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Compliance · E-commerce rules · Shopify · 25 Sep 2026

What must change on your site before 1 January 2027, and what was already the law

Most of this list has been the law since July 2020. The new part is short, and one item needs a record you start in December. Hold it against your own store.

By Rishi Jain, Fractional CMO, Agra15 min readUpdated 25 Sep 2026

Read it as3-minute version15-minute version

The short version

  • The notification of 9 September 2026 amends the E-Commerce Rules of 23 July 2020. It does not replace them. Most duties on a one-brand store have been law since 2020, and no size or MSME exemption exists.
  • New on 1 January 2027 for a one-brand store: the prior price with an announced price cut, a copy of every complaint, National Consumer Helpline partnership, a yearly dark-pattern self-audit with a displayed certificate, best-before dates where they apply, and full country names for imports. Three narrower rules cover search boosts, paid placements and invoices.
  • One item needs a record you start in December. For a cut announced on 1 January, the 30 days before run from 2 to 31 December. That is arithmetic, not a rule. Shopify keeps no usable price history. A dated daily product export is free.
  • The MRP is not banned. The rule defines neither "price reduction" nor "announces", so codes, combos and a standing strike-through are unsettled.
  • PhysicsWallah was directed to pay ₹5,00,000 on 1 June 2026 for three practices, one of them a pre-ticked ₹10 donation that broke a 2020 rule. No order against a Shopify-only brand showed up in the regulator's order list, read on 25 September 2026. Your real exposure is your own buyers.

Most of this is not new

Most of this list has been the law since 23 July 2020. A short list is new from 1 January 2027. One item needs a record you start in December.

The instrument is a seven-page gazette notification, G.S.R. 789(E), dated 9 September 2026. Its own words are "rules to amend" the Consumer Protection (E-Commerce) Rules, 2020. It comes into force on 1 January 2027, with no transition clause and no grace period, and it adds no penalty clause of its own. Some national coverage said the new rules come into force "replacing the 2020 rules". The gazette says amend, so every 2020 duty still stands.

Already law, or new on 1 January 2027?

The Consumer Protection (E-Commerce) Rules 2020 and the 2026 amendment, read side by side on 25 September 2026

Law since 23 July 2020 (overdue if missing)

  • Your store is covered at any size. Rule 2(1)(c)
  • Legal name, addresses, customer-care and grievance-officer contacts on the site. Rule 4(2)
  • A named grievance officer, with designation. Rule 4(4)
  • Acknowledge a complaint within 48 hours. Resolve within one month. Rule 4(5)
  • A ticket number for every complaint. Rule 7(1)(f)
  • No pre-ticked boxes on a purchase. Rule 4(9)
  • No one-sided cancellation fee. Rule 4(8)
  • Refunds as the RBI prescribes, in reasonable time. Rule 4(10)
  • Importer named for imported goods. Rule 4(6)
  • The returns list: return, refund, exchange, warranty, delivery, cost of return shipping, payment modes, complaint route. Rule 7(1)(a)
  • Payment methods, their security, recurring payments, fees, chargebacks. Rule 7(1)(c)
  • One total price with every charge broken out. Rule 7(1)(e)
  • No posing as a customer in reviews. Rule 7(2)
  • No refusing returns of faulty, short, fake, misdescribed or late goods. Rule 7(4)
  • Marketplace sellers: your own grievance officer; origin, importer, returns with return-shipping cost, delivery and warranties given to the platform. Rules 6(4), 6(5)
Other law already in force. Pack-label declarations on the listing, Legal Metrology, since 1 January 2018. The Dark Patterns Guidelines, 13 patterns, since 30 November 2023. A misleading "was" price is an unfair trade practice under the Consumer Protection Act 2019, since July 2020.

New or changed on 1 January 2027

  • Prior price shown with an announced price cut. New Rule 4(13)
  • A copy of the complaint as recorded, sent to the complainant. Changed Rule 4(5)
  • Helpline partnership: from "best effort" to "shall". Changed Rule 4(7)
  • Yearly dark-pattern self-audit and a displayed certificate. New Rule 4(15)
  • Best-before or use-before date added to the returns list. Changed Rule 7(1)(a)
  • Full country-of-origin name for imported goods. New Rule 4(6)(b)
  • No misleading search manipulation against the query. New Rule 4(11)(c)
  • Sponsored listings labelled. New Rule 4(12)
  • Seller's name on the invoice in the same font size as the store's. New Rule 4(14)
  • Identity block "at an appropriate place"; fax dropped. Changed Rule 4(2)
  • Marketplace sellers: best-before and payment modes named in the seller list. Changed A government ID number for display, such as GSTIN or MSME. New Rules 6(5)(d), 6(5)(j)
  • Marketplaces only: sellers inside "ranking"; seller website and email; ranking parameters "in descending order"; buyer-data and bundled-fee bars. Rules 3(1)(j), 5(3), 5(6), 5(7)

On the E-Commerce Rules: 20 duties law since 23 July 2020; 9 new and 7 changed from 1 January 2027, of which 3 bind marketplaces only and 2 bind marketplace sellers only.

Every row checked against the gazette texts of G.S.R. 462(E) and G.S.R. 789(E). Last checked 25 September 2026.

