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December 15, 2025
By Saumyangi Yadav, Entrepreneur India
Dec 15, 2025
India’s D2C ecosystem has grown rapidly over the past five years, but scale remains elusive. While thousands of brands have launched and many have crossed early revenue milestones, only a small fraction manage to break past INR 100 crore in annual revenue. According to a new report by DSG Consumer Partners, based on a survey of over 100 Indian D2C founders and operators, the problem is not demand or product-market fit, it is how brands attempt to scale.
The report shows that around 60–65 per cent of Indian D2C brands remain stuck in the INR 1–50 crore revenue band, with very few reaching the INR 100 crore mark. This stage marks the point where early traction exists, but growth begins to strain unit economics, teams, and operating systems.
Insights from over 100 D2C founders reveal that India’s fastest-growing brands win on fundamentals rather than speed alone. Clear product-market fit, disciplined data tracking, strong unit economics, creative velocity, and an early focus on retention consistently separate scalable brands from those that plateau. Founders also admit that performance marketing mistakes, pricing missteps, and weak creative systems slow growth far more than budget constraints. In a booming D2C landscape, capability gaps in operations, brand-building, and supply-chain depth are widening the divide between breakout brands and those stuck in the performance plateau.
Industry observers argue that this is where many brands mistake rapid online growth for sustainable scale.
As Devangshu Dutta, Founder & CEO, Third Eyesight, explains, “Scaling up online can be very rapid, but is also capital-hungry in terms of CAC. Given the intense competition, the lack of customer stickiness and the power of platforms, there is a constant churn of marketing spend which is a huge bleed for growing brands.”
CAC Inflation is The Real Constraint
One of the clearest findings from the playbook is that acquisition efficiency, rising CAC and unstable ROAS, is the single biggest blocker to growth, cited by more founders than funding or category expansion. Moreover, over 70 per cent of brands rely on Meta as their primary acquisition channel, increasing vulnerability to auction pressure and platform-driven volatility.
Dutta links this directly to the limits of a digital-only mindset. “Limited offline expansion can trap brands in narrow urban digital markets, blocking broader scale,” he said.
This over-reliance on online performance marketing often leads to growth that looks strong on dashboards but weak on cash flow.
Highlighting their report, Pooja Shirali, Vice President, DSG Consumer Partners, said, “Across over 90 consumer brands we’ve partnered with at DSGCP, one truth is clear: brands that master Meta’s ecosystem don’t just grow, they change their entire trajectory through strategic clarity and disciplined execution. The real drivers of scale have less to do with viral moments, and everything to do with the long-term fundamentals that make milestones like the first INR 100 crore predictable, not accidental.”
Why Omnichannel is Unavoidable
The report suggests that brands that scale sustainably are those that reduce overdependence on paid digital acquisition and expand their distribution footprint. However, offline expansion brings its own complexity.
Dutta stresses that omnichannel is not an optional add-on, but a strategic shift. “D2C brands must adopt an omnichannel approach, blending online with offline retail for sustainable and scalable reach. Clearly the channels work very differently and management teams have to be prepared and capitalised for the long haul to tackle acquiring customers with channel-appropriate strategies,” he adds.
This aligns with the DSGCP report’s broader insight that scale breaks down when brands fail to adapt operating models as they grow.
Even within digital channels, performance weakens over time. The playbook finds that 62 per cent of founders report creative fatigue, where repeated creatives fail to sustain ROAS despite higher spends. At the same time, 55 per cent admit to under-investing in CRM and retention, with most brands reporting repeat purchase rates of just 10–30 per cent.
Both the data and expert opinion point to a common theme: brands that cross the INR 100 crore mark are structurally different. They obsess over unit economics, processes, and capital efficiency rather than topline growth alone.
As Dutta puts it, “Scalable brands that cross the growth hump have leadership obsessed with unit economics and omnichannel execution rather than chasing vanity metrics. Cash always was and is king, especially at early stages of growth.”
He adds that execution strength matters as much as strategy. “They are able to grow and steer teams that build and replicate processes fast rather than spending time, effort and money reinventing all the time, and do so without constant CXO intervention.”
As competition intensifies and capital becomes more selective, the next generation of INR 100 crore D2C brands is likely to be defined not by speed, but by the ability to compound cash flows, institutionalise processes, and scale distribution beyond digital platforms.
