Registering as an E-Commerce Operator Collecting TCS

An online marketplace can face three registration questions at once, and they lead to different forms. It may have to collect tax from what it pays its sellers. It may be treated as the supplier of certain services sold on its platform. And if it sells its own stock, it is an ordinary supplier as well. Treating these as one registration is the commonest mistake. So is assuming that every seller on the platform must be registered, a rule that has changed for sellers of goods since October 2023.

This guide covers the registration of an operator that must collect tax at source, and how the other two roles relate to it. The general steps of an online application are in Applying for GST Registration: the Steps Every Applicant Takes. Only what differs is set out here.

Who is an operator, and when TCS applies

Section 2(45) of the CGST Act defines an electronic commerce operator as “any person who owns, operates or manages digital or electronic facility or platform for electronic commerce”. Electronic commerce, in section 2(44), is the supply of goods or services “including digital products over digital or electronic network”.

Section 52(1) requires “every electronic commerce operator …, not being an agent” to collect an amount on “the net value of taxable supplies made through it by other suppliers where the consideration with respect to such supplies is to be collected by the operator”. Two conditions are in those words. Other suppliers must be selling through the platform, and the operator must be collecting the money. The Act caps the rate at one per cent. Notification No. 52/2018-Central Tax fixed the central tax rate at half per cent of the net value of intra-State taxable supplies. Notification No. 15/2024-Central Tax substituted “0.25 per cent.” from its publication on 10 July 2024.

Three registrations, three provisions

Section 24, which applies regardless of turnover, deals with operators in three clauses, as now numbered:

• Clause (x): “every electronic commerce operator who is required to collect tax at source under section 52”. This is the TCS registration, applied for in FORM GST REG-07.
• Clause (iv): persons required to pay tax under section 9(5). Under section 9(5), for services notified by the Government, the operator pays the tax “as if he is the supplier”. The services are listed in Notification No. 17/2017-Central Tax (Rate). It was most recently amended by Notification No. 17/2025-Central Tax (Rate), which added local delivery services from 22 September 2025, except where the person supplying them through the operator is liable to register under section 22(1). This liability is registered in the ordinary application, FORM GST REG-01, where the reasons for registration include “Person liable to pay tax u/s 9(5)”.
• Clause (ix): persons who supply “through such electronic commerce operator who is required to collect tax at source under section 52”, other than supplies covered by section 9(5). This is the sellers’ obligation, discussed below.

Clause (xi) is a different case. It covers persons supplying online information and database access or retrieval services from outside India to unregistered recipients in India, and has its own procedure under rule 14.

An operator that collects TCS and is also liable under section 9(5) therefore has two separate obligations under clauses (x) and (iv), and they are made in two different forms. Supplies of its own stock fall under the ordinary rules in Who Must Register.

An operator without a physical presence in India is dealt with by the provisos to section 9(5). Liability for section 9(5) tax then falls on a person representing the operator, or on a person the operator must appoint.

The application: FORM GST REG-07

Rule 12(1) of the CGST Rules requires a person “required to collect tax at source in accordance with the provisions of section 52” to apply in FORM GST REG-07, signed or verified through EVC. The tax deductor uses the same form, and the applicant ticks “Tax Collector”.

Two points differ from the deductor’s case.

• PAN only. The TAN alternative in the proviso to section 25(6) is limited to “a person required to deduct tax under section 51”. An operator applies on its PAN, and the portal’s manual says the legal name and PAN are validated against the CBDT database.
• States without an office. Rule 12(1A) lets an operator applying in a State “where he does not have a physical presence” name that State in Part A and its principal place of business, in another State, in Part B. Section 25(1) requires registration in each State where the person is liable.

The portal’s user manual for tax collectors describes the same Part A, OTP and TRN steps as for any applicant, with an unsubmitted application purged after fifteen days. Part B has six tabs: Business Details, Tax Collecting Officer, Authorized Signatory, Office Address of Tax Collector, Aadhaar Authentication, and Verification. The applicant signs with a DSC or verifies by EVC, and receives an ARN.

Document checklist

Document	Who provides it	Format and size (portal manual)
Photograph of the Tax Collecting Officer	The operator	JPEG, under 100 KB
Proof of principal place of business: property tax receipt, municipal khata copy or electricity bill for owned premises	The operator	PDF or JPEG, up to 1 MB
For rented or leased premises, the rent or lease agreement and a document of the lessor’s ownership	The operator, with the lessor’s document	PDF or JPEG, up to 1 MB
For consent or shared premises, a consent letter and a document of the consenter’s ownership	The operator, with the consenter’s document	PDF or JPEG, up to 1 MB
Where no rent or lease agreement exists, an affidavit to that effect and a document of possession	The operator	PDF or JPEG, up to 1 MB
For SEZ premises, the Government of India certificates	The operator	As above
If Aadhaar authentication is declined, e-KYC documents for the primary authorised signatory and at least one promoter or partner	Those individuals	PDF or JPEG, up to 2 MB

The manual also records that the portal rejects an upload it reads as blank, and warns where it reads one as illegible. Bank account details are optional in REG-07.