Here is what I checked. On 25 September 2026 I read the 2020 and 2026 texts side by side, clause by clause. Twenty duties have been law since 2020. Nine are new and seven are changed from 1 January 2027. Five of those 16 bind only marketplaces, sites like Amazon and Flipkart that sell other sellers' goods, or the sellers on them. The returns list for a one-brand store gained one phrase, "best before or use before date", and a proviso for food. The 2020 Rules cover "single brand retailers in single or multiple formats", with no size, turnover or MSME exemption.

How to read this list

This is not legal advice. I am a marketer who read the gazette, and each rule is quoted so you can hand it to a lawyer. "Reading" marks words that allow more than one meaning. Every item carries the year its duty began. Hours are my estimates. Last checked 25 September 2026.

The checklist

Hold this against your live store. Overdue items come first, the ones with the most complaints and orders behind them at the top. Then the 2027 items by lead time, then marketplace sellers, then the open questions. Your ticks stay in your own browser.

The checklist. Tick what your store already does.

32 items · N = overdue today · J = new or changed on 1 January 2027 · M = marketplace sellers · ticks stay in your browser

0 of 32 done

N · Do first: overdue today (15)
Rule 7(4) 2020 · Where: Settings > Policies > Return policy; Return and cancellation rules > final-sale exceptions, with these cases approved by hand · ESTIMATE: 60 minutes
Rule 4(9) 2020 · Where: cart and checkout add-on apps (shipping protection, gift wrap, donation, priority dispatch) · ESTIMATE: 60 minutes · Skip if: you run no add-on apps
Rule 7(1)(e); Dark Patterns Guidelines, drip pricing 2020 2023 Guidelines · Where: Settings > Taxes and duties > "Include sales tax in product price and shipping rate"; shipping rates; a COD-fee app (Shopify has no native COD fee) · ESTIMATE: 60 to 120 minutes
Rules 4(5), 7(1)(f) 2020 · Where: the contact form only emails the store; add a helpdesk app or an email auto-reply; link the complaint route on the order status page · ESTIMATE: 180 to 300 minutes, covers J5 too
Rule 4(2) 2020 · 2027 adds "at an appropriate place" and drops fax · Where: Settings > Policies > Legal notice (auto-linked in the checkout footer) + footer text block + Settings > Store details · ESTIMATE: 60 to 120 minutes
Rule 4(4) 2020 · Where: Online Store > Pages > "Grievance officer"; Content > Menus > footer; order status page via the checkout and accounts editor · ESTIMATE: 60 to 120 minutes
Rule 7(1)(a), 2020 text 2020 · Where: Settings > Policies > Return policy and Shipping policy, rewritten by hand (the generated policy leaves out the return rules) · ESTIMATE: 240 to 360 minutes
Rule 4(10) 2020 · Where: Orders > Refund; the gateway dashboard; refund policy text · ESTIMATE: 60 minutes
Dark Patterns Guidelines, false urgency 2023 Guidelines · Where: timer and low-stock apps · ESTIMATE: inside J3 · Skip if: you run no timer or stock apps
Legal Metrology (Packaged Commodities) Rules, rule 6(10) 2018 Legal Metrology · Where: product metafields (Settings > Custom data > Products) shown via the theme editor's "connect dynamic source"; the Vendor field cannot hold an address · ESTIMATE: 120 to 180 minutes set-up plus 2 to 5 per product; shared with N11 and J7 · Skip if: you sell no pre-packaged goods
Rule 4(6)(a) 2020 · Where: a product metafield, as N10 · ESTIMATE: shared with N10 · Skip if: you sell only goods made in India
Rule 7(2) 2020 · Where: the review app ("Verified" only from order-linked requests) · ESTIMATE: 60 to 120 minutes · Skip if: you show no reviews
Rule 7(1)(c) 2020 · Where: Settings > Policies > Terms of service (a payments section); Subscription policy if you sell subscriptions · ESTIMATE: 60 minutes
FSS (Labelling and Display) Regulations 2020, regulation 4(2) FSSAI · Where: product page text · ESTIMATE: not measured · Skip if: not a food brand
Rule 4(8) 2020 · Where: Settings > Policies > Return and cancellation rules · Reading: a COD fee kept on a cancelled order may count as a cancellation charge · Skip if: you charge no cancellation fee
J · New or changed on 1 January 2027, by lead time (11)
Prepares for rule 4(13); the record itself is not a duty and the date is arithmetic 2027 prep · Where: Products > Export, one dated CSV a day (it carries "Price" and "Compare-at price" per variant); or a price-history app, which logs only from its install day · ESTIMATE: 60 to 120 minutes to set up · Skip if: you will never announce a price cut or show a price against a higher one (reading; see U2)
Rule 4(7) 2027 changed "best effort" becomes "shall" · Where: outside Shopify, consumerhelpline.gov.in, one online form and two letterhead uploads, no fee; then one line on the grievance officer page · ESTIMATE: 30 minutes · Skip if: you sell only on marketplaces (reading)
Rule 4(15); Dark Patterns Guidelines 2027 new Guidelines in force since 30 November 2023 · Where: storefront, cart, checkout and every app that touches them; whether emails and WhatsApp flows are inside is not said · ESTIMATE: 360 to 600 minutes
Rule 4(15) 2027 new · Where: Online Store > Pages + Content > Menus > footer · ESTIMATE: 30 minutes · Reading: a footer link is the floor; "prominently" is undefined
Rule 4(5) as substituted 2027 changed these words only · Where: the helpdesk or email auto-reply from N4, quoting the complaint text · ESTIMATE: inside N4
Rule 4(13) with its Explanation 2027 new · Where: price and compare-at price fields, plus a line under the price from a metafield or a price-history app · ESTIMATE: 60 to 120 minutes · Skip if: you announce no price cuts (reading; see U2)
Rule 4(6)(b) 2027 new in these Rules; Legal Metrology already required it for imported packaged goods from 1 January 2018 · Where: a display metafield with the full country name; Shopify's customs "Country/Region of origin" field does not show on the storefront · ESTIMATE: shared with N10 · Skip if: you sell only goods made in India
Rule 7(1)(a) as substituted 2027 changed these words only · Where: a product metafield · ESTIMATE: inside N7 · Skip if: your products carry no such date
Rule 4(11)(c) 2027 new · Where: Apps > Search & Discovery > Search > Product boosts (up to 10 terms per product) · ESTIMATE: 60 minutes · Skip if: you set no boosts
Rule 4(12) 2027 new · Where: collection sort and theme badges from tags or metafields · ESTIMATE: 60 to 120 minutes · Skip if: nobody pays you for a placement (reading)
Rule 4(14) 2027 new its effect on a one-brand store is a reading · Where: an invoice app's template (Shopify makes no GST-compliant bill) · ESTIMATE: 60 to 120 minutes · Read U18 before buying anything for this
M · If you also sell on a marketplace: you are a "seller" under rule 6 (6)
Rules 6(4)(b), 6(4)(d) 2020 · Where: the marketplace seller panel
Rule 6(5)(b) to (i) 2020 · Where: the seller panel. Amazon.in made country of origin mandatory from 21 July 2020 and manufacturer and packer contact from 30 November 2023; Flipkart's listing API marks origin, manufacturer, packer and MRP mandatory
Rules 6(3), 6(2) 2020 · Where: the seller panel; your own returns handling
Rule 6(5)(d) as substituted, with the food proviso 2027 changed · Where: the seller panel
Rule 6(5)(j) 2027 new · Where: the seller panel (no display field seen on the pages that could be read) · Which number is enough is unsettled
Reading of rule 4(13) Reading · Where: your own export or sheet · Whether the rule binds you directly or only the platform is not settled