Saumyangi is a Senior Correspondent at Entrepreneur India with over three years of experience in journalism. She has reported on education, social, and civic issues, and currently covers the D2C and consumer brand space.
(Published in Entrepreneur India)
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December 10, 2025
Shabori Das, ET Bureau
Dec 10, 2025
India’s social media platforms are powerful marketing tools but not yet retail destinations. Billions scroll and swipe daily, but few buy directly within apps. Unlike China, India faces regulatory hurdles and a lack of integrated payment systems.
A billion Indians scroll, swipe and double tap every day, but barely buy. Despite Instagram and Facebook Marketplace being in India for over a decade, social media here remains a showroom, not a store. Creators and D2C brands are hustling to convert attention into action, but the holy grail of in-app shopping where discovery, live streaming, and purchase happen seamlessly, remains out of reach.
The question is, what’s stopping India from becoming the next China or the US in social commerce?
Influence-to-Commerce Gap
Globally, social commerce is powered by influencers. In China, influencer Li Jiaqi reportedly sold products worth $2 billion on Singles’ Day on Alibaba’s online marketplace Taobao Live in 2021. Another popular influencer Zheng Xiang Xiang, with over 5 million followers on Douyin (the Chinese equivalent of TikTok), reportedly generated $18 million in sales in a week in 2023. These are numbers India’s creator economy can only dream of, for now.
To be clear, influencer marketing in India is booming. EY estimates the sector at over Rs 3,000 crore and yet, due to regulatory restrictions, social media platforms in India can’t host end-to-end transactions. What India has is content commerce, driven by players like Meesho and Myntra, not social commerce. Globally, social commerce is a $1-trillion market. China alone accounts for over $500 billion and the US, $100 billion. India’s share? Around $10 billion — despite being home to the world’s largest Gen Z population and the second-largest base of internet users after China.
What’s Holding India Back
“Just as quick commerce changed how India buys food, social commerce will change how we shop for fashion and lifestyle,” says Anand Ramanathan, partner, consumer industry leader, Deloitte South Asia.
The idea is simple: Social commerce enables an end-to-end purchase journey within a social media app. But in India, the final sale still happens elsewhere — typically on e-commerce platforms.
“In China, live streaming contributes nearly 20% of total e-commerce revenue. In India, it hasn’t taken off,” says Puneet Sehgal, CEO of D2C apparel brand Freakins. He believes in-app checkout could be transformative. “Our Gen Z audience spends over an hour daily on social media. If the purchase could happen right there, it’s one step less for the consumer — and one step closer to a sale.”
The China Contrast
China’s social commerce revolution was built on three forces — speed, scale and seamlessness. Influencer Zheng, for instance, showcases each product for barely three seconds and moves on. That brevity, combined with integrated payments, drives impulse buying at staggering volumes.
India’s influencer-driven commerce, by contrast, is still warming up. Projected to touch $ 55 billion by 2030, it remains largely limited to discovery and advertising.
The barriers aren’t technological, they’re regulatory. India’s payment rules require clear accountability and settlement tracking, making it difficult for global platforms to enable in-app sales. Meta’s 2023 policy shift also directed purchases off-platform, keeping Instagram and Facebook Marketplace confined to discovery and promotion, rather than purchase. For now, social media in India remains a potent marketing engine, not yet a retail destination.
Experiments and Exceptions
Some Indian players are testing new waters. Myntra’s Glamstream, launched this July, lets influencers host live sessions where viewers can “shop the look” in real time — though the final checkout still redirects you to the Myntra app.
“India’s creator economy influences over $300 billion in annual consumer spending,” says Sunder Balasubramanian, chief marketing officer at Myntra.“That could grow to $1 trillion in the next few years, making India one of the fastest-growing creator economies globally,” adds Lakshminarayan Swaminathan, vice president-product management, Myntra.
The potential is clear. In 2021, Taobao Live hosted a 12-hour live streamed sale with influencer Li Jiaqi in China that clocked $2 billion in presales and attracted 250 million viewers.
Closer home, Sujata Biswas, co-founder of Suta Sarees, recalls Instagram’s shortlived Shop Now feature. “We saw an immediate dip in transactions after it was withdrawn,” she says. “Fashion is about instant gratification. You see it, you want it and buy it right away.”
