MSME & Global Commerce · established evidence

Reading ONDC's Public Disclosure Filings: What 70+ Seller and Buyer Apps Reveal About How They Actually Rank MSME Listings

Last reviewed 2026-08-09. Written by Chandranshu Kumar, Founder, Raveneye Global. · 9 min read

The ONDC buyer app sorting algorithm disclosure requirement obliges every Buyer App on the network to publish, in plain language, the key parameters that decide how seller listings are sorted and ranked, a rule ONDC traces to Clause 5(3)(f) of the Consumer Protection (E-Commerce) Rules, 2020. ONDC keeps a public registry of these filings at resources.ondc.org/disclosures. A direct reading of that registry turns up 20 Buyer App filings and 52 Seller App and logistics filings, 72 in all, filed between August 2023 and November 2024. The filings vary considerably in what they actually say: one buyer app names two factors with no weights disclosed, a second app's filed disclosure link now redirects to a generic homepage, and a third's filing renders as a set of untagged images with no readable text. ONDC has also clarified, in its own published consultation record, that Buyer Apps are not required to disclose their actual algorithms or specific weights, only to act fairly and to guide sellers on improving searchability "without actually being required to disclose business secrets." The result is a real, government-linked transparency mechanism that most MSME sellers appear never to have read, and that several of the filing apps themselves have let go stale.

A disclosure mandate most sellers have never opened

Every seller who lists on an ONDC buyer app is, on paper, entitled to know the logic that decides whether their listing shows up first or on page four. ONDC's Network Policy, Chapter 2 Business Rules, Clause 2.3.3(k), requires every Buyer Side App to ensure search results are displayed "in a non-discriminatory manner," provided that the Buyer App "discloses, to other Network Participants and ONDC... the key parameters of the logic used for sorting/listing search results, to ensure that Sellers are able to improve their ranking on listings or results." A further proviso lets the Buyer App also publish uniform minimum standards for what gets displayed at all, so long as it applies those standards consistently.

ONDC traces this obligation to a specific external rule. In Notification No. 2023/06/06/01, dated 6 June 2023, ONDC told all Buyer Apps that Clause 5(3)(f) of the Consumer Protection (E-Commerce) Rules, 2020, requires e-commerce entities to publish "an explanation of the main parameters which, individually or collectively, are most significant in determining the ranking of goods or sellers on its platform and the relative importance of those main parameters through an easily and publicly available description drafted in plain and intelligible language." ONDC gave Buyer Apps three days: comply by 9 June 2023 or face disciplinary action, with the possibility of separate enforcement action by government authorities under the underlying rule.

This is not a soft best-practice suggestion. It is a compliance deadline tied to a central government rule, run through a network that, by ONDC's own count, had onboarded more than seven lakh sellers and service providers by 2025, the large majority of them micro, small, and medium enterprises. A rule this specific, aimed at a network this large, ought to be one of the more consequential pieces of paper an MSME seller could read before deciding which buyer app to prioritize.

What ONDC itself said the mandate does not cover

Before reading what apps actually filed, it is worth reading what ONDC said the obligation means, because the network answered this question directly. When Chapter 2 Business Rules went through public consultation, stakeholders asked ONDC to clarify the scope of Clause 2.3.3(k), including whether ranking algorithms had to be made uniform across apps and how much of the underlying logic had to be revealed. ONDC's published response, part of the official Summary of Consultation attached to the Business Rules document, is unambiguous: "ONDC also clarifies that it doesn't intend to define algorithms or actual parameters for Network Participants, and it will be left to the discretion of the Buyer Side App to decide on the algorithm to be employed." The response adds that Buyer Apps "must provide guidance to Seller Side Apps/Sellers on ways to improve searchability, without actually being required to disclose business secrets."

That distinction, between disclosing "key parameters" and disclosing an algorithm, is the central fact for a seller trying to use these filings. The rule was never designed to hand a seller a formula they could reverse-engineer. It was designed to guarantee that some named, human-readable factors exist and are published, and that the app cannot claim commercial secrecy as a reason to publish nothing at all. What counts as sufficient disclosure under that standard is left almost entirely to each Buyer App's discretion, which is exactly why the actual filings, read side by side, look so different from one another.

