Who the E-Commerce Rules, 2020 cover
Notified under the CPA 2019, the Consumer Protection (E-Commerce) Rules, 2020 apply to both inventory-based
e-commerce entities (which own the stock they sell) and marketplace entities (which host third-party sellers),
and extend to entities not established in India but that systematically offer goods or services to Indian
consumers. Every e-commerce entity must appoint a grievance officer, display seller details (name, address,
contact, ratings) for each listing, and disclose the country of origin of goods, along with acknowledging
consumer complaints within a prescribed period and redressing them within a set timeline from the date of
receipt, failure of which exposes the entity to both individual liability and CCPA action.
Dark patterns -- the CCPA’s 2023 guidelines
The Central Consumer Protection Authority’s Guidelines for Prevention and Regulation of Dark Patterns,
2023 identify specific manipulative UX practices as unfair trade practices, including false urgency (fake
countdown timers), basket sneaking (adding items without consent), confirm-shaming, forced continuity/hidden
subscription traps, drip pricing (hiding charges until checkout), and rank/rating manipulation. A platform
found using these can be proceeded against by the CCPA and by individual consumers.
Fake reviews and ratings manipulation
The Bureau of Indian Standards’ voluntary standard IS 19000:2022 sets out requirements for collecting,
moderating, and publishing online consumer reviews, and the CCPA treats non-compliant practices -- paid or
incentivized fake reviews, suppression of genuine negative reviews -- as an unfair trade practice enforceable
under the CPA 2019, giving consumers and the regulator a route to act even though IS 19000:2022 is itself a
standard rather than a standalone statute. For NRIs who shop on Indian e-commerce platforms or run online
businesses selling into India, these rules matter in both directions: as a buyer, the same grievance-redressal
and unfair-trade-practice remedies apply whether the purchase happens from within India or from abroad, and as
a seller or platform operator targeting Indian consumers, compliance obligations attach regardless of where
the business itself is incorporated or physically located.
Can I get a refund for a defective product bought from an overseas seller on an Indian marketplace?
Generally yes -- the E-Commerce Rules require marketplace entities to have a mechanism for consumers to
know sellers’ details and to facilitate grievance redressal, and the CPA 2019’s remedies for
defective goods apply regardless of whether the seller is based in India, so long as the transaction falls
within the Rules’ scope.
What counts as a “dark pattern” under Indian law?
The CCPA’s 2023 guidelines list specific practices -- fake urgency indicators, pre-selected paid
add-ons (basket sneaking), guilt-tripping opt-out language (confirm-shaming), hidden subscription renewals,
and manipulated rankings/reviews, among others -- as prohibited unfair trade practices under the CPA 2019.
Who do I complain to about a misleading online advertisement?
You can complain to the Central Consumer Protection Authority (CCPA), which has suo motu power to
investigate misleading advertisements and can penalize both the company and, in some cases, the endorser,
in addition to filing an individual complaint before a Consumer Commission.