The D2C Advantage
India’s D2C market, valued at $87 billion as of 2025 by Deloitte, could be the biggest gainer if social commerce does take off. Most D2C brands currently pay 25–35% retailer margins to platforms like Myntra and Nykaa. Social commerce could let them bypass intermediaries and sell directly to their audiences.
“Anything that reduces friction between intent and purchase is gold,” says Sehgal. “If that entire journey — from watching to buying — happens within the same app, conversion rates would shoot up.”
Even so, social platforms come with their own costs. TikTok, for instance, charges promotional, marketplace and fulfilment fees. But for Indian D2C players, the larger hurdle isn’t cost — it’s access.
Open vs Closed Ecosystems
“India’s retail market is far more open than China’s,” explains Devangshu Dutta, CEO of ThirdEyesight, a retail consulting firm. “In China, closed ecosystems like WeChat and Douyin created the perfect environment for social commerce to thrive. In India, where consumers can freely move between Google, Meta and e-commerce giants, those closed loops don’t exist.”
Globally, TikTok Shop, Douyin, WeChat, Pinduoduo, and Taobao Live dominate social commerce. According to Business of Apps, a data provider for the global app industry, TikTok earned $23 billion in 2024, with nearly 23% of it from in-app and commerce purchases.
If similar models are launched in India, e-commerce giants would face direct competition from the very platforms that fuel their traffic.
The Wait Continues
From beauty tutorials to thrift stores, social media spawns thriving micro economies. Yet, true social commerce — where discovery leads directly to purchase — hasn’t yet clicked.
The next big leap for India’s e-commerce may not come from deeper discounts or faster delivery but from social media itself. “The idea of instant gratification is key,” says Biswas. “When the ‘Shop Now’ button comes back, we’ll be the first to use it.”
Till then, India scrolls, likes, shares — and waits.
(Published in Economic Times)
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December 7, 2025
Gargi Sarkar, Inc42
7 December 2025
The past year has been nothing short of monumental for LensKart — from reporting another operationally profitable quarter in Q2 FY26 to making the public markets leap in November, and crossing a market capitalisation of INR 70,000 Cr despite a muted stock market debut.
A clear shift this year has been Lenskart’s effort to move beyond the image of a ‘basic D2C eyewear’ brand selling prescription glasses and sunglasses. The company is now working to reposition itself as a new-age tech brand.
Further, Lenskart is rethinking where and how its products are manufactured. Currently, around 20–25% of its frames are reportedly manufactured in India. The company is ramping up its domestic production. As a new manufacturing facility in Telangana is a work in progress, Lenskart intends to gradually shift most of its manufacturing operations from China to India.
In many ways, 2025 has been about scaling up for Lenskart, and as it embarks on a fresh journey as a publicly listed company, let’s take stock of the company in 2025 and where it might be headed in 2026.
Lenskart’s Smart Eyewear Bet
Lenskart began its smart eyewear journey last year with the launch of Phonic, its audio glasses. It later deepened its push into the segment by announcing a strategic investment in Ajna Lens, a Mumbai-based deeptech company that develops AI-powered XR glasses. Back then, Peyush Bansal described the move as the “next chapter” in Lenskart’s smart glasses journey.
Cut to December 2025, the company is all set to launch its AI camera smartglasses, B by Lenskart, by the end of this month.
What makes B by Lenskart noteworthy is that it isn’t being marketed as just another pair of smart glasses. The new eyewear features an integrated Sony camera that enables hands-free photo and video capture. The glasses come with a built-in AI assistant powered by Gemini 2.5 Live. They are designed to offer natural, conversational interactions and pack in a range of advanced features — from hands-free UPI payments and live translation to wellness insights and more.
What makes the move even more significant is Lenskart’s decision to open B by Lenskart to India’s developer ecosystem. By making its AI and camera technology accessible to consumer apps and independent developers, the company is enabling integrations across categories such as food delivery, entertainment, and fitness.
“By opening its AI smartglasses to third-party developers, Lenskart is moving from a one-time product-sale model to a platform ecosystem model. In the long run, this could unlock recurring revenue streams and higher margins,” said a product developer.
Besides, the company is aligning itself with a younger customer cohort, aided by affordability, style, and technology.
“That’s what seems to define their current strategy. Over time, they’ve also brought in elements of innovation like virtual try-ons, and any product, feature, or service that brings novelty and appeals to younger customers has become part of their brand approach,” said Devangshu Dutta, the founder of Third Eyesight.
