D2C x India

Hey readers,

Welcome to the thirty first edition of D2C Cents!

If you have ever added an iPhone 16 to your Flipkart cart, you may have noticed something strange. The “deal” price was actually the same as the MRP. So, there was almost no real discount. It just looked like you were getting a discount.

This happened throughout the festive shopping season.

MediaNama tracked prices during these sales and found that many of these discounts were more like marketing tricks than real savings. 

In September 2025, the Central Consumer Protection Authority fined FirstCry ₹2 lakh for a small but important issue. The website said that its prices were “MRP inclusive of all taxes.” But when customers reached checkout, GST was added again. This meant a discount advertised as 27% effectively became closer to 18%.

₹2 lakh was a small amount for a company of FirstCry’s size. But the fine sent a message that regulators were paying attention.

And they continued taking action. By August 2026, the CCPA had fined nine platforms for similar practices. 

For example, Zepto was fined ₹7 lakh for having a “Zepto Pass” option already selected, Physics Wallah was fined ₹5 lakh, and PharmEasy was fined ₹1 lakh. The total fines were around ₹20 lakh, and the government later announced these actions in Parliament.

Until now, most of these actions were based on guidelines. In simple terms, companies were being told, “This practice is not acceptable,” and fines could be imposed if they broke those guidelines.

The new rules will come into effect on January 1, 2027.

This law ends the era where a discount could do your selling for you. What's left is the product itself.

So, what does the new law actually say? It is quite simple.

From January 1, whenever you advertise a discount, you must show the “prior price” next to it. The prior price means the lowest price at which you sold that product during the previous 30 days.

This one rule makes fake discounts much harder.

For example, imagine you normally sell a kurta for ₹999. In September, you increase its listed price to ₹2,999. Then, in October, you bring it back to ₹999 and advertise “67% OFF.”

The customer feels like they are getting a huge deal, but they aren't. The kurta was already selling for ₹999.

Under the new rule, you cannot advertise that 67% discount unless the product was actually sold at ₹2,999 during the previous 30 days.

The CCPA can investigate businesses, impose fines, and even order product recalls. It has already taken action against nine platforms and imposed real fines. So businesses should treat these rules seriously.

This is where many founders may stop paying attention too soon. They see the “prior price” rule, fix their discount claims, and think they are done.

But the new rules cover much more than pricing. They also target the small tricks websites and apps use to push customers into making decisions they may not have made otherwise.

The government has identified 13 types of “dark patterns.” These five come up most often in e-commerce, and you'll probably recognise them:

There are also several less obvious requirements.

Sponsored listings must clearly be labelled as ads. They cannot simply look like normal recommendations.

Search results and rankings cannot be manipulated unfairly. The rule applies regardless of the technology being used, so businesses cannot simply blame the algorithm for how products are ranked.

You also cannot add unrelated fees to a purchase. Loyalty programmes are an exception.

Businesses need proper customer consent before reusing customer data. Imported products must also clearly show their country of origin.

Businesses need to conduct an annual self-audit and display a compliance certificate publicly.

Yes, that sounds like paperwork. But it becomes a problem if the business has no record of doing it when the regulator asks.

It is easy to think these rules are mainly for big platforms like Amazon, Flipkart, or Zepto. But smaller D2C brands are covered too.

First, if you run your own website, you are the platform.

There is no Flipkart between you and the customer. Your product pages, checkout process, subscription system, and add-ons are all your responsibility. So if your website automatically adds ₹49 gift wrapping, makes a customer search through several screens to cancel a subscription, or shows a misleading discount, it can fall under these rules.

The size of your business does not change what your website is doing.

Second, marketplaces will also put pressure on sellers.

Around 26 major platforms, including Flipkart, Myntra, Swiggy, Zepto and Meesho, have publicly declared that they do not use dark patterns.

For years, many D2C brands have relied on this approach.

The biggest adjustment may be for brands that have trained customers to wait for sales before buying.

If customers only purchase when they see “70% OFF,” but that discount can no longer be presented in a misleading way, the brand may need to rethink how it attracts customers and creates demand.

There is also a positive side to all of this, especially for brands that have always kept their pricing fair.

When every brand has to show genuine discounts, honest pricing becomes easier for customers to recognise. If you were already selling products at fair prices, you may suddenly look more trustworthy when exaggerated discounts disappear from competitors' websites.

It can also help brands that focus on customer retention.

If customers come back because they genuinely like your product, receive good service, or get useful loyalty benefits, these rules do not change much for you.

That creates a difficult cycle. Customers learn to wait for sales, and the brand becomes dependent on running bigger and bigger promotions.

Brands that never built their business around constant discounts have less of this problem.

If fake discounts are no longer an option, what can replace them? Brands that prepare for this already have several alternatives, and many of them can actually be better for the business. 

There is also a question about who fixes a problem listing. 

If a marketplace finds that your listing is not compliant, will it change the price itself? Will it use a coupon or simply lower the price? The rules explain what is not allowed, but don't clearly explain how marketplaces should handle every situation. 

The rules will be new for everyone in January. Brands that sort out their pricing across channels now will be in a much better position than those trying to figure it out after the rules take effect. 

Give store credit instead of a discount. 

For example, on a ₹1,000 product, instead of selling it for ₹700, you could give the customer ₹300 in store credit. Your original price stays unchanged, so you avoid the 30-day pricing problem. And because some customers never use all their points or credit, the actual cost to you can be lower than giving the discount immediately. Most importantly, the customer has to come back to your store to use the credit. A discount leaves with the customer; store credit gives them a reason to return.

Create useful bundles, not bundles of leftover products.

If the price and contents of a bundle keep changing, tracking its lowest price over 30 days becomes difficult. A fixed bundle with a stable, honest price is much easier to manage.

The important part is relevance. Pair a bestseller with a product that genuinely goes well with it, rather than adding something that has been sitting unsold in your warehouse. Present the bundle as a complete solution, such as “everything you need for a monsoon skincare routine.” When the bundle solves a problem, the discount becomes less important.

Give every product a clear role.

Not every product needs the same pricing strategy.

Once every product has a clear role, you can set rules for each one. One product can be bundled, another should never go below a certain price, and another may have enough margin that it never needs a discount.

This means you stop discounting automatically and start discounting only when there is a clear reason.

Add value instead of always reducing the price.

For your best customers, give them something extra: a surprise gift, early access, or a premium service.

This gives them a reason to stay loyal without making them feel that the original price was too high. Constant discounts can do the opposite. They can teach customers to think that the product was overpriced in the first place.

Discounts make people wait for the next sale.
Give them a reason to come back, and they might.

The bottom line

The rules around how D2C brands sell are changing.

From January, discounts have to be real, prices have to be clear, and the little tricks that push people to buy will be harder to use.

For years, discounts did a lot of the work. Now brands will have to give customers a reason to come back beyond another coupon.

A good product, fair pricing, and a great customer experience give customers a reason to come back.

When those things are strong, you don't need a countdown timer or “70% OFF” banner to convince customers every time. Let the product do more of the selling.

See you next edition - same time, deeper insights.

Until then, keep building strategically.
Abhishek