Reading the registry: 72 filings, wildly uneven upkeep

ONDC maintains the compliance record for this mandate in one place: the Disclosures page of its Resources and Knowledge Base, at resources.ondc.org/disclosures. It is a plain table, split into a Buyer Apps section and a Seller Apps and Logistics Service Providers section, each row linking out to the filing itself, most often a Google Doc or a page on the app's own website.

As reviewed for this piece, the Buyer Apps table lists 20 entries, from Rapidor and MyStore through Meesho, Pincode, PayTM, and Namma Yatri, with filing dates running from 7 August 2023 to 28 November 2024. The Seller Apps and Logistics Service Providers table lists 52 entries, from MyStore and uEngage through Delhivery, Shiprocket, Shadowfax, and a long tail of smaller catalogue and fulfillment platforms, filed across roughly the same window. Together that is 72 disclosure filings sitting on one government-linked registry, comfortably matching the "70-plus" figure this piece leads with, and a handful of additional rows across both tables are still marked "Pending" more than two years after the compliance deadline the network itself set.

What that table does not show is quality. A row with a green "View" link tells a seller nothing about whether the document behind it names two factors or ten, whether it was last touched in 2023, or whether the link even resolves anymore. That is a separate check, and it is the one most sellers, understandably, never run.

Three filings, three very different pictures

Pulling three filings directly from the registry shows the range.

MyStore: named factors, no weights

MyStore's filed sorting-parameters page names two factors: how closely a product matches the buyer's search term, and the seller's distance from the buyer, with the balance between the two flipped depending on category, search relevance dominates for most goods, while proximity dominates for food and beverage, where delivery speed matters more. The same page discloses minimum display standards (a valid product image at least 300 by 300 pixels, correct category classification, required statutory fields) and two hard performance thresholds: a seller whose delivery-SLA violations or customer-complaint rate crosses 10 percent of orders can be unpublished. No numeric weight is given for search relevance versus distance, which is consistent with ONDC's own reading of the rule, but it does mean a seller cannot calculate anything from this filing; they can only infer the rough order of what matters.

Pincode: the filed link now redirects to a homepage

Pincode, PhonePe's ONDC buyer app, is listed on the registry with a filing dated 4 October 2023 at a URL on pincode.com titled "listing-guidelines-and-sorting-mechanism." Requesting that exact URL, as filed on ONDC's own registry, returns a 301 redirect straight to phonepe.com's general homepage, with no sorting-mechanism content anywhere in the chain. The disclosure the network relies on to prove compliance for one of its buyer apps has become, in practical terms, unreachable. Whether that is a domain migration nobody updated on the registry or a deliberate takedown is impossible to tell from the outside, and either explanation should concern a seller who was told this document exists to help them improve their ranking.

PayTM: a disclosure made of pictures

PayTM's filed listing-guidelines page, at paytmmall.com/listingGuidelines, does load. What loads is eleven separate image files, apparently numbered catalogue-guideline slides, with no surrounding text, headings, or alt attributes in the page markup. A sighted user with a fast connection can still read whatever text is baked into those images. A screen reader cannot. Neither can any automated tool trying to verify, at scale, whether the content on the page matches the "plain and intelligible language" standard the underlying rule actually specifies. A disclosure that exists only as unlabelled pictures is a disclosure that technically satisfies "published," while failing the accessibility and machine-readability half of what "plain and intelligible" should mean in 2026.

What a seller can and cannot do with a filing like this

Read generously, the disclosures that are intact and current are genuinely useful. A seller who reads MyStore's filing learns, in plain terms, that keeping delivery SLA violations and complaint rates under 10 percent is not a soft best practice, it is the line between staying listed and being unpublished, and that F&B sellers should weight proximity and delivery speed over keyword-stuffing a title. That is an actionable, free, primary-source insight that most sellers on that app have likely never seen, because it lives on a page named "product-sorting-parameters-for-search-results" that nobody links to from the seller onboarding flow.