Next, the timing couldn’t be better for Lenskart to place its bet on smart glasses. An IDC report reveals that despite a slowdown in smartwatch and earwear segments in the second half of 2025, smart glass shipments shot off more than 1,000% over the last year.
However, it’s not going to be smooth sailing from here.
At its core, Lenskart is still a consumer-facing company, and it needs new products to keep its revenue growing. But the competition is already heating up. Jio unveiled its own AI-powered smart glasses, Jio Frames, at Reliance Industries’ 48th annual general meeting. And of course, Meta continues to lead the global smart glasses market.
At this point, smart eyewear is a niche category, which comes with a hefty price tag.
“Unless cost drops dramatically, mass adoption is still a distant dream. As of now, the product will only attract early adopters and tech enthusiasts, rather than the mainstream consumer,” Dutta adds.
Lenskart’s Make In India Push
Lenskart is not only widening its product range but also ramping up its manufacturing. The company currently operates centralised manufacturing facilities in India (Bhiwadi in Rajasthan and Gurugram in Haryana), Singapore, and the UAE. It also has manufacturing operations in China.
Back home, Lenskart has also signed a non-binding MoU with the Government of Telangana for setting up a greenfield manufacturing facility for optical glasses. The proposed investment stands at INR 1,500 Cr and will be supported by certain incentives and assistance from the state government.
The new production facility is expected to strengthen Lenskart’s domestic manufacturing capabilities while reducing its exposure to foreign exchange fluctuations and import-related volatility.
However, the expansion comes with its own set of challenges. While the new manufacturing plant in Telangana is expected to strengthen Lenskart’s vertical integration, it will come with a hefty cost burden.
Profitability Still A Troubling Question
The cost structure is becoming increasingly important for Lenskart. Despite its headline-grabbing profitability, the company is still operating on fairly thin margins.
Lenskart reported a net profit of INR 297 Cr in FY25, a notable turnaround from a loss of INR 10 Cr in FY24. However, market analysts caution that the business’ core operations were unprofitable. It was largely “other income” or investment income that drove the FY25 bottom line.
“Though Lenskart has increased its revenue from INR 3,789 Cr in FY23 to INR 6,651 Cr in FY25, the company’s profitability has largely improved due to a rise in other income. While it reported a PAT of INR 297 Cr in FY25, a closer look shows that the profit was driven significantly by an increase in other income, which jumped to INR 356 Cr in FY25,” SimranJeet Singh Bhatia, senior research analyst for equity at Almondz Group.
The point of concern here is that Lenskart turned operationally profitable only after its market debut. Bhatia believes that at least three to four quarters of consecutive profitability will be needed to prove the company’s underlying strength.
However, making matters worse are the company’s climbing expenses, which stood at INR 1,980.3 Cr in Q2 FY26, up 18.5% YoY.
What Lies Ahead?
The year was equally sour for the eyewear major. While its IPO generated significant buzz and saw strong subscription levels, its market debut turned out to be a muted affair.
At the upper end of its INR 382 to INR 402 IPO price band, the public issue implied a price-to-earnings (P/E) multiple of roughly 235–238 times its FY25 profits, placing it among the most expensive consumer tech listings in India.
On its first day of trading, Lenskart Solutions Ltd. was listed on the NSE at INR 395 per share, a discount of 1.74% to the issue price of INR 402. The stock, however, fell close to 9% shortly thereafter. On the BSE, it debuted at INR 390, marking a discount of nearly 3%.
After the IPO, Bhatia adds, the biggest concern surrounding Lenskart is the store-level unit economics, particularly because a significant share of the IPO proceeds is being directed toward expanding its company-owned, company-operated store network.
Entering the new year as a public company, Lenskart will have to prove that its scale-up plans are justified and that it has greater control over its balance sheet. 2026 will be a critical juncture for the company, as the next three to four quarters will be closely watched for signs of sustainable growth, improved margins, and stronger operational discipline.
[Edited by Shishir Parasher]
(Published in Inc42)
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December 3, 2025
Pooja Yadav, Exchange4Media
3 December 2025
Over the last few months, India’s e‑commerce and quick‑commerce ecosystem has undergone a wave of structural regulatory and tax reforms. Be it the Goods and Services Tax Council (GST Council) formally bringing “local delivery services” under the tax net with an 18% levy, or the newly implemented labour and social-security reforms expanding obligations for gig workers on aggregator platforms like Swiggy and Zomato, the cost and compliance landscape for delivery and fulfilment is shifting significantly.
