The Central Government has revised the provisions governing payment of GST on delivery services supplied through electronic commerce operators, linking the operator’s liability to whether the underlying service provider is liable for registration under Section 22(1) of the Central Goods and Services Tax Act, 2017.
Through Notification No. 09/2026-Central Tax (Rate), dated October 27, 2026, the Ministry of Finance has substituted clause (v) of Notification No. 17/2017-Central Tax (Rate). The revised provision will take effect from November 1, 2026.
Under the substituted clause, delivery services other than postal and courier services fall within the notified mechanism for payment of tax by electronic commerce operators. However, the provision excludes cases where the person supplying those services through the operator is liable for registration under Section 22(1) of the CGST Act.
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Supplier’s Registration Liability Becomes The Key Test
The amendment makes the delivery service provider’s liability for registration under Section 22(1) central to determining whether the electronic commerce operator must discharge tax under this entry.
Where a person supplies covered delivery services through an electronic commerce operator and is not liable for registration under the specified provision, the services fall within the operator-payment framework.
Conversely, where the delivery service provider is liable for registration under Section 22(1), the exception in the substituted clause applies. The electronic commerce operator’s liability under this particular entry consequently does not extend to those supplies, and the applicable tax treatment must be determined under the ordinary provisions.
The wording is significant because it refers specifically to a person being “liable for registration” under Section 22(1). Accordingly, determining the applicability of the exception requires examining the supplier’s statutory registration liability, rather than relying solely on whether the supplier has furnished a GST registration number.
How Section 9(5) Operates?
The notification has been issued under Section 9(5) of the CGST Act on the recommendations of the GST Council.
This provision empowers the Government to notify categories of services for which tax on intra-State supplies must be paid by the electronic commerce operator when the services are supplied through it. For those supplies, the Act treats the operator as the supplier liable to pay tax.
The amendment therefore concerns the allocation of tax-payment responsibility between the electronic commerce operator and the underlying delivery service provider.
Postal And Courier Services Expressly Excluded
The substituted clause expressly excludes postal and courier services from the description of delivery services covered by this entry.
Consequently, the revised clause cannot, by itself, be used to place postal or courier services within this particular Section 9(5) mechanism. Their GST treatment must be determined under the provisions applicable to those services.
The exclusion should not be understood as a GST exemption. The notification identifies the services covered by the operator-payment mechanism; it does not declare postal or courier services tax-free.
No New GST Rate Prescribed
Although issued as a Central Tax (Rate) notification, the amendment does not prescribe a new percentage rate of GST for delivery services.
Its operative change is the substitution of the service description and the associated exception relating to the supplier’s registration liability. The applicable rate and other tax conditions must therefore be examined separately under the relevant provisions.
Similarly, exclusion from this particular operator-payment entry does not, by itself, make a delivery service exempt from GST.
Implications For Platforms And Delivery Service Providers
As a practical consequence of the revised wording, electronic commerce operators facilitating delivery services will need to assess whether the services supplied through their platforms fall within the notified description and whether the relevant suppliers are liable for registration under Section 22(1).
This assessment will be relevant to identifying supplies on which the operator must discharge tax from November 1, 2026. Platforms may accordingly need to review supplier declarations, registration information and their internal tax-treatment processes.
Delivery service providers will also need to examine their registration position under the specific provision cited in the notification. The exception turns on the statutory liability for registration, making an accurate assessment of that liability material to the treatment of supplies made through a platform.
These are practical implications of the substituted clause; the notification itself does not prescribe a separate supplier-verification procedure.
Amendment Effective From November 1
The notification expressly provides that the substitution will come into force on November 1, 2026. It does not specify a separate transitional arrangement.
The principal Notification No. 17/2017-Central Tax (Rate), dated June 28, 2017, was last amended through Notification No. 17/2025-Central Tax (Rate), dated September 17, 2025, according to the explanatory note accompanying the notification.
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