India’s new e-commerce rules are set to make discount planning more deliberate for direct-to-consumer (D2C) brands, with companies likely to bring greater scrutiny to pricing decisions in the weeks leading up to major sales and festive events.
The Consumer Protection (E-Commerce) Amendment Rules, 2026, effective January 1, 2027, require price reductions to be benchmarked against the lowest price at which a product was offered during the preceding 30 days. The rules also introduce additional requirements around disclosures and transparency on e-commerce platforms.
For D2C brands, the changes could mean that pricing decisions made well ahead of a festive sale will influence how discounts can subsequently be communicated to consumers.
“The new pricing framework will make discount planning more deliberate. Brands will have to look beyond individual sale periods and consider how pricing decisions made in the preceding weeks affect their ability to offer and communicate discounts during key festive events. This will require closer alignment between merchandising, inventory, pricing and marketing teams,” said Akhil Jain, CEO and MD, Madame.
“Festive sales will remain important, but the emphasis could increasingly move towards building compelling product propositions and genuine value, rather than competing primarily on the depth of the headline discount,” he added.
The rules could also bring incremental operational costs for brands, particularly those selling across multiple channels and marketplaces.
“There will be some incremental operational costs for brands, particularly around maintaining accurate pricing records, ensuring consistency across channels and strengthening internal checks. However, the larger impact may be on processes and systems rather than on the direct cost of compliance,” Jain said.
He added that while marketplaces would have an important role in implementing customer-facing disclosures, brands would still need to ensure that the pricing information they provide is accurate and consistent.
“So, compliance will ultimately be a shared responsibility across the ecosystem,” Jain said.
For some D2C brands, however, the new framework may largely formalise practices they already follow.
“The new rules essentially formalise what we already treat as best practice — pricing discounts against a genuine 30-day reference price rather than an inflated ‘strike-through’ number,” said Karan Korke, Co-Founder, The Healthy Binge.
“This means tighter, more disciplined planning: we’ll need to lock in our lowest-price windows earlier and audit them more rigorously ahead of every major sale, festive season included,” he said.
Korke said the company did not expect the rules to materially increase its own compliance burden, but expected marketplaces to absorb much of the work related to search rankings, dark patterns and sponsored-listing disclosures.
The pricing requirement could also make historical price tracking more important for brands, particularly those that run promotions across several platforms.
Stella Joseph, partner, Economic Laws Practice, said the 30-day prior-price requirement makes maintaining an accurate historical record of pricing an important compliance consideration. While the amended rules do not prescribe a specific record-retention format, she said brands and marketplaces should maintain a defensible SKU-level pricing trail to demonstrate the lowest price offered during the preceding 30 days.
“In practice, D2C brands are therefore required to pay particular attention to their pricing, promotional claims and product information, while marketplaces will be responsible for the underlying platform level compliance,” she added.
She also pointed to the lack of clarity around personalised discounts, loyalty pricing, limited-user coupons, bank offers and geographically restricted campaigns. Brands, she said, would therefore need clear internal pricing policies and consistent methodologies to substantiate the prior price.
For D2C companies, the impact of the new rules could consequently extend beyond the discount displayed during a festive sale to the way brands plan, record and manage pricing in the weeks leading up to it.
Published on September 23, 2026