U · Unsettled. Thirteen price questions (U1 to U13) and twelve other questions (U14 to U25) have no answer in any Indian text, FAQ or order as of 25 September 2026. They are not ticks. See the table under "What is still unsettled".

Hours are my estimates. They come from no rule and no Shopify page. Ticks are saved only in this browser. Last checked 25 September 2026.

Who these rules bind

Your own store selling your own stock is an "e-commerce entity", and has been since 2020, whatever its size. On Amazon or Flipkart you are a "seller" under rule 6 instead. A store that also lists other brands or drop-shipped goods may count as a marketplace, and an Instagram-only seller may sit outside these Rules. Neither line is settled.

Who is bound by what.

Which rulebook each business is under, and which 2027 items reach it

Your own store, your own stockA marketplaceYou, selling on a marketplaceA platform that buys your stock
Rules that apply4 and 74 and 56The platform carries 4 and 7; you are its supplier (reading)
Identity and grievance officer4(2), 4(4), since 20204(2), 4(4), plus seller details under 5(3)6(4)(b), 6(4)(d), since 2020Platform
Complaint copy, 2027YesYesNot in rule 6(4), which was not amendedPlatform
Helpline partner, 2027YesYesReading: not boundPlatform
Prior price, 2027YesYesReading: unsettled whether directly or through the platformPlatform
Self-audit and certificate, 2027YesYesReading: 4(15) names "every e-commerce entity", which excludes a seller; the 2023 Guidelines still reach sellersPlatform
Listing information7(1), since 2020; best-before added 20275(3), changed 20276(5), since 2020; best-before, payment modes and an ID number added 2027Platform
No size, turnover or MSME exemption exists. A store that also lists other brands, consigned or drop-shipped goods may be a marketplace: unsettled. Instagram-only or WhatsApp-only sellers: the Consumer Protection Act reaches you; whether these Rules do is unsettled. Last checked 25 September 2026.

Do these first: the 2020 duties

These are overdue today, not due in January. Most cost hours, not rupees. Walk them page by page on your own phone.

Your returns page

Search your return policy for "no returns", "final sale" and "exchange only". Shopify's generated policy leaves out the return rules you set, and a "final sale" setting blocks self-serve returns for every reason, damaged goods included. The final-sale trap.

It comes first because refund or replacement refused "as per policy" drew 61,056 complaints to the National Consumer Helpline in 2025. That is the third-largest e-commerce category, out of about 5.11 lakh. The 2020 rule: a store may not "refuse to refund consideration, if paid, if such goods or services are defective, deficient spurious", not as described, or late.

Write those five cases into the policy as named exceptions, and approve such returns by hand. Rewrite the policy to the 2020 list: return, refund, exchange, warranty, delivery, cost of return shipping, payment modes and how to complain. State the real refund time per payment mode, cash on delivery (COD) included, and keep proof of every refund. About 6 to 8 hours, estimate.

