India’s new e-commerce rules: what changes on 1 January 2027

From 1 January 2027, an online seller in India announcing a discount must also display the prior price — and prior price has a definition you do not get to choose. It is the lowest price at which that product was offered in the thirty days before the announcement. Dark patterns stop being guidance and become an annual audit with a certificate on your site. Complaints get a clock.

The changes come from the Consumer Protection (E-Commerce) (Amendment) Rules, 2026, notified by the Department of Consumer Affairs on 9 September 2026 and amending the 2020 Rules. Much of the coverage has treated them as a design problem. For anyone actually running a store, the harder part is data — and one piece of it has to start accruing well before January.

This is a working summary for our clients, written from the notification itself. It is not legal advice — check your own position against the notification and take advice where it matters.

First, work out which of the three you are

The obligations are not uniform, and the single most common mistake in reading these rules is assuming they all land on everybody. They do not. Before anything else, place yourself.

If you…	You are	What lands on you
Sell your own goods through your own website or app	An e-commerce entity, selling from your own inventory	The general duties — identity, grievances, prior price, dark patterns, invoice, imports — plus accurate return, refund, warranty, expiry and return-shipping information
Run a platform where other sellers list	A marketplace e-commerce entity	All of the above, plus seller disclosure, ranking transparency, the limits on using collected information, and the bundled-fees restriction
Sell on someone else’s marketplace	A seller on a marketplace	Product-level disclosure, including country of origin, expiry, return shipping cost — and your GST or MSME registration number

Most building materials businesses are the first row, and many are the first and third at once — own site, plus listings on a marketplace. The heaviest new obligations, the ones about using platform data and about bundled fees, sit on marketplaces and will not apply to you. The prior price rule and the dark patterns audit will.

The prior price rule, and why it is a data problem

When a price reduction is announced — by the platform or by the seller — the reduced price and the prior price must both be shown. The notification defines prior price precisely: the lowest price of that good or service in the thirty days before the announcement.

Not what you charged yesterday. Not an MRP you nominated. The lowest, across a rolling window.

Which means the number cannot be typed in by whoever sets up the sale. It has to be derived from your own price history, per product, on the day the discount goes live. Three questions worth asking your team this week.

Do we keep price history at all? Many stores simply overwrite the price field. If the old value is gone, there is nothing to derive a prior price from.
Is it per variant? A 600×600 in matte and the same tile in gloss are separate products with separate histories.
Does it capture every channel? If a price was lower in an app, or during a promotion, that is part of the same picture.

There is a practical consequence that catches people out: a brief deep discount contaminates the next month. Drop a product very low for a weekend flash sale, and for the following thirty days that weekend price is your prior price — so the next campaign displays a much smaller reduction than it feels like you are offering.

Businesses that discount constantly will find the rule quietly reshapes their calendar. That is presumably the intention.

Dark patterns become auditable

The Guidelines for Prevention and Regulation of Dark Patterns have existed since 2023. What changes is their status. Every e-commerce entity must comply with them, conduct a yearly self-audit to ensure the platform is free of dark patterns, and display a certificate to that effect prominently.

That moves it from something you could interpret loosely into something with a document behind it. A certificate you display in public is a statement you can be held to, so the audit wants a written basis rather than a quick look around the site.

Patterns worth examining honestly on your own store: countdown timers that reset on refresh, stock counts that are not real, pre-ticked add-ons, a cancellation path harder to find than the buying path, and interface copy that shames a customer for declining something.

Most of these arrive in a store not through bad intent but through a theme or a plugin that shipped with them switched on. Worth checking what your storefront is doing by default, because the certificate does not distinguish between a pattern you chose and one you inherited.

Search, ranking and sponsored listings

Three related changes.

Search results and search indexes may not be manipulated to mislead users, having regard to what the user actually searched for. Sponsored listings must be distinctly identified with clear and prominent disclosure. And the definition of “ranking” itself has been rewritten to mean the relative prominence or relevance given to sellers or goods, irrespective of the technological means used — which closes the argument that an algorithm is somehow not a ranking decision.

Marketplaces additionally have to publish an explanation of the main parameters that determine ranking, in descending order of significance, with their relative importance, in plain and intelligible language, publicly available.

For a single-brand store this is usually a small matter. For a marketplace, or a dealer site carrying several principals, it is worth reviewing how ranking actually works before writing the description of it — those two things have a habit of diverging.

Grievances now have a clock

This is the change most likely to require new working practice rather than a code change.

A grievance officer must acknowledge receipt of a consumer complaint within forty-eight hours, give the complainant a copy of the complaint as recorded, and redress it within one month of receipt. Every e-commerce entity must also become a partner in the convergence process of the National Consumer Helpline.

The middle one is easy to skim past and is the most revealing. Handing the customer a copy of the complaint as recorded by your officer means there has to be a record, and that the customer gets to see how you wrote it down. A complaint that lives in someone’s WhatsApp thread cannot be copied to anybody.

Some context for why this section exists at all: the National Consumer Helpline received 17,71,622 grievances during 2025, of which 5,11,196 — around 29 per cent — related to e-commerce.

If complaints currently arrive by phone, on WhatsApp, and through a form nobody monitors at weekends, there is no way to show a forty-eight hour acknowledgement happened. The requirement is not really about speed. It is about having a front door that records when something arrived, who owns it, and what happened next.

