GuideRule 4(15) · Applicability · Updated 5 October 2026
Does Rule 4(15) apply to my online store?
From 1 January 2027, every e-commerce entity must self-audit for dark patterns each year and display a certificate. Whether that's you depends on how you sell, not how big you are. Here is how the 2020 Rules draw the line, in five questions.
01The short answer
If you sell to consumers from a website or app you run, yes
The Consumer Protection (E-Commerce) Rules, 2020 apply to goods and services bought or sold over a digital or electronic network, including digital products, under every model: marketplaces, inventory sellers, and single-brand retailers selling from their own site.
An e-commerce entity is anyone who owns, operates or manages a digital platform for e-commerce. Size doesn't matter: there is no turnover threshold. A D2C brand on Shopify or WooCommerce is an e-commerce entity for its own store.
02Five questions
Work through these in order
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Do you sell goods or services, including digital products, to consumers in India?
No, only to businesses: consumer protection law protects consumers, so a purely business-to-business platform may fall outside it. That's a question for your counsel.
Yes: go on. -
Do you sell through a website or app that you own, operate or manage?
Yes: that includes a Shopify, WooCommerce or custom store, an app, or a booking site. You are an e-commerce entity for it, so Rule 4, including the Rule 4(15) self-audit, applies.
No: go to question 3. -
Do you sell only through someone else's marketplace?
The definition of e-commerce entity excludes a seller offering goods or services on a marketplace. If you sell only on Amazon, Flipkart, Myntra or Meesho, the marketplace self-audits its platform. Your own duties as a seller are in Rule 6, such as displaying your GSTIN or MSME registration number (Rule 6(5)(j)). If you also run your own store, Rule 4(15) applies to that store.
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Are you based outside India?
The Rules also apply to an entity not established in India that systematically offers goods or services to consumers in India.
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Are you an individual selling occasionally?
The Rules don't apply to a natural person acting in a personal capacity, outside any professional or commercial activity carried on regularly or systematically. A side business that sells regularly is a commercial activity.
03Grey areas
Cases the text doesn't settle
- Instagram and WhatsApp selling. If orders and payments run through a catalogue site or checkout you manage, treat yourself as covered. Pure direct-message selling is less clear: ask counsel.
- A store and a marketplace presence. The self-audit covers your own platform. Your marketplace listings fall under the marketplace's audit and your Rule 6 duties.
- A website plus an app. Both are your platform. Examine both, or say plainly in your statement which one you didn't.
04If it applies
What it means in practice
Rule 4 applies to every e-commerce entity. Marketplaces also pick up Rule 5; inventory sellers, Rule 7. In practice:
- Run a self-audit against the thirteen patterns and the duties: the checklist has every item.
- Publish your statement before 1 January 2027: see the sample statement.
- Repeat it every year, and after big changes to checkout.
Two-minute start. The free store check reads your public pages and shows which required details we could find, and which features are worth testing.
General information, not legal advice. Whether a rule binds your business is a question for your counsel.