The latest GST clarification, delivery fees, packaging charges, and logistics surcharges are now creating a ripple effect across pricing, platform margins, and seller compliance requirements.
The past few months have already shown concrete signals that platforms are revising their incentives, delivery promises, and fee structures. Following the GST clarification, major food‑delivery players have raised their platform fees, for instance, Zomato reportedly increased its per‑order fee from ₹10 to ₹12 (pre‑GST), while Swiggy also raised fees in select markets. Some quick‑commerce arms are also reworking free‑delivery thresholds or fee waiver conditions. Swiggy Instamart also recently updated its free‑delivery threshold to orders above ₹299, with handling and surge fees applying below that level, per reports.
Meanwhile, some platforms seem to be signalling a de‑emphasis on “ultra‑fast for every order” as universally viable; free or fast delivery now appears increasingly tied to higher order values or subscription/membership perks.
It looks like these pressures are forcing platforms to reconsider long-standing quick-commerce levers such as ultra-fast delivery, first-order free offers, zero delivery fees, and flash discounts — which have historically driven customer acquisition and retention.
While Zomato did not comment directly, it referred to the Code on Social Security, 2020 (CoSS), noting that the platform is prepared for gig-worker obligations and does not expect the rules to negatively impact long-term business sustainability.
According to Kapil Sharma of Amazon Ads, “The e‑commerce landscape will continue to evolve, but some fundamentals remain constant such as delivering value to consumers and providing advertisers with meaningful ways to engage. Our full-funnel ad solutions allow brands to focus on objectives such as new product launches, brand building, or promoting larger pack sizes, ensuring campaigns remain relevant and effective even as the ecosystem adapts to changing costs and regulations.”
e4m reached out to Swiggy, Meesho, Zepto and BigBasket for comments, but did not receive responses until the time of publishing.
Several experts told e4m that the economic model of quick commerce, built on heavily subsidised delivery and small-ticket frequent orders, is under pressure. Platforms will need to find sustainable levers to retain customers without eroding margins. The industry has started to see a strategic recalibration where speed is increasingly becoming a hygiene factor rather than a differentiator, free delivery is becoming conditional, and platforms are nudging consumers toward larger baskets, subscription models, curated bundles, and scheduled deliveries. Brands, in turn, are also shifting focus from mass discounting to premiumisation, value-led messaging, and precise cohort-based targeting.
Will Free Delivery Become Rare?
With the new social‑security obligations for gig workers under India’s labour reforms, and the added cost burden of delivery services now subject to GST, the economic logic underlying “free delivery” as a marketing lever is coming under stress. Chetan Asher, Founder and CEO of Tonic Worldwide, echoes this view, noting that quick-commerce platforms previously operated on thin contribution margins and heavily subsidised small-ticket, frequent orders. With rising delivery costs and mandatory social-security contributions, universal free delivery is becoming increasingly unsustainable.
Industry analysts point out that the new social-security mandates and GST on delivery fees have lifted per-order costs noticeably. Most quick-commerce platforms already operate at low single-digit contribution levels, making blanket “free delivery” hard to justify. It may continue, but only as a conditional incentive tied to higher basket values, subscription memberships, or flexible delivery slots, rather than as a universal subsidy.
Shradha Agarwal, Co- Founder & Global CEO, Grapes Worldwide, added from an advertising standpoint, “It’s already happened, brands like Zomato, Swiggy, Amazon and Flipkart, who know we are going to buy from them, have shifted from ‘buy now’ tactics to ‘stay with me’ strategies. Those days are gone when platforms were giving blanket discounts, now brands are the ones tightening their offers.” Citing an example she mentioned how offline pricing is ₹235, but online it is sold at ₹185, with online adding to top-line rather than bottom-line.
On promo hooks like ‘₹0 delivery’, ‘first-order free’ or ’10-minute delivery’, Agarwal said, “As labour codes, compliance costs, and social-security contributions kick in, platforms will have less room to burn cash on promos that don’t create sustainable value. Consumers care more about convenience than freebies.”
