FSSAI Clarifies Food Safety Compliance Framework for E-Commerce FBOs Under the ONDC Model

The Food Safety and Standards Authority of India (FSSAI) has issued a formal order dated 18 March 2026, laying down a structured compliance framework for e-commerce Food Business Operators (FBOs) functioning within the Open Network for Digital Commerce (ONDC) ecosystem. The order, which takes effect from 1 April 2026, addresses a critical regulatory gap arising from the multi-entity nature of ONDC transactions and establishes clear accountability between the various participants involved.

Background: Why a Separate Framework Was Necessary

The Traditional vs. ONDC E-Commerce Model

Under conventional e-commerce arrangements, a single platform entity manages the entire transactional chain — from product listing and order processing to delivery and consumer interaction. Regulatory obligations under the Food Safety and Standards Act, 2006 and the FSS (Licensing and Registration of Food Business) Amendment Regulations, 2021 were designed with this consolidated model in mind.

However, the ONDC model, an initiative championed by the Department for Promotion of Industry and Internal Trade (DPIIT), operates on an entirely different architecture. A single food transaction on ONDC may involve:

  • A Seller App — the seller-side platform facilitating the listing and sale of food products
  • A Buyer App — the buyer-side platform through which the consumer discovers and places the order
  • Separate last-mile delivery entities who may be independent of both apps

This decentralized structure meant that applying food safety obligations uniformly to a single entity was no longer practical or equitable. FSSAI, after receiving representations from ONDC, undertook a review of the existing regulatory framework and issued this clarificatory order to rationalize responsibilities across participating entities.

Key Definitions Under the Regulatory Framework

Under the FSS (Licensing and Registration of Food Business) Amendment Regulations, 2021, an E-commerce FBO is defined as any Food Business Operator that carries out any of the activities specified under Section 3(n) of the Food Safety and Standards Act, 2006 through electronic commerce channels.

Furthermore, any e-commerce entity that:

  • Provides a listing or directory of FBOs or food products, and
  • Facilitates orders or transactions through its website

…is required to obtain a central FSSAI license, irrespective of whether it operates as a seller app or buyer app.

Demarcation of Compliance Obligations: Seller App vs. Buyer App

The heart of the FSSAI order lies in Annexure 1, which maps out each compliance obligation and assigns responsibility either to the Seller App, the Buyer App, or both. Below is a structured breakdown of these obligations: