How new e-commerce rules could reshape brands' online advertising strategies

India's new e-commerce rules could change how brands advertise discounts, plan promotional campaigns and buy visibility on digital marketplaces, as stricter requirements around reference pricing and sponsored listings push advertisers to reconsider how they communicate value to consumers.

The Consumer Protection (E-Commerce) (Amendment) Rules, 2026, which come into effect on January 1, 2027, introduce greater transparency around paid product placements, search rankings and promotional pricing. Among the most consequential changes for advertisers is the new definition of "prior price", which requires advertised price reductions to be referenced against the lowest price at which a product or service was offered during the preceding 30 days.

The changes come as India's commerce advertising market continues to expand. WPP Media's June 2026 midyear forecast projects commerce advertising revenue at $3.9 billion, or approximately ₹34,700 crore, this year, representing 29% year-on-year growth. The broader category includes advertising on digital marketplaces and quick-commerce platforms.

Brand economics

For brands and their marketers competing for consumer attention in this growing market, the new requirements could make the distinction between paid visibility, promotional claims and actual consumer value increasingly important.

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Rahul Vengalil, CEO and Co-founder of tgthr, believes the prior-price requirement could have a tangible impact on how brands structure and advertise discounts.

"Those gimmicks will definitely change," he said, referring to the practice of raising reference prices before advertising steep reductions. From a consumer's perspective, he added, "if there is a discount, then there is an actual discount."

The requirement could make promotional pricing more transparent by giving consumers a clearer reference point against which to assess advertised savings. For advertisers, it raises questions about how discounts are calculated, presented and communicated across successive campaigns.

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Vishal Pundir, VP, Strategy & Operations, Electronics Mart India Limited, expects the change to require greater discipline in promotional planning, particularly in price-sensitive categories such as consumer electronics.

"Since the prior price will be defined as the lowest price offered during the preceding 30 days, retailers will need stronger price governance and better coordination between everyday pricing, platform promotions and festive events," he said.

Pundir does not expect discount-led sales to lose their importance, but anticipates a shift towards more structured promotions and longer planning horizons.

"In the long run, this can shift the conversation from headline discount percentages to genuine value—price, exchange benefits, financing, bundles and after-sales service," he added.

The implications extend beyond individual campaigns to the broader pricing strategies that underpin them.

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Nitin Kosari, Business Head – eMarkets, LS Digital, said the bigger change would be in how brands approach pricing architecture and promotional planning, rather than simply modifying advertising creatives.

"With a 30-day prior-price reference, brands will have to look at the entire price and promotion journey leading into the event, including the depth, frequency and sequencing of offers," he said.

Kosari expects this to encourage brands to look beyond discount-led growth and consider bundles, differentiated packs, loyalty propositions and product innovation as part of their broader commerce strategies.

A growing e-commerce ecosystem

The potential impact extends across a rapidly expanding online retail ecosystem. Redseer Strategy Consultants projects India's online retail market will exceed $90 billion in 2026, growing 22–24% year on year. Amazon India announced in September that its seller base had crossed 20 lakh, while Meesho reported 264 million annual transacting users, 2.67 billion placed orders and 9.61 lakh active sellers in FY26.

Together, these figures illustrate the scale of online commerce across established marketplaces and value-focused platforms, even as quick-commerce players such as Blinkit, Zepto and Swiggy Instamart expand the ways consumers discover and purchase products.

For D2C brands, the new requirements could influence how value is communicated to consumers across these increasingly diverse shopping environments.

Swagatika Das, CEO and Co-founder, Nat Habit, said brands would need to examine their pricing and offerings with closer attention to the preceding 30 days.

"For us, it is about being able to communicate value more transparently, which Nat Habit has been doing since Day 1. The consumers will not only rely on a higher percentage of discount, and festive campaigns will continue to run their course, but it is about bundling relevant offerings and curating routines and value-centric propositions rather than a steeper discount," she said.

Greater price transparency, she added, could help brands build credibility beyond individual promotional events.

While the pricing provisions could require changes to campaign planning, the rules also introduce greater transparency around the paid visibility that drives product discovery on e-commerce platforms. Sponsored listings must be clearly and prominently identified, while marketplaces are required to explain the principal parameters determining product and seller rankings and their relative importance.

Industry executives, however, do not necessarily expect these requirements to fundamentally change how brands purchase retail-media inventory.

Pundir said the impact would be more about formalising and institutionalising existing practices than changing how Electronics Mart buys visibility.

"We will increasingly look at paid visibility as part of a broader performance equation rather than simply buying placement," he said, adding that ROI, conversion and incremental sales would become more important metrics for evaluating retail-media expenditure.

Das similarly expects greater transparency and accountability rather than a fundamental change in media-buying strategies.

"At Nat Habit, we see visibility as just the first step. A paid placement may bring a consumer to a product, but what matters next is whether the product is relevant, delivers a good experience and earns the consumer's trust," she said.

The operational implications of the amendments, meanwhile, could extend well beyond marketing departments.

Legally speaking

Aakanksha Munjhal, Partner, Saikrishna & Associates, identified the prior-price requirement as potentially having the greatest operational impact, with businesses needing robust historical pricing records and audit trails to substantiate promotional claims.

"Businesses therefore need robust pricing records and audit trails, with marketing teams working closely with legal, compliance and technology teams on promotional campaigns," she said.

Responsibility for compliance would also need to be clearly established between marketplaces and sellers. While platforms are responsible for sponsored-listing disclosures and search rankings, sellers remain responsible for pricing and product claims, Munjhal explained.

Alay Razvi, Managing Partner, Accord Juris, said responsibility could rest with both the marketplace and the brand or seller, depending on who made the relevant representation and controlled the conduct.

"Brands should audit the price data supporting promotions, verify that reference prices reflect the required 30-day history, and review marketplace advertising agreements," he said.

Both platforms and advertisers should also preserve pricing histories, campaign approvals and supporting documentation ahead of the January 2027 implementation deadline.

For India's expanding commerce advertising ecosystem, the amendments could therefore have implications beyond how discounts and sponsored listings appear on a shopping interface. They may also change how brands coordinate pricing, media investments and promotional planning, with the accuracy of advertised savings becoming a more explicit part of the consumer value proposition.