Your cart and checkout

Add a product on your phone, go to the last checkout step, and pick COD. Add-on apps for shipping protection, gift wrap and donations can default to ticked. A COD fee from an app can appear only at the last step. Two conditions: the ticked box, and the last-step surprise.

The 2020 rule: "no such entity shall record such consent automatically, including in the form of pre-ticked checkboxes". A second 2020 rule asks for one total price with every charge broken out. Untick every paid add-on. Switch on "Include sales tax in product price and shipping rate". Show delivery and any COD fee as their own lines before the buyer picks COD, and name the fee in your terms. About 3 to 4 hours, estimate. No rule bans a COD fee, but the Minister called extra COD charges a dark pattern in October 2025, and a fee shown only at the last step is the risk.

Count the taps from your homepage to your legal name, full address, landline, mobile and the grievance officer's name. Settings > Policies has no type for a grievance officer or a contact block, and a policy shows in the storefront footer only if you add it to a menu. So who you are can end up buried, or nowhere. I call it the three-hop contact page.

The 2020 rule asks for the "e-mail address, fax, landline and mobile numbers of customer care as well as of grievance officer". It also asks for the officer's "name, contact details, and designation" on the site. Put one identity block in Settings > Policies > Legal notice, which auto-links in the checkout footer. Add a two-line version to the footer. Add a Grievance Officer page, linked from the footer and the order status page. About 2 to 4 hours, estimate. From 2027 the block must sit "at an appropriate place", and fax is dropped.

Your complaint desk

Send a complaint through your own contact form, then wait. Shopify's form "sends all submissions to your store's sender email address". Its help page describes no acknowledgement and no reference number. The silent ticket.

The 2020 rule: the grievance officer "acknowledges the receipt of any consumer complaint within forty-eight hours and redresses the complaint within one month". A second rule asks for "a ticket number for each complaint lodged". One month, not 30 days. A helpdesk app, or a plain email auto-reply that sends a ticket number at once, does it. In December the same auto-reply gains the complaint copy. About 3 to 5 hours, estimate.

Your product pages

Open one imported product, one packaged product, your review widget and any timer. Shopify's "Vendor" field cannot carry an address, and one timer app sells "evergreen" countdowns where each visitor gets a fresh clock.

Three laws meet here. Legal Metrology has required the pack-label declarations on the listing since 1 January 2018: maker, packer or importer name and address, generic name, net quantity, MRP inclusive of taxes, country of origin for imports. The 2020 Rules ask for the importer's details, and say no store shall "falsely represent itself as a consumer and post reviews". The 2023 Guidelines bar false urgency. Put the declarations in product metafields, extra fields your theme can show on the page, as text and not only inside images. Keep timers and stock counts true. Show "Verified" only on reviews from orders. About 2 to 3 hours to set up, then 2 to 5 minutes per product, estimate.

New on 1 January 2027, in order of lead time

Start a price record by 1 December

Open any product's price fields, then Settings > activity log. Shopify has "only two fields for product price: the price, and compare-at price", and compare-at is Shopify's "was" price box. Shopify does not check it against any past price. The activity log shows "A maximum of 250 results" and "The information can't be exported". The store with no price memory.

The new rule, in full: "Where an e-commerce entity or the seller announces a price reduction for any goods or services on its platform, it shall indicate the prior price of such goods or services along with reduced price." Its explanation: "'prior price' means the lowest price of a good or service thirty days prior to the announcement of price reduction." The government's press release of 10 September reads that as the lowest price "during the 30 days preceding the announcement".

The arithmetic: for a cut announced on 1 January 2027, the 30 days before run from 2 to 31 December 2026. The rule sets no record duty and no start date. 1 December is arithmetic, with a day to spare.

The free route: Products > Export, one dated file a day, kept for 30 days or more. The exported file carries "Price" and "Compare-at price" for every variant. Keep a dated list of every discount code beside it. The app route: price-history apps from $4.99 to $16.99 a month, at list prices on 25 September 2026, and none says it can rebuild prices from before installation. The rule has no transition clause. If a December sale will still run on 1 January, start the record 30 days before you announce that sale.

What the prior-price line looks like

The rule asks for the prior price "along with reduced price" and prescribes no wording, size or placement. If you charged the MRP on every day of the 30 days before the cut, the MRP is your prior price. If you sold lower on any of those days, the lowest of those prices is your prior price, on the government's reading.

The second case has a name: the everyday sale. An MRP struck through above a price you charge every day. On the government's reading the prior price is that everyday price, so the saving you can show is zero. That claim was already risky under the Consumer Protection Act 2019, which bars misleading the public about the price at which goods "have been or are, ordinarily sold". Whether a standing strike-through "announces a price reduction" at all is unsettled. The MRP itself is not banned.

The prior-price line, two ways.

Example numbers. Same product, same MRP, one difference: what the store charged in the 30 days before a 1 January offer

Card 1 · sold at the MRP every day of the 30 days before the offer

Cotton kurta (example)

₹1,199 ₹1,499 20% OFF

Inclusive of GST. Delivery and any COD fee are shown before you pay.

Lowest price in the 30 days before this offer: ₹1,499

Prior price = the MRP, because the MRP of ₹1,499 was charged on every day from 2 to 31 December. (1,499 minus 1,199) divided by 1,499 = 20 per cent.

