships using consumer data.
Rule 5(7): There should be no bundled fees for services that are unrelated to the platform, except in the case of loyalty or membership programmes.
Rule 6(5)(d): Requires sellers to give full details about the product and the transaction, including the country of origin, the best-before or use-before date, the terms regarding returns, refunds and exchanges, the warranty, delivery arrangements, the cost of return shipping and the various payment methods. This is the seller's obligation which underpins the platform's duty to display the information.
Rule 6(5)(j): Requires sellers to provide a government-issued identification number, for example a GSTIN or an MSME registration number.
It is also worth noting that the amendment will come into force on 1 January 2027, giving the platforms about a quarter of a year from being informed to get ready. Moreover, with regard to the related Legal Metrology changes, there will be a searchable and sortable country-of-origin filter for imported products from 1 July 2027, which implies that the listing data must be organised and cleaned well in advance of that date.
Legal Analysis
A. Moving from “Display” to “Verify”: The Checks That Marketplaces Should Make Regarding Sellers.
The 2026 Amendment imposes two related obligations on the marketplace. According to Rule 5(3), it is required that the marketplace give the consumer the specified seller details. Together with the marketplace's onboarding process, Rule 6(5)(j) requires sellers to provide a government-issued identification number. While the first of these duties is clear in regard to the need to display the information, neither the amendment nor the commentary on which this blog has drawn specifies a verification standard.
The key issue here is compliance. A platform which simply obtains a GSTIN and prints it on a listing page may comply with the requirement relating to the display of information, but it will still be at risk if the number is false, belongs to a different business, or has been cancelled. Commentary from law firms points out that the improved disclosures will mean that platforms have to make sure that the information gathered during onboarding stays both complete and up to date throughout the seller's relationship, indicating that this should involve continuous rather than one-off due diligence. The Rules also continue to require, as they did under the 2020 framework, that content on the platform - such as descriptions and images - be accurate, so a platform that displays unverified seller data will have few defenses if that data is misleading.
In practice, the following are the seller-level facts a marketplace should treat as verifiable rather than merely collectable:
Legal identity and registration status: the business name of the seller, indicating whether or not it is registered, together with its government-issued identification number (GSTIN or MSME registration); the 2026 version specifically includes sellers who are not registered, so the onboarding procedures have to record their registration status rather than requiring them to provide a number.
Address and branches. The geographical address and, in the case of requests made after a purchase, the main address and the branches. A virtual or unattainable address defeats the object of the disclosure, which is to ensure that dispute resolution can take place.
Reachability: a working customer care telephone number, together with the seller's website and email address if available.
B. The products and listings: what the platform must make available
The amendment extends the range of product information which must be available to the consumer at the time of purchase. Now, under Rule 5(3) and Rule 6(5)(d), the best-before or use-before date together with the terms regarding return, refund and exchange, the warranty and guarantee terms, the delivery and shipment details, the cost of return shipping and the various payment methods are all included.
With regard to food products, the requirement relating to the date remains in force pursuant to the Food Safety and Standards Act, 2006 and the regulations made thereunder. Furthermore, with regard to imported goods, the platform has to indicate that they are imported, make the identity of the importer known, and provide the full and complete name of the country of origin in accordance with the Legal Metrology (Packaged Commodities) Rules, 2011.This has practical importance since the country of origin cannot be included in a free-text description field if the platform is later to offer a filter based on it; instead, it should be a mandatory, structured attribute in the listing template.
Three further listing-level risks flow from the amendment:
Claims regarding price. A discount can only be displayed when it is compared with the lowest price recorded over the previous 30 days, which means that a listing offering a discount without a reliable record of past prices is at a disadvantage. The commentary points out that the amendment does not cover newly listed products, personalised offers, or situations where both seller-paid and platform-paid discounts are involved, so the platforms will have to draw up their own internal rules for these instances.
Sponsored placement. Sponsored listings must be clearly identified. A seller which purchases prominence is therefore not only a commercial customer but also a disclosure subject, and the platform must keep paid and organic listings visibly separate.
The ranking of sellers. Since the definition of ranking now includes sellers, a platform which promotes certain sellers should be able to state, in simple terms and in descending order of importance, the criteria that cause that promotion to occur.C. Seller Onboarding as the Control Point Onboarding is where most listing risk is either prevented or created. The amendment’s demands on seller data (identification number, address, contact details, product attributes) all originate at this stage. Commentary on the amendment states that marketplaces will need to change onboarding, seller-master-data and product-information systems so that required information can be collected, verified and displayed as the Rules prescribe. Seller agreements, too, will need revisiting so that sellers are contractually bound to supply and update the prescribed particulars within defined timelines, and so that the platform has clear rights to delist or suspend when they do not.
For platforms with an intellectual property exposure, onboarding is also the natural point to collect brand authorisations and proof of trade mark rights for branded goods. The consumer-protection rules do not themselves create an IP verification duty, but a listing that is inaccurate about origin, brand or authenticity can fall foul of both regimes at once.