Read across the registry as a whole, the picture is thinner. There is no single comparable table anywhere, official or independent, that lines up what Meesho weighs against what Pincode weighs against what Magicpin weighs, because ONDC deliberately left the disclosure format to each app's discretion and never required a common template. A seller listing on three or four buyer apps simultaneously, which is the entire point of an interoperable network, cannot benchmark them against each other without opening every one of those 72 links themselves, and, per the two examples above, some of those links no longer lead anywhere useful.

The government's own MSME onboarding push has not closed that gap either. The Ministry of MSME's MSME Trade Enablement and Marketing Initiative, sanctioned with an outlay of Rs 277.35 crore over 2024 to 2027 and aimed at onboarding five lakh MSMEs onto ONDC through more than 150 awareness workshops, is built around catalogue creation, account setup, and digital literacy for sellers who are not yet on the network at all. Its published scope does not include walking existing sellers through the sorting-parameter disclosures that determine whether their catalogue, once uploaded, is ever actually seen.

What the filings show

None of this means ONDC's disclosure mandate is merely performative. The rule is real, the legal basis is real, the registry is real and centrally maintained, and at least one of the filings examined here contains a quantified rule an MSME could act on today. What the mandate has not produced is a system a typical seller can actually use: a common format, a maintained link, or any built-in path connecting the moment a seller joins ONDC to a clear account of how each app it sells on decides what a buyer sees first. A rule that requires publication but not upkeep, and that explicitly protects the underlying algorithm as a business secret, was likely always going to produce a registry this uneven.

For an MSME, the practical lesson is not to distrust ONDC's framework, it is to treat "we filed a disclosure once" as the floor, not the ceiling, of what a serious buyer app owes its sellers. The filings of more practical value are the ones that are current, specific, and written for a human to act on, rather than the ones filed in 2023 and never revisited. Verifying that costs a seller little more than twenty minutes and the willingness to open a table most people have never heard of.

The evidence

Key findings, with their sources

  • ONDC Notification No. 2023/06/06/01 (6 June 2023) required all Buyer Apps to publish an explanation of sorting parameters and their relative importance, plus minimum search-result display standards, by 9 June 2023, citing Clause 5(3)(f) of the Consumer Protection (E-Commerce) Rules, 2020.

    established ONDC, Notification 2023/06/06/01, "Publishing information on parameters affecting ranking of goods/services or sellers," ondc-static-website-media.s3.ap-south-1.amazonaws.com.

  • ONDC Network Policy, Chapter 2 Business Rules, Clause 2.3.3(k) requires Buyer Apps to disclose "the key parameters of the logic used for sorting/listing search results, to ensure that Sellers are able to improve their ranking on listings or results."

    established ONDC, "Chapter [2]: Business Rules," Version 1.0, 15 September 2022, ondc-static-website-media.s3.ap-south-1.amazonaws.com.

  • In its own published consultation summary on Clause 2.3.3(k), ONDC clarified it does not intend to define algorithms or actual parameters for Buyer Apps, leaving the algorithm to each app's discretion "without actually being required to disclose business secrets."

    established ONDC, "Chapter [2]: Business Rules" (Summary of Consultation, item 14), ondc-static-website-media.s3.ap-south-1.amazonaws.com.

  • As reviewed, the ONDC Disclosures registry lists 20 Buyer App filings and 52 Seller App / Logistics Service Provider filings, 72 combined, dated between 7 August 2023 and 28 November 2024, with several rows still marked "Pending."

    established ONDC Resources & Knowledge Base, "Disclosures," resources.ondc.org/disclosures.

  • MyStore's filed disclosure names search-term relevance and buyer-seller distance as its sorting factors (weighted differently for F&B versus non-F&B), discloses no numeric weights, and states delivery-SLA violations or complaint rates above 10% of orders can trigger delisting.

    established MyStore, "Product Sorting Parameters for Search Results," mystore.in.