Card 2 · never sold at the MRP in the 30 days (the everyday sale)

Cotton kurta (example)

₹1,199 ₹1,499

Inclusive of GST. Delivery and any COD fee are shown before you pay.

Lowest price in the 30 days before this offer: ₹1,199

The store charged ₹1,199 every day, so the prior price is ₹1,199 and there is no cut to announce. If it sold at ₹1,099 on even one day of the window, the prior price becomes ₹1,099, on the government's reading: below today's price, so there is no saving to claim. Whether a standing MRP strike-through is itself an announced cut is unsettled.

The rule asks for the prior price "along with reduced price" and prescribes no wording, size or placement. This is one way to show it, not the only way. The MRP is not banned. Last checked 25 September 2026.

Join the National Consumer Helpline

The 2020 text said a store "shall endeavour on a best effort basis to become a partner". The 2027 text says it "shall become a partner in the convergence process of the National Consumer Helpline". A partner gets the helpline's complaints about it sent straight to it, and answers them on the helpline's portal. One online form at consumerhelpline.gov.in, which asks for a company number only "if registered", plus two uploads on your letterhead. No fee. 1,853 companies were partners on 12 August 2026. Approval time is not published, so apply in October. Half an hour, estimate.

Run the self-audit before you sign the certificate

The new rule binds every e-commerce entity to the Dark Patterns Guidelines of 2023, and then says it shall "conduct yearly self-audit to ensure that its platform is free from dark patterns and a certificate to this effect shall be displayed prominently". That is all it says about the audit. A dark pattern is a design that tricks the buyer into something he did not choose. No format, no auditor, no filing and no first due date are set, and "prominently" is defined nowhere. The Guidelines themselves have applied since 30 November 2023 and name 13 patterns. By 12 August 2026, 31 companies had filed statements that their platforms are free of dark patterns, brand-owned stores among them.

Walk your store, cart, checkout and every app against the 13 patterns. Keep dated screenshots. Fix what you find. Only then publish the certificate page and link it from every footer. About 6 to 10 hours, estimate. A certificate is a public statement that your platform is free from dark patterns. If you publish it while a pre-ticked add-on is still live, the statement is untrue. A certificate signed before the check-up is worse than none.

Four smaller changes

Complaint copy: from 2027 the grievance officer "provides the complainant with a copy of the complaint as recorded by the grievance officer". Add the complaint text to your auto-reply. Country of origin: for imported goods, the full country name, not a two-letter code, from a display metafield. Best-before: where a product carries such a date, the listing shows it. Food brands ask first, because the words are "subject to" the food-safety law. Search, sponsored, invoice: three rules written for marketplaces but binding every store. On my reading, on a one-brand store they bite only if a search boost misleads against the query, someone pays you for a slot, or your invoice names a seller other than you.

If you also sell on Amazon or Flipkart

You are a "seller" under rule 6, which has applied since 2020. Already law: your own grievance officer, and giving the platform country of origin, importer details, return terms with the cost of return shipping, delivery details and warranties. New in 2027: the best-before date, named beside the expiry date you already had to give, the modes of payment, and a government ID number for display, such as a GSTIN or MSME number. Keep your own dated price record for every deal, because whether the prior-price rule binds you directly or only the platform is a reading.

What is still unsettled, and what to ask a lawyer

The rule defines neither "price reduction" nor "announces", and no Indian guidance existed as of 25 September 2026. The cautious course: treat any price shown against a higher price as an announced cut, and ask a lawyer about codes and combos.

What is not settled, as of 25 September 2026.

Part 1: thirteen price questions · Part 2: twelve other questions · the EU column is for comparison only, it is not Indian law