On ad spend shifts, she noted, “Offer-driven campaigns will weaken, while value-driven storytelling will rise. ATL and influencer campaigns will strengthen, and performance marketing will become more strategic. Retail media will become non-negotiable.”
From a brand perspective, Asher pointed out that quick-commerce spends are increasingly evaluated against contribution margin rather than sheer GMV growth. Discounts and zero-fee offers are losing bite as customer acquisition costs rise. First-party data, replenishment journeys, and sharper cohort-based offers are gaining importance, ensuring that incentives remain ROI-focussed rather than mass-oriented. Similarly, speed claims such as “0 delivery” or “10-minute delivery” are becoming less differentiating in top cities, where most players already deliver within 15–20 minutes. Consumers now respond better to reliable ETAs, fair fee structures, and transparent pricing than aggressive speed promises.
Adding her viewpoint, Pooja Dhamdhere, Commerce Lead at Starcom India, said, “Incentives like free delivery or first-order offers are likely to evolve rather than disappear, and platforms will explore strategies such as tiered benefits, curated bundles, or differentiated pricing for specific cohorts.”
According to serial entrepreneur Alok Chawla and Founder at Kiko Live, added that while platforms may continue absorbing delivery costs in the short term, the long-term economics will require charging for ultra-fast or low-value orders. “Once platforms pass the actual delivery costs to consumers, we expect order frequency and small-cart behaviour to change, with many users shifting to larger baskets or neighbourhood retailers offering free delivery,” he noted.
Alternative Consumer-Incentive Models
Devangshu Dutta, founder and chief executive of Third Eyesight, who is an expert in the consumer and modern retail sector, stated, “I think platforms will pass a significant portion of the new 18% GST burden on delivery to end-consumers, either through higher delivery charges or repackaged platform fees. Some of this cost may also be clawed back from restaurant partners and quick-commerce brands via revised commissions, slotting fees or mandatory participation in marketing programmes, especially in categories where the platform has stronger bargaining power. Overall, I expect higher minimum-order thresholds and a tighter margin environment for restaurants and small D2C brands that rely heavily on third-party platforms.”
Analysts highlight strategies such as minimum-order thresholds, where free or lower-fee delivery applies only above a certain cart value, nudging consumers to order larger baskets rather than frequent small-ticket items. Subscription and membership-based models are also gaining prominence, offering benefits like waived or discounted delivery, priority fulfilment, and access to exclusive promotions in exchange for a fixed fee.
Scheduled or batch delivery windows are being used to optimise logistics, reduce cost pressure on ultra-fast last-mile fulfilment, and improve operational efficiency. Meanwhile, curated bundles and value packs, including weekly or monthly combos, allow consumers to plan purchases while enhancing per-unit economics for platforms. These levers also enable brands to maintain margin integrity without over-reliance on short-term discounting.
From a marketing perspective, this shift is prompting agencies and creative-first firms to move toward value-led messaging, premiumisation, and cohort-based targeting. Dhamdhere explained, “Platforms are optimising assortments by surfacing premium SKUs, nudging higher average order values, and using search optimisation to strengthen profitability. Brands are now focusing on aspirational consumers with curated bundles, subscriptions, and value-led propositions, rather than mass discounting. Performance campaigns will continue, but clarity of value and sustainable margin-led offers are becoming key for acquisition and retention.”
2026: Will regulatory pressure force a recalibration?
As 2026 approaches, the combined impact of GST on delivery services and mandatory social-security contributions for gig workers is forcing a fundamental rethink of quick-commerce economics. With blanket discounts, zero delivery fees and ultra-fast delivery no longer viable as mass levers, platforms are shifting toward basket-building, subscriptions, curated bundles and conditional incentives. The growth thesis is evolving from “habit formation at any cost” to protecting contribution margins through reliable ETAs, transparent pricing and premium assortments rather than aggressive subsidies.
Brands are recalibrating alongside this shift. Premiumisation, value-led propositions and sharper cohort-based targeting are taking precedence over broad discounting, and campaigns are increasingly evaluated on ROI, repeat behaviour and lifetime value rather than raw GMV. Tiered memberships, scheduled deliveries and subscription-led conveniences are emerging as key retention tools, while short-form video, influencer ecosystems and retail media help articulate value in a tighter cost environment.
