The Ministry of Consumer Affairs, Food and Public Distribution has recently amended the Consumer Protection (E-Commerce) Rules, 2020, through the Consumer Protection (E-Commerce) (Amendment) Rules, 2026. The amended set of rules will come into force on January 1, 2027. In light of this development, the important changes to be considered by e-commerce platforms include the following:

●       Copy of complaint to be provided to complainant

The existing grievance redressal framework required the e-commerce entity to acknowledge a customer’s grievance within 48 hours and resolve the same within one month. The amended rules additionally require the e-commerce entity to provide to the complainant, a copy of the grievance as recorded by the grievance officer. It appears that the intention of the amendment is to address situations where complainants have no proof of having lodged a grievance, particularly where platforms accept grievances through online forms. Such upfront furnishing of proof of filing would aid consumers who need to pursue a consumer complaint if the grievance remains unresolved.

●       Disclosure of Country of Origin for Imported Goods or Services

The existing rules require e-commerce entities offering imported goods or services to disclose the name and details of the importer. In addition to the aforementioned, the amended rules also require e-commerce entities to identify imported goods and disclose their country of origin, in accordance with the Legal Metrology (Packaged Commodities) Rules, 2011.

●       Mandatory National Consumer Helpline (NCH) participation

The existing set of rules simply mentioned that e-commerce entities should endeavour on a best effort basis to become a partner in the convergence process of the National Consumer Helpline (NCH). The amended rules, however, mandate that all e-commerce entities become a partner in the convergence process of NCH of the Central Government. This change is expected to strengthen the grievance redressal mechanism of e-commerce platforms and enable greater oversight over the resolution of grievances by e-commerce entities.

●       Restriction on search ranking manipulation

The amended rules introduce a new restriction on e-commerce entities, requiring them to not mislead users by manipulating search results or search indexes having regard to the user’s search query. Accordingly, e-commerce platforms must ensure that search results displayed by them remain relevant to a user’s search query and are not manipulated in a manner that adversely affects such relevance.

●       Display of sponsored labels

The amended rules require e-commerce entities to ensure that sponsored listings of products and services are distinctly identified through clear and prominent disclosures. Accordingly, e-commerce entities must implement appropriate disclosures in a manner that makes sponsored listings clearly visible and identifiable, so consumers have greater clarity while purchasing goods and services.

●       Disclosures regarding price reduction

The amended rules require that where an e-commerce entity or a seller announces a price reduction for any goods or services offered on its platform, they must indicate the prior price of such goods or services along with the reduced price. To ensure effective enforcement of this requirement, the amended rules further specify that ‘prior price’ means “the lowest price of a good or service  thirty days prior to the announcement of price reduction”. Therefore, as a consequence of the amendment, e-commerce platforms will not be able to advertise price reductions by comparing  the reduced price against recently inflated prices of such goods or services.

●       Compliance with Dark Patterns Guidelines

The amended rules expressly require e-commerce platforms to comply with the Guidelines for Prevention and Regulation of Dark Patterns, 2023. In addition, platforms are required to conduct a yearly self-audit to confirm that the platform is free from dark patterns, and to prominently display a certificate to that effect. This requirement adds additional compliance obligations for e-commerce platforms going forward.

●       Enhanced Disclosure Requirements for Marketplace E-Commerce Entities

The amended rules introduce additional disclosure requirements for marketplace e-commerce entities. Platforms are now required to provide the website and email address of sellers, where available, and disclose the best-before or use-before date of products, where applicable, subject to applicable food safety laws in the case of food products. Further, the main parameters used for determining the ranking of goods or sellers must now be disclosed in descending order of significance. Accordingly, marketplace e-commerce entities will need to review and update their existing seller and product disclosures, as well as the manner in which ranking parameters are disclosed on their platforms.

●       Restriction on usage of data collected by platforms

Under the amended rules, marketplace e-commerce entities  must not use data collected by them for the sale of goods, directly or indirectly, by any seller, whether related or not, whose brand or name is common with that of the marketplace e-commerce entity. Additionally, marketplace e-commerce entities are restricted from using such  data to promote or advertise any seller as being associated with the platform, unless the platform has obtained the express and affirmative consent of the consumer(s) for such use.

This appears intended to address a longstanding consumer concern regarding the alleged practice of e-commerce platforms using consumer data to prioritise their own goods and services, or sellers affiliated with them.

●       Restriction on bundling of fee

Marketplace e-commerce platforms will no longer be able to collect a bundled fee from users for any services unrelated to the e-commerce platform itself. The amended rules, however, provide an exception to this requirement, platforms remain free to charge a fee for a loyalty or membership programme, or for any benefit, service, offer or incentive provided in connection with such a programme.

●       Additional Disclosures by Inventory E-Commerce Entities

The amended rules introduce additional disclosure requirements for inventory e-commerce entities, requiring them to disclose the best-before or use-before date, where applicable. In the case of food products, the requirement will be subject to applicable food safety laws.

Given that this amendment introduces several new requirements for e-commerce platforms many of which address concerns around unfair trade practices allegedly adopted by such platforms, it is recommended that platforms review their existing systems and practices and implement the necessary changes to ensure compliance with the amended rules within the stimulated time period.

Authors:
Gaurav Bhalla (Partner)

Lavanya Bhakuni (Associate)