Rule 4 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.
Rule 4 is a records rule. Every direct selling entity must keep, at its registered office, either manually or electronically, the documents that any law in force requires, including twelve listed documents or records "as may be applicable". The list runs from the certificate of incorporation to the register of direct sellers and licences for food and drugs.
This article takes the rules as amended up to G.S.R. 454(E) dated 21 June 2023, which changed rule 3 only and left rule 4 as published. Later amendments should be checked on the website of the Department of Consumer Affairs.
Under rule 4, every direct selling entity shall maintain at its registered office, either manually or electronically, all documents required under any law in force, including the twelve records listed in clauses (a) to (l) "as may be applicable": incorporation and constitution documents, tax registrations and returns, financial statements, a register of direct sellers, import-export code, food and drug licences and the trade mark certificate. The records also feed the website duty in rule 5(1)(d).
What rule 4 requires
The opening words are: "Every direct selling entity shall maintain at its registered office, either manually or electronically, all such documents as are required under any law for the time being in force, including the following documents or records, as may be applicable".
Three features are worth noting.
- Place. The records are kept at the registered office. Rule 5(1)(b) requires at least one physical location as the registered office within India (see rule 5(1)).
- Form. Manual or electronic. A well-indexed electronic folder is as good as a paper file, provided the records can be produced from the registered office.
- Scope. The list is not exhaustive. It says "including the following"; it adds to whatever other laws require the entity to keep.
The phrase "as may be applicable" means an entity keeps only those records that apply to it. A company that sells no food does not need a food licence; a firm that sells only domestic goods does not need an importer-exporter code. A compliance documentation review can confirm which items apply to a particular entity.
The twelve records
| Clause | Record | Typically relevant where |
|---|---|---|
| (a) | Certificate of Incorporation | Entities that are incorporated |
| (b) | Memorandum of Association and Articles of Association | Companies |
| (c) | Permanent Account Number and Tax Deduction and Collection Account Number | Entities holding them |
| (d) | Goods and Services Tax registration | Entities registered |
| (e) | Goods and Services Tax returns | Entities registered |
| (f) | Income Tax returns | Entities filing them |
| (g) | Balance Sheet, Audit Report and such other relevant reports | Entities preparing and auditing accounts |
| (h) | Register of direct sellers | Every entity with direct sellers |
| (i) | Certificate of Importer-Exporter code | Where goods are imported |
| (j) | Licence under the Food Safety and Standards Act, 2006 for manufacture or sale of food items | Food products |
| (k) | Licence and registration certificate under the Drugs and Cosmetics Act, 1940 for manufacture or sale of drugs, including Ayurvedic, Siddha and Unani drugs and Homoeopathic medicines | Drugs and medicines |
| (l) | Certificate of Registration of Trademark | Where a trade mark is registered |
For the tax items see our GST guides and income-tax guides; this article does not go into returns or rates.
The register of direct sellers
Clause (h) asks for a "Register of direct sellers". Rule 5(10) separately requires the entity to maintain a record of all its direct sellers, including their identity proof, address proof, e-mail and other contact information, and rule 5(16) requires a record of those delisted. Taken together, the register is a working document: it should show who the direct sellers are and how to contact them. See rule 5(10)-(17).
An invented example: Silverline Naturals Pvt Ltd sells herbal supplements through direct sellers and imports some raw material. Its registered office file should hold its certificate of incorporation, memorandum and articles, PAN and TAN, GST registration and returns, income tax returns, the balance sheet and audit report, the register of its direct sellers, its importer-exporter code, its food licence and its trade mark registration certificate. If it also sold Ayurvedic drugs, it would add the licence under the Drugs and Cosmetics Act, 1940.
How rule 4 connects to the website rule
Rule 5(1)(d) requires the entity to maintain a proper and updated website with all relevant details, "including the documents or records specified in rule 4". The records kept under rule 4 are therefore also what the website must display, along with the self-declaration, contact information, nodal officer and grievance redressal officer details, management, products, product information, price and grievance mechanism. See rule 5(1) and the disclosure list in rule 5(2). Rule 5(1)(g) also requires the information on the website to be certified by a Company Secretary.
Old references in the list
The list names the Food Safety and Standards Authority of India Act, 2006, the Drugs and Cosmetics Act, 1940 and the Goods and Services Tax and Income Tax laws as printed. The current position of each of those laws should be checked before relying on a particular licence name, since the rule names no replacement.
Where rule 4 sits among the rules
Rule 4 is the first of the substantive duties after the definitions in rule 3. A breach of the rules is dealt with under the Act (rule 13); see rules 8-13. For a wider view of the compliance load on a business, read our post on consumer protection compliance for businesses.
Need help organising direct selling records?
If your records are scattered or incomplete, our compliance documentation team can build a rule 4 file index and a register of direct sellers that match the text.
Key takeaways
- Records must be kept at the registered office, manually or electronically.
- The list of twelve is "including", not exhaustive, and is subject to "as may be applicable".
- A register of direct sellers is one of the twelve.
- The records support the website duty in rule 5(1)(d).
Read next
- Rule 5(1): obligations of the direct selling entity, set-up and contracts
- Rule 5(2): information on the website
- Rule 5(3)-(9): declarations, data, grievance officer and complaints
- Consumer Protection Compliance for Businesses
Disclaimer: Based on the rules, regulations and guidelines named above as published in the Gazette of India or on the CCPA website, with the amending notifications the article names (consulted on 3 October 2026). Later amendments, the Consumer Protection Act, 2019 provisions referred to, State rules and CCPA advisories should be checked. This article is general information, not legal advice; check the official text before acting.