Chawla said platforms will have to move beyond “₹0 delivery”, “first order free” and “10-minute delivery” as core propositions because the delivery cost burn far exceeds margins on small-ticket orders. Many consumers currently place multiple micro-orders a day simply because delivery is free, but once fees come into play, behaviour will likely shift toward clubbing orders or reverting to neighbourhood retailers, who themselves are rapidly digitising through partners like Kiko Live.
In the next phase, he adds, free instant delivery will only be sustainable for larger baskets, whereas scheduled delivery may become the default for free delivery, with paid instant delivery as an optional upgrade. Subscriptions may drive loyalty, but only up to a point, since the heaviest users would consume more deliveries than the subscription fee can realistically subsidise, making it difficult for platforms to make the model profitable.
This points to a clear playbook for 2026. “Free delivery” and mass discounting are expected to fade, giving way to conditional, tier-based formats that reward higher basket values, subscriptions or specific cohorts. Brand platform partnerships will also move toward profitability rather than promotional burn, with campaigns designed to protect margins instead of fuelling discount-led spikes.
Taken together, the signs suggest that 2026 will not mark the end of convenience, but the end of convenience that is subsidised blindly. The real test now is who absorbs this new cost of convenience, platforms, brands, or consumers. And as that battle plays out, another tension is already emerging: whether small and regional advertisers can survive the rising cost of visibility in India’s digital economy.
(published in Exchange4Media)
admin
November 26, 2025
Aakriti Bansal, Medianama
November 26, 2025
MediaNama’s Take: The Central Consumer Protection Authority’s (CCPA) decision to publish 18 self-declarations confirms only a partial picture of its dark pattern(s) identifying exercise. The authority has stated that 26 platforms have filed their declarations, but it has made only 18 of them public. This gap means the public still cannot see what eight major platforms submitted or whether those filings contain any meaningful detail. Moreover, even among the published declarations, several are one-paragraph statements that offer almost no insight into the scope or accuracy of the companies’ internal audits.
LocalCircles’ new survey adds further complications, reporting that 21 of the 26 platforms that submitted declarations still display at least one dark pattern. This finding suggests that the CCPA’s reliance on voluntary self-assessment may not be enough to shift platform behaviour at scale. It also raises questions about what the unpublished declarations contain and whether the missing submissions are similarly sparse or incomplete.
Notably, the CCPA has not clarified how it plans to verify the accuracy of any of the declarations, whether published or unpublished. If filings remain unverified for months, compliance risks turning into a box-ticking exercise rather than a meaningful regulatory process. Therefore, the next phase matters far more than the publication of select declarations, because the current approach raises more questions than it answers.
What’s the News
The CCPA has made 18 dark pattern self-declarations public, despite stating that 26 platforms have filed their compliance letters. The publication follows an RTI filed by MediaNama that revealed which companies had submitted their declarations, and pointed out that none of the filings had been available to the public at the time.
These declarations stem from the Ministry’s June 5 advisory, which required e-commerce and quick commerce companies to conduct internal audits under the 2023 Guidelines for Prevention and Regulation of Dark Patterns and submit compliance letters within 90 days.
For context, Moneycontrol reported that Amazon has still not filed its declaration and has asked for additional time. A senior government official told the publication that the government “has done what it had to” and does not plan further discussions.
The official also said that any punitive action would depend on consumer complaints routed through channels such as the national consumer helpline. This indicates that the enforcement approach continues to be reactive rather than compliance-driven.
What Did The CCPA Ask Platforms To Do?
The June 5 advisory set out a simple compliance framework for digital platforms. It asked every e-commerce and quick commerce company to complete a self-audit of its website and mobile app within 90 days and check their interfaces for the 13 dark patterns listed in the 2023 guidelines. Platforms were required to file a self-declaration confirming compliance once this internal review was complete.
However, the advisory did not specify how the audit should be conducted. Companies were free to choose any methodology, and the CCPA did not prescribe a standard format, a uniform checklist, or a minimum evidence requirement. Also, the advisory did not require independent audits or third-party validation.
Furthermore, there was no explanation of how the CCPA planned to verify whether the declarations were accurate or complete. In effect, the responsibility for defining the scope, depth, and rigour of the audit rested entirely with each platform.
What the CCPA Has Done With the Declarations
As mentioned before, the CCPA has now published 18 self-declarations on its website. The release confirms that companies submitted their compliance letters, but it does not indicate whether the authority evaluated the accuracy or depth of the filings.
