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Yes, but only in a narrow, conditional case. Since 1 October 2023, an unregistered seller of goods may use an e-commerce operator (ECO) that collects tax at source without obtaining a GST registration, if the seller stays below the applicable registration threshold in the relevant State or Union Territory, makes only intra-State goods supplies, uses the route in no more than one State/UT, validates a PAN on the GST portal and receives an enrolment number before selling. This is not a general licence to sell taxable goods across India without a GSTIN, and a marketplace may impose stricter onboarding rules than the law.
The short answer: legal permission, but only with conditions
Notification No. 34/2023-Central Tax created the relevant exception under the Central Goods and Services Tax framework. It applies to a supplier of goods selling through an ECO that is required to collect tax at source (TCS) under section 52 of the CGST Act. The supplier’s aggregate turnover must not exceed the registration threshold applicable in the State or Union Territory where the route is used, in both the preceding and the current financial year.
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The concession became effective on 1 October 2023. It allows the seller to remain unregistered, but it does not remove compliance obligations. Before making any marketplace supply, the seller must complete the GST portal enrolment process, have the PAN validated and obtain the enrolment number. A seller cannot lawfully make the first qualifying sale and complete enrolment later.
The route also has two geographic limits that are easy to miss: the seller must not make inter-State supplies of goods, and goods cannot be supplied through ECOs in more than one State or Union Territory under this concession. The result is a state-bound model, not pan-India selling without GST registration.
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Check these six eligibility questions first
1. Are you selling goods, not services?
Notification 34/2023 is written for suppliers of goods. It does not create a matching exemption for every online service provider. A consultant, designer, tutor, software provider or other service seller must analyse the normal registration rules and any service-specific exceptions separately. Section 24(ix) and services taxed by the recipient under section 9(5) involve different legal questions.
2. Are your supplies taxable or wholly exempt?
If you deal exclusively in goods that are wholly exempt or non-taxable, a separate rule may mean you are not liable to register on that basis. The CGST Act and CBIC’s GST-registration FAQ describe that general treatment. Do not confuse it with the 2023 ECO enrolment route: exempt-only status is one analysis, while taxable intra-State marketplace sales under the notification are another.
3. Is your turnover below the threshold for your State/UT?
The notification points to the threshold under section 22(1) in the relevant State or Union Territory. It does not establish one universal number for all Indian sellers. The applicable limit can depend on the State/UT, the nature of supplies and notifications in force at the time. Check the current threshold before relying on the exemption, and assess aggregate turnover rather than looking only at one marketplace account.
Eligibility requires turnover not to exceed that applicable threshold in both the preceding financial year and the current financial year. If your sales approach the limit, keep a running total and obtain professional advice before crossing it; once compulsory registration applies, the enrolment route is no substitute for a GSTIN.
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4. Will every sale remain intra-State?
No inter-State goods supply is permitted under this route. In practical terms, a seller cannot use the concession while shipping taxable goods from one State to buyers in another. A marketplace’s national reach does not change that legal condition. Review how the platform assigns inventory, dispatch locations, returns and fulfilment before listing products.
5. Will you use the route in only one State/UT?
Notification 34/2023 prohibits supplying goods through ECOs in more than one State or Union Territory under the concession. It also provides that no more than one enrolment number may be granted in a State/UT. A seller operating stock or separate marketplace activity in several States should not assume that one enrolment covers all locations.
6. Have you completed PAN validation and portal enrolment?
Before supply, declare your PAN, business address and intended State/UT on the common portal. The portal validates the PAN and grants an enrolment number. That number is a prerequisite to making qualifying ECO supplies. If you later obtain GST registration, the enrolment number ceases to be valid from the effective date of that registration.
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An enrolment number is not a GSTIN. Under this concession, the seller remains unregistered for GST but is identified on the portal for the limited purpose of supplying goods through an eligible ECO. The seller should preserve the enrolment confirmation, PAN details, turnover records, invoices and marketplace statements so that the conditions can be demonstrated if questioned.
The ECO still has its own TCS and reporting responsibilities under section 52. Those marketplace processes do not turn the seller into a registered taxpayer, and they do not authorise inter-State sales. Nor does the concession erase other obligations such as consumer-protection disclosures, product licences, local-shop requirements, income-tax reporting or record keeping that may apply to the business.
How to use the route in the correct order
- Identify the supply. Confirm that you sell goods and classify each product as taxable, wholly exempt or non-taxable.
- Identify the State/UT. Establish where the business is located and where goods will be dispatched. Decide whether all marketplace supplies can remain within that State/UT.
- Check the current threshold. Verify the section 22(1) registration threshold applicable to that State/UT and confirm that aggregate turnover stayed within it in the preceding and current financial years.
- Confirm the ECO model. Make sure the platform is an e-commerce operator required to collect TCS under section 52. Ask the platform whether its category and fulfilment model support unregistered sellers using the enrolment route.
- Complete portal declarations. On the GST common portal, provide the PAN, business address and intended State/UT, complete PAN validation and wait for the enrolment number.
