The Enrolment Number and the Composition Route for Selling Through a Platform

Enrolment Number explained: this guide covers what it means, who it applies to, the step-by-step process, documents required, fees, due dates and penalties in India — so you can stay compliant with confidence and avoid costly mistakes.

Section 24(ix) made a nationwide registration requirement out of a decision to sell online. For a home business turning over ₹4 lakh a year, that was not a compliance cost — it was a door closed. Two notifications in 2023 opened it, and a third told platforms how to police the opening.

Section 24(ix) compels registration for anyone supplying goods or services (other than section 9(5) supplies) through an ECO required to collect TCS. Notification No. 65/2017-CT dated 15.11.2017 already exempted suppliers of services only below the threshold. Notification No. 34/2023-CT dated 31.07.2023, effective 01.10.2023, exempts suppliers of goods below the threshold, on five conditions, granting an enrolment number instead of registration. Notification No. 37/2023-CT dated 04.08.2023 prescribes the ECO's own special procedure for them, and Notification No. 36/2023-CT dated 04.08.2023 does the same for composition dealers, who have been able to sell goods through an ECO since 01.10.2023.

The rule that made all this necessary

Section 24(ix) compels registration of "persons who supply goods or services or both, other than supplies specified under sub-section (5) of section 9, through such electronic commerce operator who is required to collect tax at source under section 52".

So the threshold in section 22(1) is irrelevant to such a person. The Handbook: "a person who is supplying goods or services or both through electronic commerce operator which is required to collect TCS under section 52 would have to get himself compulsorily registered even if the threshold of the aggregate turnover as per Section 22(1) is not exceeded, unless he is supplying supplies specified under Section 9(5)."

Why the 9(5) carve-out? Because for those supplies the platform is the deemed supplier and pays the tax anyway; there is nothing for the supplier's registration to add.

And the Handbook names the problem plainly: this "was becoming an entry barrier for many small businesses who could make supplies through electronic commerce operators but did not want to get into the compliance burden."

Route one: services only, below the threshold

The oldest relief, and still the simplest. Under Notification No. 65/2017-Central Tax dated 15.11.2017, "a person supplying only services, other than services under section 9(5), through an e-commerce platform is exempted from obtaining compulsory registration provided its aggregate turnover does not exceed ₹20 lakh (or ₹10 lakh in specified special category States) in a financial year."

Note the word "only". A supplier mixing goods and services on a platform falls outside this notification and must look to route two — or register.

Route two: the enrolment number for suppliers of goods

Exercising the power in section 23(2), the Central Government by Notification No. 34/2023-CT dated 31.07.2023, applicable from 1 October 2023, exempted from registration persons making supply of goods through an ECO required to collect TCS, whose aggregate turnover in the preceding and current financial year does not exceed the registration threshold for the State or UT — subject to five conditions:

1. No inter-State supply of goods.
2. No supply of goods through an ECO in more than one State or Union territory.
3. The person must have a PAN under the Income-tax Act, 1961 and declare it on the portal along with the address of the place of business and the State or UT in which he seeks to supply — subject to validation on the common portal.
4. On successful validation, an enrolment number is granted. No more than one enrolment number may be granted in a State or UT.
5. No supplies may be made through the ECO until the enrolment number is obtained.

And the exit: where such a person is subsequently granted registration under section 25, the enrolment number ceases to be valid from the effective date of registration.

The first two conditions are the real boundary. The relief is for a genuinely local seller — one State, no inter-State sales. Cross a State line and the relief is gone, and with it the exemption from registration.

What the platform must do about it

Notification No. 37/2023-CT dated 04.08.2023, effective 01.10.2023, prescribes the special procedure for an ECO required to collect TCS in respect of goods supplied through it by a person exempted under Notification No. 34/2023:

• It shall allow the supply only if an enrolment number has been allotted to that person on the common portal.
• It shall not allow any inter-State supply of goods made through it by that person.
• It shall not collect TCS under section 52(1) on supplies made through it by that person.
• It shall furnish the details of such supplies in the statement in FORM GSTR-8 on the common portal.

Read the third and fourth together. The platform reports the supplies but collects nothing — GSTR-8 becomes an information return for this population, not a collection return.

And where multiple ECOs are involved, the same notification says "the electronic commerce operator" means the one who finally releases the payment to that person for the supply.

The enforcement obligations carry a penalty. Under section 122(1B), an ECO liable to collect TCS which allows a supply by an unregistered person other than one exempted by notification, or allows an inter-State supply by a person not eligible to make it, or fails to furnish correct details in GSTR-8 of supplies by a person exempted from registration, is liable to ₹10,000 or the tax that would have been involved, whichever is higher. The ECO penalty regime →

So the platform's onboarding checks are not good practice — they are the subject of a penalty provision.

Route three: the composition dealer

Section 10(2)(d), as amended by Notification No. 28/2023-Central Tax dated 31.07.2023, means a composition taxpayer cannot supply services through an ECO — but with effect from 1 October 2023 a composition taxpayer supplying only goods may supply through an ECO.

Notification No. 36/2023-Central Tax dated 04.08.2023 lays down the conditions, and they are the platform's obligations:

1. The ECO shall not allow any inter-State supply of goods through it by that person.
2. The ECO shall collect TCS under section 52(1) on supplies of goods made through it by that person and pay it to the Government under section 52(3).
3. The ECO shall furnish the details of such supplies in FORM GSTR-8.

Compare routes two and three. They share the inter-State prohibition and the GSTR-8 reporting, and differ on the middle limb:

The TCS difference follows from status. A composition dealer is registered and has a cash ledger for the credit to land in; an enrolment-number holder has neither.

Key takeaways

• Section 24(ix) compels registration for platform sellers — except for section 9(5) supplies.
• Notification No. 65/2017-CT: suppliers of services only, below the threshold, are exempt.
• Notification No. 34/2023-CT (from 01.10.2023): suppliers of goods below the threshold are exempt, on five conditions, and get an enrolment number — one per State, no inter-State supply, one State only, PAN validated, and no supply before allotment.
• The enrolment number ceases on grant of registration.
• Notification No. 37/2023-CT: the ECO must check the enrolment number, block inter-State supply, not collect TCS, and report in GSTR-8.
• Notification No. 36/2023-CT: a composition dealer supplying goods may sell through an ECO — no inter-State supply, but TCS is collected.
• The platform's checks are backed by section 122(1B) penalties.

Read next

• ECO Penalties: Section 122(1B), Interest and Late Fee
• TCS Registration: REG-07, State-Wise Registration and the Foreign ECO
• Section 52 TCS: Rate, Net Value and When to Collect

Disclaimer: Positions stated as on 5 September 2026, based on sections 10(2)(d), 22(1), 23(2), 24(ix) and 52 of the CGST Act, 2017 and Notification Nos. 65/2017, 28/2023, 34/2023, 36/2023 and 37/2023-Central Tax, as reproduced in the ICAI Handbook on E-Commerce Operators under GST (updated to 15 December 2025).