IDPracticeWhat the text saysStatus in IndiaThe EU, for comparisonCautious courseLawyer?
U1A time-limited cut shown against a higher "was" price"announces a price reduction"The plainest case; treat as covered (reading)CoveredShow the prior priceNo
U2A standing MRP strike-through, same price all yearSilentUnsettledComparisons with a recommended retail price sit outside (analogy only)The prior price you would show is your everyday price; a misleading "was" price was already risky under the ActYes
U3A sitewide code shown in a bannerSilentUnsettledA code open to all is coveredTreat as an announced cutYes
U4A first-order or sign-up codeSilentUnsettledSign-up reductions sit outsideTreat as an announced cutYes
U5An automatic cart discount, "extra 10% at checkout"SilentUnsettledNot checkedTreat as an announced cutYes
U6A combo, bundle or buy-one-get-oneSilentUnsettledTied offers sit outsideTreat as an announced cutYes
U7A member or loyalty priceSilentUnsettledLoyalty schemes sit outsideTreat as an announced cutYes
U8A bank or card offerSilentUnsettledNot checkedTreat as an announced cutYes
U9Subscribe-and-saveSilentUnsettledNot checkedTreat as an announced cutYes
U10A product on sale for under 30 days; perishables; step-by-step cutsNo exemption writtenWhat prior price applies is not addressed (reading)Member states may set other rulesAsk before the first cutYes
U11An offer announced in December and live on 1 JanuaryNo transition clauseUnsettledNot applicableStart the record 30 days before that offer is announced (arithmetic)Yes
U12"Thirty days prior": a window or a single day?"thirty days prior to the announcement"The press release reads a window; the text does not say "during""not shorter than 30 days prior to the application"Use the window: the lowest of 30 daily prices is never above any one of them, so it is the stricter testNo
U13A deal you run on a marketplaceThe rule names "the seller" as one who may announceWhether it binds you directly is a reading; no marketplace has said how it will show prior pricesNot applicableKeep your own recordYes
IDQuestionThe honest sentenceLawyer?
U14The certificate: format, signer, filing, place, first date; and the certificate as a claimNo format has been published. The rule names no auditor, no filing and no first due date. "Prominently" is not defined. The certificate is a public statement that your platform is free from dark patterns; if a pre-ticked add-on is still live, that statement is untrue.Yes
U15What the self-audit covers: site, app, ads, emails, WhatsAppThe rule's word is "platform", which the 2020 Rules define as a website or an app. It does not say whether ads, emails or WhatsApp flows fall inside. The Guidelines themselves already reach advertisers and sellers.Yes
U16The complaint copy for phone, WhatsApp or DM complaintsThe rule does not say how the copy is sent, or when, or what "as recorded" means for a complaint made by phone, WhatsApp or direct message.No, but test the process
U17Rule 4(1) for a proprietorship, partnership or LLPRule 4(1) says an e-commerce entity shall be a company and name a nodal officer resident in India. The Rules do not say how a proprietorship, partnership or LLP store meets this. A 2020 question, not a 2027 one.Yes
U18The invoice font rule on a one-brand storeRule 4(14) is written for a platform that sells other people's goods. The text does not say what it asks of a store whose seller and platform are the same company.Low stakes
U19A one-brand store that also lists other brands, consigned or drop-shipped goodsSuch a store may be a "marketplace e-commerce entity" under the 2020 definition. No source read settles where that line falls.Yes
U20Best-before on food listingsFor food, the new best-before words are "subject to" the food-safety law, whose online rule exempts dates before sale.Yes
U21Which ID number meets rule 6(5)(j)The rule asks for "any identification number issued by the Central Government including" a GSTIN or an MSME number. It does not say whether one number is enough, or whether a PAN-only seller meets it.Yes
U22How money would follow a missing certificate, copy or partnershipThe Rules carry no penalty of their own. So far the regulator has fined breaches as misleading advertisements. No order yet shows how these new duties would be penalised, because they start on 1 January 2027.No
U23Where search merchandising ends; what "sponsored listing" meansThe rule bars misleading manipulation "having regard to the search query of the user" and does not ban boosting. "Sponsored listing" is not defined. On a one-brand store it matters where someone pays for a placement.Only if someone pays you for placement
U24The COD feeNo rule bans a COD fee. The Minister called extra COD charges a dark pattern in October 2025. No order on COD fees was found. A fee shown only at the last step is the drip-pricing risk.No: show it before the buyer picks COD
U25Instagram-only and WhatsApp-only sellersA district commission in Kollam held in July 2026 that the Consumer Protection Act reaches an Instagram seller. Whether these Rules treat such a seller as an "e-commerce entity" is not settled in any source read.Yes
"Unsettled" means no Indian text, FAQ or order answers it as of 25 September 2026. The EU column comes from Directive 98/6/EC article 6a and the Commission's 2021 guidance; it is a comparison, not Indian law.

Take these to a lawyer:

  • Do my codes, combos, member prices and standing MRP strike-through count as announced cuts?
  • What do I show on an offer that runs from December into January?
  • My business is a proprietorship, partnership or LLP. How do I meet rule 4(1), which says an e-commerce entity shall be a company with a named contact who lives in India? A 2020 question.
  • Does listing other brands make me a marketplace?
  • What does my certificate say, and what does it cover?

The table above marks which other rows need one. A legal name, an address, a phone number, a named grievance officer, a true returns page, unticked boxes and a price record need no lawyer.

Last checked 25 September 2026

This page changes when a Department FAQ or certificate format, a deferral in the gazette, the first order under the prior-price rule, a marketplace notice on prior prices, or a native price-history feature in Shopify lands. Each update gets a dated line here.

What enforcement looks like at your size

The Rules carry no penalty of their own. Rule 8 says the Consumer Protection Act 2019 "shall apply for any violation of the provisions of these rules". So far the regulator, the Central Consumer Protection Authority (CCPA), has written its money penalties as misleading advertisements under section 21 of the Act. That is the regulator's choice, not a rule.

The order worth reading is against PhysicsWallah Limited, dated 1 June 2026, taken up on the regulator's own motion. Three practices: a pre-selected ₹10 "Donate for PW Foundation" option, "free" courses gated behind a mobile number and email, and guilt messaging, shown when a buyer clicked "Know More", that nudged him to keep the donation. The pre-selection ran from 14 February 2024 to 24 December 2025 and collected about ₹2.47 crore from more than 21,36,962 users, as the company itself admitted. The order rests on the 2020 rule against pre-ticked boxes and the 2023 Guidelines. The company was "directed to pay a penalty of ₹ 5,00,000", and removing the pre-selection after the notice "cannot absolve" it, the order says.