- Obtain written marketplace instructions. Keep the platform’s current onboarding response, because legal eligibility does not prove that its seller system accepts the enrolment number for taxable products.
- List and ship only qualifying orders. Do not accept inter-State goods orders or use another State/UT through this route. Monitor dispatch and return arrangements so the actual movement of goods matches the plan.
- Monitor turnover continuously. Include sales from relevant channels in aggregate-turnover tracking. Reassess registration immediately if the threshold is reached, if the business expands to another State, or if the supply pattern changes.
The GSTN October 2023 newsletter confirmed that enrolment functionality was made available for unregistered suppliers of goods through ECOs in one State/UT. Because portal screens can change, follow the current GST portal instructions rather than an old screenshot or an unofficial step list.
Marketplace onboarding can be stricter than the statute
A statutory exception does not force a marketplace to implement every possible onboarding path. Amazon.in’s public seller FAQ says GST details are required for listings of taxable goods. Its account-creation guide describes a PAN-based route for sellers listing exclusively GST-exempt products. Those pages do not establish that Amazon accepts the separate GST portal enrolment number for taxable goods under the intra-State concession.
Before investing in inventory, ask the selected marketplace, in writing:
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- Whether it currently onboards taxable-goods sellers using a GST portal enrolment number rather than a GSTIN.
- Whether the option is available for your product category and dispatch State/UT.
- How the platform prevents or handles inter-State orders, returns and fulfilment.
- Which documents, invoice fields and account settings it requires.
- Whether its warehouse or fulfilment programme would move stock across State borders, making the model unsuitable.
Retain the response and the date. Platform policy can change independently of the notification, and a public FAQ may describe the ordinary GSTIN workflow without covering the newer exception.
Why older advice says marketplace sellers must register
CBIC sectoral FAQs contain an older answer stating that a trader below the then-stated turnover figure had to register when selling through an ECO required to collect TCS. That reflected the earlier general position. It predates Notification 34/2023 and its 1 October 2023 conditional waiver.
For a current decision, read the notification and the CGST Act together. The old FAQ is useful background but should not be treated as a blanket statement that overrides the later exception. Conversely, the notification should not be read as cancelling the general registration rule for sellers who fail any condition.
Common situations and the likely result
| Seller situation | Can the 2023 ECO route apply? | Reason |
|---|---|---|
| Small seller of taxable goods, one State/UT, only intra-State orders, turnover below the applicable threshold, PAN validated and enrolment obtained | Potentially yes | All principal conditions are addressed, subject to marketplace acceptance. |
| Seller ships goods from one State to buyers in another | No | Inter-State goods supplies are prohibited under the concession. |
| Seller uses the route through ECOs in two States/UTs | No | The notification limits supplies under this route to one State/UT. |
| Seller has not received the portal enrolment number | No, not yet | Enrolment must precede the first qualifying supply. |
| Seller sells only wholly exempt goods | Separate analysis | The general exempt-supply rule may remove registration liability; the 2023 route is not the reason. |
| Online service provider below a turnover threshold | Not under this notification | The concession is expressly for suppliers of goods. |
| Marketplace requires a GSTIN for taxable listings | Operationally blocked unless the platform changes its process | Platform onboarding can be narrower than legal eligibility. |
Practical pitfalls and how to avoid them
Assuming “below ₹X” works everywhere
Do not rely on a single all-India figure. The notification ties eligibility to the section 22(1) threshold applicable in the relevant State/UT. Verify the current rule for your location and supply profile.
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Letting the platform sell nationally by default
Automatic nationwide delivery, a central fulfilment warehouse or cross-border returns can create movements inconsistent with the intra-State condition. Configure geography deliberately and ask how the ECO handles orders that fall outside the permitted State.
Treating PAN onboarding for exempt products as permission for taxable products
A marketplace’s PAN route for exclusively exempt goods does not prove that taxable goods may be listed without a GSTIN. Obtain category-specific confirmation.
Confusing enrolment with registration
The enrolment number identifies a qualifying unregistered supplier; it does not confer the rights or status of a GST registration. Do not print or describe it as a GSTIN.
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Adding another State, starting inter-State shipping, crossing the threshold or obtaining GST registration changes the analysis. If GST registration becomes effective, the enrolment number stops being valid from that date.
What the policy is intended to do
The Ministry of Finance, Department of Revenue, described the 2023 measure in its year-end review as opening the e-commerce market to small sellers without mandatory registration up to the registration threshold. That statement explains the policy objective, while Notification 34/2023 supplies the enforceable conditions. The benefit is therefore real but deliberately limited: it is designed for small, localised goods sellers whose marketplace activity can remain within one State/UT.
When professional advice is worthwhile
Consider consulting a chartered accountant or GST practitioner before listing if you have stock or warehouses in multiple States, turnover near the threshold, a mix of taxable and exempt products, marketplace fulfilment, complicated returns, or uncertainty about whether a particular platform collects TCS. A short review can prevent a costly mismatch between the legal route and the platform’s operational model.
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