Several platforms submitted very short statements that simply assert compliance without describing any checks or findings. BigBasket, Zomato, Blinkit and Swiggy were among the companies that filed especially minimal disclosures. The CCPA has not explained why these filings were accepted or whether any follow-up questions were asked. Therefore, asking for and disclosing self-declarations shows some administrative progress, but it does not reflect any regulatory scrutiny.
This lack of verification aligns with concerns raised by Devangshu Dutta, Founder of business consulting firm Third Eyesight. He told MediaNama that self-declarations “do not change things much” when regulators do not audit submissions or impose consequences.
Further, Dutta remarked that most companies comply at the minimum level required if their claims are not examined and are not made public in full. According to him, revenue-driving design choices such as forced add-ons, confusing checkout flows or misleading scarcity claims will not be voluntarily removed sans oversight.
What Independent Evidence Shows
LocalCircles’ latest audit presents a sharply different picture from the companies’ filings. The organisation found that 21 of the 26 platforms that submitted “dark pattern free” declarations still use one or more manipulative design practices. The assessment relied on feedback from more than 250,000 consumers across 392 districts along with AI-assisted testing.
The most common violations include forced action, subscription traps, bait and switch, basket sneaking, interface interference and disguised advertisements. In practice, these dark patterns respectively mean that users are pushed into steps they did not choose, face hidden or hard-to-cancel subscriptions, see offers change during checkout, encounter fees added at the last moment, get nudged toward platform-favoured choices, and come across ads that appear as regular listings.
LocalCircles also identified drip pricing (gradually adding mandatory fees during the checkout process) on 11 of the 26 companies, including Flipkart, Myntra, Cleartrip, MakeMyTrip, BigBasket, Zomato and Blinkit, among others. The organisation said that many platforms appear to misunderstand what qualifies as drip pricing, which has led to incomplete corrections.
Trust Can Erode Due To Gap Between Declarations And User Experience
Sachin Taparia, Founder of LocalCircles, said that the problem begins with the absence of any verification. “Our understanding is that CCPA is wanting that companies submit a self-declaration at the earliest. However, there is no cross checking of claims that is being done by the CCPA, and as a result the companies are not being as thorough with their dark-pattern detection and resolution,” he said.
Taparia added that discrepancies between declarations and user experience could harm trust. “LocalCircles has found dark patterns on 21 of the 26 platforms submitting self-declarations. If this exercise is not done with high accuracy, both platforms doing so and CCPA could see consumer trust being impacted,” he said.
Importantly, Dutta echoed this concern, saying that the absence of penalties or reputation-related consequences allows companies to self-declare compliance while keeping revenue-generating patterns intact. He described the current process as “more an administrative formality [rather] than a behaviour-changing regulatory tool”.
Why This Matters
The gap between self-declarations and independent audits in the true sense of the word brings the real enforcement question into focus. What should the next phase of regulation look like?
In this context, Dutta said that regulators need to move beyond self-certifications and mandate detailed user experience (UX) audit reports that map every user journey, including pop-ups, onboarding, search, checkout, cancellations and returns.
He explained that regulators should reinforce this by demanding substantive evidence instead of brief compliance letters. This evidence can include screenshots and screen recordings of key flows, version histories that show how an interface changed over time, and product design documents or A/B testing results that reveal why specific nudges were introduced. To explain, A/B testing is essentially a method for comparing two versions of something to see which one performs better.
Furthermore, Dutta noted that platforms already collect extensive data on user complaints and drop-off points, which can help identify harmful or confusing design choices. He also said that independent third-party attestations, similar to security or accessibility audits, can provide a credible external check and increase the cost of non-compliance.
Multiple Annual Audits For Apps that Change Interface Frequently
Notably, Dutta stressed that most dark pattern categories appear across e-commerce, quick commerce and Direct-to-Consumer (D2C) websites, which means regulators can create a baseline audit standard that works across sectors instead of relying on platform-specific interpretations. He also suggested that audits should occur at least once a year, and companies that frequently modify their interfaces may need to report two or three times annually.
The larger concern now is whether the CCPA plans to move toward such a structured framework. Without independent verification and clear audit expectations, companies can continue declaring compliance even when manipulative designs remain embedded in their interfaces.
(Published in Medianama)