At your size: in pages 1 to 5 of the regulator's published order list, read on 25 September 2026, no order names a Shopify-only brand. Fines on smaller online sellers ran from ₹50,000 to ₹2 lakh in 2024 and 2025. Your real exposure is your own buyers. The helpline forwards complaints to partner companies, and a buyer can file where he lives or works, within two years. In Kollam, an Instagram boutique that never delivered a ₹1,880 dress and ignored the notice was ordered to pay ₹1,880 plus ₹25,000 compensation plus ₹10,000 costs, heard without it.

When there is nothing to fix

If you sell only goods made in India, skip the country-of-origin name, the importer line and the July 2027 origin filter. If you never announce a price cut and never show a price against a higher one, the prior-price line does not arise. If nobody pays you for a placement, the sponsored label is not your problem. Timers and stock counts that tell the truth can stay. No rule bans the MRP. Nobody needs a CA-signed certificate, a paid helpline membership or a "compliance stack". And nobody skips by size: a ₹1 crore store and a ₹50 crore store carry the same list.

The dates next door

Data protection: the first DPDP rule starts on 13 November 2026, and it is not a store deadline. The core duties start on 13 May 2027. Legal Metrology: the country-of-origin filter for imported goods runs from 1 July 2027, moved from 1 July 2026 by a second notification. WhatsApp: eligible accounts billed in India move to rupee billing by 31 December 2026, which is platform billing, not law.

The dates, in one line.

Solid = law in force · dashed = arithmetic · grey = not a store deadline, or not law

  • 1 January 2018Pack-label declarations must appear on online listings (Legal Metrology rule 6(10)).
  • 23 July 2020The Consumer Protection (E-Commerce) Rules come into force. Most of the checklist dates from here.
  • 30 November 2023The Dark Patterns Guidelines, 13 named patterns.
  • 5 June 2025The regulator advises platforms to self-audit for dark patterns. Advice, not a rule.
  • 9 September 2026G.S.R. 789(E) notified: the amendment.
  • 13 November 2026DPDP: the consent-manager rule starts. Not a store deadline.
  • 1 December 2026Start the dated price record. Arithmetic on the 30-day rule, not a date in it.
  • 31 December 2026WhatsApp: eligible accounts billed in India move to rupee billing. Platform billing, not law.
  • 1 January 2027G.S.R. 789(E) in force. The new duties start.
  • 13 May 2027DPDP: notice, security, breach, retention and a named contact.
  • 1 July 2027Legal Metrology: a country-of-origin filter for imported goods, moved from 1 July 2026 by a second notification.
Each date is taken from its own instrument: G.S.R. 462(E), the Guidelines gazette, the advisory, G.S.R. 789(E), G.S.R. 846(E), G.S.R. 312(E), the Legal Metrology (Packaged Commodities) Rules 2011, and Meta's pricing page. 1 December is arithmetic. Last checked 25 September 2026.

What I would do between now and 1 January

This week, free, all 2020 law: the returns exceptions, unticked add-ons, tax-inclusive prices with delivery and COD as their own lines, the identity block, the grievance officer page, a ticket-number auto-reply. October: the helpline form, because approval time is unknown. The self-audit and the fixes. By 1 December: the dated daily export. December: the prior-price line on the product template, the complaint copy in the auto-reply, the certificate page after the fixes, full country names for imports. 1 January: go live. Keep exporting. Total, estimate: about 32 to 54 hours of one-time work for a 100-product store. The hours are mine, not sourced.

The takeaway: most of this list has been overdue since 2020, so fix it this week. The new list is short. Start the price record by 1 December.

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Questions people ask

What are the new e-commerce rules in India from 1 January 2027?

G.S.R. 789(E), dated 9 September 2026, amends the 2020 E-Commerce Rules from 1 January 2027. New for a one-brand store: the prior price with an announced cut, a copy of every complaint, helpline partnership, a yearly self-audit with a displayed certificate, best-before dates where they apply, full country names for imports, and three narrower rules on search, paid placements and invoices. Most of the checklist has been law since 23 July 2020.

Do the e-commerce rules apply to my own Shopify store?

Yes, since 2020. The 2020 Rules cover "single brand retailers in single or multiple formats". Neither text has a size, turnover or MSME exemption. A marketplace seller carries rule 6 instead.

What is the 30-day prior price rule?

When you announce a price cut, you must show the prior price next to the reduced price. The rule defines it as "the lowest price of a good or service thirty days prior to the announcement of price reduction". The government's press release reads that as the lowest price during the 30 days before.

Are MRP strike-throughs banned from 2027?

No rule bans showing the MRP. If you charged it on every day of the 30 days before a cut, it is your prior price. If you sold lower on any day, the lowest price is, on the government's reading. Whether a standing strike-through counts as an announced cut is unsettled.

Does a coupon or first-order code count as a price reduction?

Unsettled. The rule defines neither "price reduction" nor "announces", and no Indian guidance existed as of 25 September 2026. Treat any price shown against a higher price as an announced cut, and ask a lawyer about codes and combos.

Is Shopify's compare-at price enough to comply?

No. The compare-at price is a number someone typed, and Shopify does not check it against past prices. Its activity log stops at 250 entries and cannot be exported. Keep a dated daily product export, or install a price-history app at least 30 days before your first cut.

Is there a format for the dark pattern self-audit certificate?