Declarations, consents and authentication

REG-07 itself prescribes the details of the “Person responsible for deducting tax/collecting tax”, an Aadhaar consent (item 14) and a solemn verification (item 15). Its instructions require companies and LLPs, including foreign ones, to sign with a class 2 or higher DSC. The form does not list a separate authorisation letter among the uploads.

The portal adds an Aadhaar Authentication tab for tax collectors that the form does not show. It sets out, by constitution of business, whose Aadhaar is to be authenticated: for a company, the primary authorised signatory and one of the directors. For a foreign company, the director must be one who is a citizen or resident of India. According to the manual, an applicant who authenticates is treated on the seven-working-day timetable. One who declines is “marked for mandatory site visit”, with deemed approval after thirty days if the officer takes no action.

That description follows rule 9, which governs applications in REG-01, not rule 12. Rule 12(2) itself provides for grant “after due verification” in REG-06 “within a period of three working days from the date of submission of the application”. From 1 November 2025, rule 9A, inserted by Notification No. 18/2025-Central Tax, applies to applicants under rule 12 as well. An application identified “based on data analysis and risk parameters” is granted electronically within three working days. Where a site visit is made, the report and photographs go up in FORM GST REG-30 under rule 25. The common steps guide explains geotagging and the field visit.

Sellers on the platform

How the operator’s sellers are registered decides what the operator must do with each of them.

Registered sellers. Section 24(ix) requires sellers through a TCS-collecting operator to register regardless of turnover. The operator collects TCS on their supplies.

Small sellers of services. Notification No. 65/2017-Central Tax exempts suppliers of services through such an operator, other than section 9(5) services, whose all-India aggregate turnover does not exceed twenty lakh rupees, or ten lakh in special category States other than Jammu and Kashmir.

Unregistered sellers of goods. From 1 October 2023, Notification No. 34/2023-Central Tax exempts suppliers of goods through such an operator whose aggregate turnover “in the preceding financial year and in the current financial year” is within the section 22(1) threshold. The conditions are that the seller makes no inter-State supply of goods and does not sell through operators in more than one State. It must hold a PAN, declare its PAN, place of business and State on the portal, and obtain an enrolment number before its first sale. Only one enrolment number is allowed per State, and it ceases on registration. A GSTN advisory of 12 October 2023 describes the route: User Services, “Generate User Id for Unregistered Applicant”, then the box “To apply as a supplier to e commerce operators”.

For these sellers, Notification No. 37/2023-Central Tax requires the operator to allow supplies “only if enrolment number has been allotted”, and not to allow any inter-State supply. It must not collect TCS, and must report the supplies in FORM GSTR-8. Where several operators are involved, the obligation falls on the one “who finally releases the payment”.

Composition sellers of goods. The Finance Act, 2023 omitted “goods or” from section 10(2)(d), from 1 October 2023, so a composition taxpayer may now sell goods through an operator. Notification No. 36/2023-Central Tax requires the operator not to allow such a seller any inter-State supply, to collect TCS on its supplies, and to report them in GSTR-8. Supplying services through such an operator still bars the composition option. Opting In and Out of the Composition Scheme covers this.

After registration

The operator deposits the amount collected within ten days after the end of the month (section 52(3)). It files a monthly statement in FORM GSTR-8 within ten days after the month’s end (section 52(4), rule 67), and an annual statement before 31 December following the year (section 52(5)). Sellers claim the TCS in their electronic cash ledgers. Under section 52(12), an officer not below Deputy Commissioner may require details of supplies and of sellers’ stock in the operator’s warehouses, to be furnished within fifteen working days.

When the operator stops collecting tax, cancellation runs through rule 12(3), as for a deductor. The officer may act “on a request made in writing” and issues FORM GST REG-08 after following rule 22. The deductor guide, Registering as a Tax Deductor (TDS), describes the order.

The forms in sequence

• FORM GST REG-07: application for registration as a tax collector (rule 12(1))
• FORM GST REG-01: ordinary application, used for section 9(5) liability and for the operator’s own supplies
• FORM GST REG-06: certificate of registration
• FORM GST REG-30: field visit report, where a visit is ordered (rule 25)
• FORM GSTR-8: monthly statement of supplies and TCS (rule 67), including supplies by enrolled unregistered sellers and composition sellers
• FORM GST REG-08: order cancelling a TCS registration (rule 12(3))

The procedure in summary

1. Decide which roles apply: TCS collector under section 52, supplier under section 9(5), and seller of own goods. Each is registered on its own footing.
2. For TCS, apply in FORM GST REG-07 on the operator’s PAN in each State where it is liable, using rule 12(1A) for States without an office.
3. Upload proof of the principal place of business and the Tax Collecting Officer’s photograph, and complete Aadhaar authentication or the e-KYC upload.
4. Expect grant within three working days under rule 12(2) or electronic grant under rule 9A, subject to any field visit reported in REG-30.
5. Register section 9(5) liability, and any own supplies, through FORM GST REG-01.
6. Configure the platform to the sellers’ status. Enrolled unregistered sellers need an enrolment number and must make no inter-State sales or TCS collection. Composition sellers must make no inter-State sales, and TCS is collected on them.
7. Deposit TCS and file GSTR-8 within ten days of each month’s end, and the annual statement by 31 December.

The next guide in this set covers registration as an Input Service Distributor, the other separate registration a business with several GSTINs may need.