Marketplace data and own-brand goods

This is the provision most widely misdescribed, so it is worth stating carefully.

A marketplace may not use information it collects for the sale of goods bearing a brand or name common with its own, by any seller, related or not. Nor to promote or advertise a seller as being associated with it — unless it has obtained express and affirmative consent from the consumers whose information it is.

Two things this is not. It is not a rule about search results favouring private labels, which is what a good deal of the commentary has claimed. And it does not prohibit marketplaces from selling own-brand goods. What it restricts is using the data the platform gathers from hosting other people’s sales to support its own brand.

One honest caveat: the consent clause sits at the end of the second limb, and whether it also cures the first is not obvious from the drafting. The Department’s own summary reads as though consent covers both. If you run a marketplace with an own-brand range, that is a question for your adviser and not one to resolve by reading an article about it.

Disclosures, invoices and imports

A cluster of smaller requirements, several of which are concrete enough to action this month.

Your own identity, displayed prominently — legal name, principal geographic address of headquarters and all branches, website details, and contact details including email, landline and mobile for both customer care and the grievance officer.
Seller name on the invoice in the same font size as yours. A one-line change to an invoice template, and a very easy one to still be non-compliant on in January because nobody was told.
Return, refund, exchange, warranty and guarantee, best-before or use-before date, delivery and shipment, cost of return shipping, payment modes — accurate and available before purchase.
Imported goods — the importer’s name and details, and the full country of origin, identified as the packaged commodities rules require.
Seller registration numbers — GST identification number or MSME registration number, where the Central Government has issued one.
Seller details after the sale — a marketplace must give a consumer, on written request after purchase, the seller’s headquarters and branch addresses, website, email and whatever else is needed to resolve a dispute directly.
Bundled fees — a marketplace may not charge users bundled fees for services unrelated to the platform, with a carve-out for loyalty and membership programmes.

In building materials that disclosure list is more work than it looks. Cost of return shipping on heavy goods is not a flat figure, and it is now named explicitly rather than left to a general policy page. Best-before genuinely applies to adhesives, grouts and sealants. Both are product data fields, and if they do not exist in your catalogue today, they have to be created and populated before anything can display them — across every SKU, not just the ones you thought of.

What to do between now and January

Turn on price history. If your platform is not retaining it, that is the first job — you cannot compute a prior price from data you did not keep, and thirty days of it need to exist before the rule does.
Audit your storefront for dark patterns, including anything a theme or plugin enabled by default, and write down what you checked and when.
Give complaints a front door that timestamps arrival, assigns an owner, and can produce a copy of the complaint for the customer.
Check which disclosure fields exist in your catalogue — return shipping cost and expiry are the two usually missing — and which have to be added.
Fix the invoice template so the seller’s name matches your own in size and prominence.
Review ranking and sponsored placement if you carry more than one brand, and write the plain-language description while you are in there.
Separate consent from terms acceptance, and record what was agreed and when.

The first item is the only one with a deadline before the deadline. Everything else can be done in December, uncomfortably. Price history cannot — a store that starts recording on 2 January has nothing to show on the day it is first asked.

Common questions

Does this apply to us if we only sell through our own website?

Yes, though not all of it. Selling your own goods through your own site makes you an e-commerce entity, so the identity display, grievance timelines, prior price rule, dark patterns audit, invoice and import requirements apply, along with accurate return, refund, warranty, expiry and return-shipping information. The provisions aimed at marketplaces — seller disclosure, ranking parameters, use of collected information, bundled fees — do not.

What counts as the prior price if a product is new?

A product with no thirty-day history has no lowest price to draw from, which is a good reason not to launch straight into a discount. The notification does not address the case directly, so take advice if it is one you will hit often.

Does a dealer-specific or logged-in price count?

The definition refers to the lowest price of the good or service in the window, without carving out particular customer groups. The safer assumption is that any price at which the goods were genuinely offered forms part of the history — and to build your records so the question can be answered either way rather than argued about later.

We use Shopify. Does it handle this?

Compare-at price is not the same thing as a prior price derived from thirty days of history, so do not assume the built-in field satisfies the requirement — it is a number someone types in, which is precisely what the rule is designed to stop. What most stores need is a record of price changes over time and a way to display the derived figure. That is a small piece of work if started now and an awkward one in December.

Is forty-eight hours the deadline for resolving a complaint?

No — forty-eight hours is for acknowledging receipt and giving the complainant a copy of the complaint as recorded. Redressal is within one month of receipt. Two different clocks, and the short one is the one most businesses will miss, because acknowledgement tends to be nobody’s specific job.

What happens if we are not ready by January?

That is a question for your adviser rather than for us. The practical point is that price history is the one thing you cannot fix retrospectively. The rest can be addressed after the date; that one cannot.

Last verified: 25 September 2026, against the Consumer Protection (E-Commerce) (Amendment) Rules, 2026 as published in the Gazette of India on 10 September 2026, and the Department of Consumer Affairs press release of the same date. This is a general explanation for businesses selling online, not legal advice.

If you sell online and want a hand working out what this means for your store, tell us where you are. More on this: which building materials actually sell online and eCommerce development.