The GST Council approved in principle a simplified registration mechanism for small sellers supplying goods through e-commerce operators across multiple states. But the Council’s 2025 release says detailed operating rules would be placed before it; it does not establish that sellers can use the mechanism now. Separately, existing CBIC guidance allows multiple registered sellers to declare the same eligible shared e-commerce warehouse as an additional place of business, subject to documentation and record-keeping requirements.
What the Council approved—and what remains unresolved
The Council’s 2025 announcement addresses small suppliers selling through e-commerce operators (ECOs) across multiple states, including suppliers who face difficulty maintaining a principal place of business in each state. It describes an in-principle approval for a simplified registration mechanism, not a set of operational instructions.
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The release says: “The detailed modalities for operationalizing the said scheme will be placed before GST Council.” That means the release alone does not show that the mechanism has been activated or explain how a seller would apply. The 2025 release and a November 2025 Council newsletter do not establish whether later action has made this specific multi-state ECO mechanism operational. Sellers should check for current Council or CBIC notifications and portal instructions before relying on it.
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Yes, under existing CBIC guidance, multiple registered sellers may declare the same shared ECO warehouse as an additional place of business if they have the requisite documents supporting their use of the premises. The registered persons must also comply with applicable records requirements. This guidance answers the warehouse-sharing question; it does not, by itself, settle whether a seller must register in the state where the warehouse is located.
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Warehouse access does not settle state registration
CBIC’s registration FAQ says registration in another state is a fresh registration. A seller considering stock or fulfillment facilities in a state where it is not registered should therefore treat state registration as a separate question. The cited warehouse-sharing guidance does not say that sharing premises removes state-wise registration obligations.
Whether a particular seller must register depends on its circumstances and the applicable rules. Warehouse access alone is not a basis to assume that registration is unnecessary. Confirm the seller’s position against current requirements before storing or supplying goods from another state.
Do not confuse the two small-seller measures
| Measure | Who or what it addresses | What the official material establishes |
|---|---|---|
| 2023 ECO route for certain unregistered suppliers | Eligible unregistered suppliers making intra-state supplies of goods through ECOs, subject to prescribed conditions. | A conditional route for those intra-state supplies. It is not a blanket authorization for interstate sales or a substitute for the later multi-state proposal. |
| 2025 multi-state ECO concept | Small ECO suppliers operating across multiple states, including those facing difficulty maintaining a principal place of business in each state. | In-principle approval, with detailed modalities to be placed before the Council. The 2025 release does not establish that sellers can already use it. |
| Rule 14A simplified registration scheme | A separate general simplified registration scheme described in the November 2025 Council newsletter. | The newsletter passage reviewed describes this separate scheme, not activation of the multi-state ECO concept. |
These routes have different conditions and purposes. In particular, the 2023 route is limited to eligible intra-state supplies of goods by unregistered suppliers through ECOs; it should not be read as general permission to store goods in another state or make interstate sales without registration.
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- Establish the seller’s registration position. Check whether the seller is registered in the warehouse state or has a current legal basis not to register there. CBIC describes registration in another state as a fresh registration.
- Confirm the warehouse documentation. Ask the ECO or facility operator what documents it can provide to support the seller’s use of the premises for declaring it as an additional place of business.
- Classify the supplies. Determine whether the relevant sales are intra-state or interstate; the 2023 unregistered-supplier route described by CBIC is limited to qualifying intra-state supplies of goods.
- Identify the route being used. Do not treat the 2023 conditional route, the 2025 in-principle multi-state concept, shared-warehouse guidance, and Rule 14A as interchangeable.
- Check records and platform processes. Confirm that the seller can meet records requirements and that the ECO’s onboarding and reporting process supports the seller’s actual registration route.
- Verify current implementation. Before relying on the 2025 concept, look for subsequent Council or CBIC action and current portal instructions that expressly operationalize that specific mechanism.
The official guidance establishes these general distinctions, but it does not determine GST liability for a particular seller’s locations, transactions, or arrangements. For an individual case, confirm the current rules and facts with a qualified GST adviser.
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