No format, signer, filing or first due date had been published as of 25 September 2026. The rule says "self-audit" and names no outside auditor. Audit your store against the 13 named patterns, fix what you find, keep dated screenshots, and only then display the certificate.

Is a "no return, no exchange" policy legal in India?

Not for goods that are faulty, short of what was promised, fake, not as described or late, and that has been the rule since 2020. An exchange-only policy for a change of mind is lawful if disclosed. No rule found gives a buyer the right to return goods that match their listing.

What changes for sellers on Amazon and Flipkart in 2027?

Little. Country of origin, importer details, return terms with return-shipping cost, delivery details and warranties have been seller duties since 2020. New from 1 January 2027: the best-before date, named beside the expiry date you already give, payment modes, and a government ID number for display, such as a GSTIN or MSME number.

What is the penalty for breaking the e-commerce rules?

The Rules carry no penalty of their own. Breaches are judged under the Consumer Protection Act 2019. So far the regulator has framed them as misleading advertisements under section 21(2), whose ceiling is ₹10 lakh for a first breach. PhysicsWallah was directed to pay ₹5,00,000 on 1 June 2026 for three practices.

Sources

  1. Gazette of India Extraordinary No. 721, G.S.R. 789(E), Consumer Protection (E-Commerce) (Amendment) Rules 2026, 9 Sep 2026
  2. G.S.R. 462(E), Consumer Protection (E-Commerce) Rules 2020, 23 Jul 2020
  3. Consumer Protection Act 2019, Gazette of India, 9 Aug 2019
  4. PIB release 2308759 on the amendment, 10 Sep 2026
  5. Guidelines for Prevention and Regulation of Dark Patterns 2023, CCPA, 30 Nov 2023
  6. CCPA advisory on self-audit by e-commerce platforms for dark patterns, 5 Jun 2025
  7. Legal Metrology (Packaged Commodities) Rules 2011, Maharashtra Legal Metrology copy amended to 23 Jun 2017, in force 1 Jan 2018
  8. G.S.R. 312(E), Legal Metrology (Packaged Commodities) Second Amendment Rules 2026, 27 Apr 2026
  9. FSS (Labelling and Display) Regulations 2020, FSSAI compendium, 23 Sep 2021
  10. CCPA order, PhysicsWallah Limited, Case CCPA-2/94/2025-CCPA, 1 Jun 2026
  11. CCPA order, Wolte Marketing, 18 Jul 2025
  12. CCPA order, Enroots Horizon, Case CCPA-2/59/2024-CCPA, 7 Nov 2025
  13. CCPA published orders list, pages 1 to 5, read 25 Sep 2026
  14. District Consumer Commission, Kollam, C.C. 439/2025, 17 Jul 2026
  15. Lok Sabha Unstarred Question 4041, 12 Aug 2026
  16. Lok Sabha Unstarred Question 890, 4 Feb 2026
  17. National Consumer Helpline, Convergence Programme, read 25 Sep 2026
  18. National Consumer Helpline, convergence partner registration and company undertaking, read 25 Sep 2026
  19. Directive 98/6/EC, article 6a, consolidated text of 28 May 2022
  20. European Commission guidance on article 6a, 29 Dec 2021)
  21. Shopify Help Center, European Price Indication Directive, read 25 Sep 2026
  22. Shopify Help Center, activity logs, read 25 Sep 2026
  23. Shopify Help Center, using CSV files for products, read 25 Sep 2026
  24. Shopify Help Center, adding store policies, read 25 Sep 2026
  25. Shopify Help Center, return and cancellation rules, read 25 Sep 2026
  26. Shopify Help Center, adding a contact page, read 25 Sep 2026
  27. Shopify Help Center, product details and displaying metafields, read 25 Sep 2026
  28. Shopify Help Center, Search & Discovery: modifying search results, read 25 Sep 2026
  29. Shopify Help Center, including taxes in prices, manual payment methods and GST in India, read 25 Sep 2026
  30. Shopify App Store listings for price-history, COD-fee, timer, stock and shipping-protection apps, read 25 Sep 2026
  31. Judge.me Help Center, verified reviews, read 25 Sep 2026
  32. Razorpay refunds documentation, read 25 Sep 2026
  33. Amazon.in Seller Forums, "New mandatory fields for your listings", Nov 2023
  34. Flipkart Seller Listing API v3 reference, read 25 Sep 2026
  35. Meta for Developers, pricing on the WhatsApp Business Platform, read 25 Sep 2026
  36. AJIO Commerce seller FAQ, read 25 Sep 2026
  37. LiveLaw-hosted print of PIB release 2308759, 14 Sep 2026
  38. DPDP Rules 2025 (G.S.R. 846(E), 13 Nov 2025), reproduction
  39. Consumer Protection Act 2019, section 2(47), Indian Kanoon copy, read 25 Sep 2026
  40. The Tribune, "Govt launches probe into e-commerce platforms over extra charges", Oct 2025
  41. Outlook Business (PTI), "New e-commerce rules could add compliance load for small sellers", 12 Sep 2026
Rishi Jain
Rishi Jain

Fractional CMO in Agra for founder-led D2C brands and manufacturers building their own brand. Ran a factory before running marketing, so he reads a business from both sides of the table. How he works · Book a free 30-minute funnel review.

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