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What the Council approved, and what it has not yet finished
The 2025 GST Council release describes a proposed simplified registration scheme for small suppliers making supplies through ECOs across multiple states. It names the difficulty of maintaining a principal place of business in each state as the problem the scheme addresses. The release does not give operating instructions. Its own wording is that “the detailed modalities for operationalizing the said scheme will be placed before GST Council.”
In practical terms, that means:
- The multi-state mechanism has been accepted as a policy direction, not yet written up as a procedure a seller can follow.
- No filing steps, eligibility thresholds or portal screens for it appear in the official material reviewed for this article.
- Any later Council decision or CBIC notification that sets the modalities would be the point at which sellers can plan around it.
The most recent official material available for this explainer is dated 2025. Before relying on the mechanism, check the outcomes of later GST Council meetings and CBIC notifications, and confirm on the GST portal whether any corresponding registration function has been enabled.
Four arrangements that are easy to confuse
Most of the confusion comes from treating these four items as one permission. They cover different sellers, different supply types and different stages of implementation.
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| Arrangement | Who it covers | Supplies covered | Status in the sources reviewed |
|---|---|---|---|
| 2023 ECO exemption for unregistered suppliers | Qualifying unregistered suppliers selling through ECOs | Intra-state supplies of goods only, under prescribed conditions | Conditional; not a general permission to sell from another state |
| Multi-state simplified registration for small ECO suppliers (2025 Council release) | Small suppliers operating across multiple states, including those who cannot maintain a principal place of business in each state | Interstate supplies through ECOs | Approved in principle; detailed modalities still to be placed before the Council |
| Shared ECO warehouse as an additional place of business (CBIC sectoral FAQ) | Registered sellers who use the same premises | Goods stored in a shared ECO facility | In CBIC guidance; conditional on documents and record-keeping |
| Rule 14A simplified registration (November 2025 Council newsletter) | General simplified registration scheme | Not limited to the multi-state ECO concept | Described in the newsletter, which covers its portal procedure; the newsletter does not show the multi-state ECO concept being activated |
The 2023 exemption and the 2025 multi-state proposal are two different measures. A seller who qualifies for the first is not thereby covered by the second, and the 2025 proposal does not extend the 2023 exemption to interstate sales.
Is a shared ECO warehouse allowed?
CBIC’s sectoral FAQ on e-commerce addresses a specific case: sellers on an ECO platform may share a common place of business where the operator stores goods in a shared facility. This can mean several suppliers register the same additional place of business. The FAQ asks whether that is allowed, and the answer is “Yes, this is allowed.”
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The answer comes with conditions:
- Each seller must be a registered person. The 2023 unregistered-supplier route is a different arrangement.
- The registered person declares the premises as an additional place of business, supported by the documents that show it may use the premises.
- Multiple sellers may declare the same premises.
- Required records must be maintained by each registered person, not by the operator alone.
The guidance concerns declaring an existing shared facility. It does not create a new registration route for a warehouse in a state where the seller has no registration.
Does a warehouse in another state require registration?
This is the question sellers most often need answered, and the CBIC registration FAQ gives a clear starting point. It states that registration in another state is a fresh registration. The warehouse-sharing FAQ does not itself waive state-wise registration requirements, so access to a shared facility in another state does not, by itself, settle a seller’s registration obligations.
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The question “When is registration in other state required?” is answered by the seller’s specific facts: where the goods are stored, where the supplies are made, and what the seller’s current registrations and any legal basis for not registering are. The official sources reviewed set out the general distinctions but do not determine liability for a particular seller.
The Rule 14A scheme and the 96% figure
The November 2025 Council newsletter covers a general simplified registration scheme under Rule 14A. It is separate from the multi-state ECO concept, and the newsletter does not show the multi-state concept as in operation. A figure from the GST Council Secretariat’s 2025 material, that around 96% of new applicants benefit from the simplified process, relates to this general scheme. It should not be read as evidence about the effect of the multi-state warehouse proposal, which has not been measured.
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Checklist before using a warehouse in another state
Work through these points before moving stock into a state where you are not registered:
- Registration status: Are you registered in the state where the warehouse sits? If not, do you have a current legal basis for not registering there?
- Premises documents: Can the operator supply the documents needed to declare the premises as an additional place of business?
- Supply type: Are your sales intra-state or interstate? The 2023 exemption covers only intra-state supplies of goods.
- Route: Are you using the 2023 unregistered-supplier route, or operating as a registered seller?
- Platform process: Does your marketplace’s onboarding and reporting process support the route you are using?
- Current status: Have the GST Council or CBIC issued modalities for the multi-state mechanism, and is it live on the GST portal? Confirm this before planning around it.
The official sources establish the general distinctions, not the answer for your business. A GST practitioner or chartered accountant can apply these points to your state registrations, invoices and returns.
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