Practical Implications
The 1 January 2027 commencement date of the amendment leaves very little time. Breaches of the E-Commerce Rules are subject to the same penalties as under the CP Act and it is expected that the Central Consumer Protection Authority will ramp up its enforcement post-commencement given its recent track record of taking action against platforms and issuing advisories on dark patterns and misleading advertising. A sensible plan for the remaining weeks would be to work along four tracks.
Data. Add in the mandatory, structured fields for every prescribed seller and product attribute and audit the existing seller base against them. The existing sellers on the platform are just as much in scope as any new ones so it's going to be a case of back filling and re-verifying.
Contracts. Amend the seller agreements to require accurate and timely disclosures, to permit the platform to display those disclosures and to give the platform clear rights to suspend and delist.
Interface. Go through the listing pages, seller profile pages, invoices and complaint flows against the new display rules (including the labelling of sponsored listings and the prior price display). Governance. Ownership needs to be assigned across the legal, product, seller management and customer service teams and the rationale for your verification decisions needs to be documented as the Rules leave the standard very open.
For sellers (particularly small businesses) the amendment means that their registration details and product information will be publicly available. They can expect to receive more documentation requests from the platforms and should ensure their GST, MSME and labelling records are up to date.
Relevant Case Laws
Christian Louboutin SAS v. Nakul Bajaj & Ors., 2018 SCC OnLine Del 12215 (Delhi High Court): The platform was not a mere passive intermediary. It was actively engaged in the sale of luxury goods (including Louboutins) and had in fact taken steps to assure the authenticity of the goods and to control the transaction. That is sufficient to mean that it cannot be treated as a passive intermediary for the purposes of the safe harbour. The point is very much relevant to the extent to which verification and curation impact the status of a platform.
Kent RO Systems Ltd. & Anr. v. Amit Kotak & Ors. (Delhi High Court, 2017) - the Court looked at the position of an online marketplace as an intermediary in an IP dispute relating to listings. It confirmed the availability of the safe harbour for an intermediary who is compliant with the intermediary framework and acts on the notices. It is frequently cited on the proposition that the platform's role in practice will determine its exposure.
Conclusion
The 2026 Amendment takes seller disclosure from a principle to a structured, auditable duty. Marketplaces will be required to have sellers identify themselves via a government number, make seller and product information visible to the consumer prior to purchase, show the seller's name on the invoice and provide the consumer with a documented route for making a complaint which will be supported by the National Consumer Helpline.
The most defensible approach is to treat seller onboarding as a standalone compliance function: structured data capture, appropriate and documented verification, contractual rights to enforce the accuracy of that data and periodic re-verification.
Platforms that have those controls in place will be in the best position to meet the 1st January 2027 deadline, to be able to respond to consumer requests for seller information and to be able to demonstrate due diligence if a listing is challenged. As the regulators go on to clarify the open issues around the standard of verification and the scope of the dark pattern audit, the controls can be adapted, but they shouldn't be put off until that clarification is in place.
Author: Ishika in case of any queries please contact/write back to us via email to content@khuranaandkhurana.com or at Khurana & Khurana, Advocates and IP Attorney
Endnotes
Consumer Protection (E-Commerce) (Amendment) Rules, 2026, notified by the Department of Consumer Affairs, Ministry of Consumer Affairs, Food and Public Distribution, 9 September 2026 (Notification No. CG-DL-E-10092026-276125, Gazette of India, Extraordinary, Part II, Section 3, Sub-section (i)), in force 1 January 2027.
Khaitan & Co., ‘Consumer Protection (E-Commerce) (Amendment) Rules, 2026: Additional Compliances for E-Commerce Entities’, Legal 500 (5 October 2026).
Argus Partners, ‘Overview of the Consumer Protection (E-Commerce) (Amendment) Rules, 2026’, Legal 500 (23 September 2026).
Consumer Protection (E-Commerce) Rules, 2020, notified 23 July 2020.
Consumer Protection Act, 2019, s. 101(2)(zg), as referred to in LexComply, ‘Consumer Protection (E-Commerce) (Amendment) Rules, 2026: Everything That Changed, Clause by Clause’.
Khaitan & Co., supra note 2 (commencement, Legal Metrology country-of-origin filter, grievance redressal, dark-pattern audit, data-use consent and enforcement observations); see also SCC Online Blog, ‘Consumer Protection (E-Commerce) Amendment Rules 2026: Explained’ (14 September 2026).
Christian Louboutin SAS v. Nakul Bajaj & Ors., 2018 SCC OnLine Del 12215 (Delhi High Court).
Kent RO Systems Ltd. & Anr. v. Amit Kotak & Ors. (Delhi High Court, 2017).
Guidelines for Prevention and Regulation of Dark Patterns, 2023 (Central Consumer Protection Authority).
Legal Metrology (Packaged Commodities) Rules, 2011; Food Safety and Standards Act, 2006.
Information Technology Act, 2000, s. 79.
Digital Personal Data Protection Act, 2023.
OECD, Recommendation of the Council on Consumer Protection in E-commerce (2016).
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