Compliance · E-commerce rules · Shopify · 25 Sep 2026
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.
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The short version
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
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.
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.
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
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".
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 stock | A marketplace | You, selling on a marketplace | A platform that buys your stock | |
|---|---|---|---|---|
| Rules that apply | 4 and 7 | 4 and 5 | 6 | The platform carries 4 and 7; you are its supplier (reading) |
| Identity and grievance officer | 4(2), 4(4), since 2020 | 4(2), 4(4), plus seller details under 5(3) | 6(4)(b), 6(4)(d), since 2020 | Platform |
| Complaint copy, 2027 | Yes | Yes | Not in rule 6(4), which was not amended | Platform |
| Helpline partner, 2027 | Yes | Yes | Reading: not bound | Platform |
| Prior price, 2027 | Yes | Yes | Reading: unsettled whether directly or through the platform | Platform |
| Self-audit and certificate, 2027 | Yes | Yes | Reading: 4(15) names "every e-commerce entity", which excludes a seller; the 2023 Guidelines still reach sellers | Platform |
| Listing information | 7(1), since 2020; best-before added 2027 | 5(3), changed 2027 | 6(5), since 2020; best-before, payment modes and an ID number added 2027 | Platform |
These are overdue today, not due in January. Most cost hours, not rupees. Walk them page by page on your own phone.
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.
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.
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.
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.
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.
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
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.
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 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.
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.
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.
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.
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
| ID | Practice | What the text says | Status in India | The EU, for comparison | Cautious course | Lawyer? |
|---|---|---|---|---|---|---|
| U1 | A time-limited cut shown against a higher "was" price | "announces a price reduction" | The plainest case; treat as covered (reading) | Covered | Show the prior price | No |
| U2 | A standing MRP strike-through, same price all year | Silent | Unsettled | Comparisons 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 Act | Yes |
| U3 | A sitewide code shown in a banner | Silent | Unsettled | A code open to all is covered | Treat as an announced cut | Yes |
| U4 | A first-order or sign-up code | Silent | Unsettled | Sign-up reductions sit outside | Treat as an announced cut | Yes |
| U5 | An automatic cart discount, "extra 10% at checkout" | Silent | Unsettled | Not checked | Treat as an announced cut | Yes |
| U6 | A combo, bundle or buy-one-get-one | Silent | Unsettled | Tied offers sit outside | Treat as an announced cut | Yes |
| U7 | A member or loyalty price | Silent | Unsettled | Loyalty schemes sit outside | Treat as an announced cut | Yes |
| U8 | A bank or card offer | Silent | Unsettled | Not checked | Treat as an announced cut | Yes |
| U9 | Subscribe-and-save | Silent | Unsettled | Not checked | Treat as an announced cut | Yes |
| U10 | A product on sale for under 30 days; perishables; step-by-step cuts | No exemption written | What prior price applies is not addressed (reading) | Member states may set other rules | Ask before the first cut | Yes |
| U11 | An offer announced in December and live on 1 January | No transition clause | Unsettled | Not applicable | Start 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 test | No |
| U13 | A deal you run on a marketplace | The rule names "the seller" as one who may announce | Whether it binds you directly is a reading; no marketplace has said how it will show prior prices | Not applicable | Keep your own record | Yes |
| ID | Question | The honest sentence | Lawyer? |
|---|---|---|---|
| U14 | The certificate: format, signer, filing, place, first date; and the certificate as a claim | No 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 |
| U15 | What the self-audit covers: site, app, ads, emails, WhatsApp | The 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 |
| U16 | The complaint copy for phone, WhatsApp or DM complaints | The 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 |
| U17 | Rule 4(1) for a proprietorship, partnership or LLP | Rule 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 |
| U18 | The invoice font rule on a one-brand store | Rule 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 |
| U19 | A one-brand store that also lists other brands, consigned or drop-shipped goods | Such a store may be a "marketplace e-commerce entity" under the 2020 definition. No source read settles where that line falls. | Yes |
| U20 | Best-before on food listings | For food, the new best-before words are "subject to" the food-safety law, whose online rule exempts dates before sale. | Yes |
| U21 | Which 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 |
| U22 | How money would follow a missing certificate, copy or partnership | The 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 |
| U23 | Where search merchandising ends; what "sponsored listing" means | The 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 |
| U24 | The COD fee | No 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 |
| U25 | Instagram-only and WhatsApp-only sellers | A 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 |
Take these to a lawyer:
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.
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.
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.
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
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.
If you want a second pair of eyes
Book a free 30-minute funnel review: we look at the numbers you have. I say where I would look first, and whether the Leak Map makes sense for you, or not yet. The 30-Day Leak Map goes deeper into where the money leaks. If you are short on time, the 3-minute version has the truth in three sentences and the thirteen checks that matter most.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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