  • The sorting-mechanism disclosure URL that Pincode (PhonePe's ONDC buyer app) filed on the ONDC registry now returns a 301 redirect to phonepe.com's general homepage rather than any disclosure content.

    established Direct verification of the filed URL on resources.ondc.org/disclosures, checked August 2026.

  • PayTM's filed listing-guidelines disclosure renders as eleven separate image files with no accompanying text or alt attributes, rather than a text description.

    established Direct verification of paytmmall.com/listingGuidelines, the URL filed on resources.ondc.org/disclosures, checked August 2026.

  • The Ministry of MSME's MSME-TEAM sub-scheme was sanctioned with an outlay of Rs 277.35 crore over 2024-2027 to onboard 5 lakh MSMEs onto ONDC through 150+ awareness workshops focused on catalogue creation, account setup, and onboarding, not on ranking-disclosure literacy.

    established Entrepreneur India, "MSME Ministry Unveils TEAM Initiative with INR 277.35 Cr Budget," January 2025, entrepreneur.com/en-in.

  • ONDC reported 1.16 lakh+ retail sellers live across 630+ cities and towns as of December 2025, out of a broader base of 7+ lakh sellers and service providers onboarded on the network since 2022, the large majority MSMEs.

    established SMEStreet, "ONDC Expands Digital Commerce Access for MSMEs and Local Sellers," smestreet.in.

Calibration

What is proven, what is promising, what is unproven

Evidence tierTacticsWhat the evidence says
establishedThe legal basis for the disclosure mandate, the exact clause text, and the observable state of the public registry (filing counts, dates, dead links, image-only pages).ONDC Notification 2023/06/06/01; ONDC Chapter 2 Business Rules v1.0 + Summary of Consultation; direct read of resources.ondc.org/disclosures and three individual filings.
emergingReading what "key parameters" versus a full algorithm actually leaves a seller able to act on, and what a "good" disclosure filing looks like in practice versus a merely compliant one.ONDC's own consultation-record clarification on Clause 2.3.3(k); comparison of the MyStore, Pincode, and PayTM filings against each other.
contestedWhether the stale and low-quality state of many filings reflects deliberate opacity or ordinary non-maintenance, and how many MSME sellers have ever actually read their buyer app's disclosure.No independent survey of seller awareness or use of the ONDC disclosure registry is publicly available; this piece's framing is an inference from the registry's observable state, not a measured statistic.

Reference

Glossary

Buyer Side App
The ONDC-registered application through which an end customer searches, browses, and orders; responsible under Network Policy for disclosing how it sorts and ranks the seller listings it displays.
Seller Side App
The ONDC-registered application through which a seller or service provider lists goods and services; must disclose any differential treatment it gives to different Buyer Apps.
Clause 2.3.3(k)
The specific provision in ONDC's Network Policy, Chapter 2 Business Rules, requiring Buyer Apps to disclose the key parameters used to sort and list search results, and permitting them to publish uniform minimum display standards.
Ranking parameters disclosure
The plain-language explanation of the main factors that determine how goods or sellers are ranked, required of e-commerce entities under Clause 5(3)(f) of the Consumer Protection (E-Commerce) Rules, 2020, and extended to ONDC Buyer Apps by ONDC notification.
ONDC Gateway
The network component that receives a Buyer App's search request and relays it, without discrimination, to all relevant registered Seller Apps, per Clause 2.2 of the Business Rules.

Straight answers

Frequently asked questions

Is ONDC actually required to disclose how buyer apps rank sellers?

Yes. ONDC's Network Policy, Chapter 2 Business Rules, Clause 2.3.3(k), requires every Buyer App to disclose the key parameters of the logic it uses to sort and list search results, a rule ONDC traces to Clause 5(3)(f) of the Consumer Protection (E-Commerce) Rules, 2020, and enforced through a June 2023 notification with a compliance deadline.

Where can I find my buyer app's ONDC disclosure filing?

ONDC maintains a public registry of every filed disclosure at resources.ondc.org/disclosures, split into Buyer Apps and Seller Apps / Logistics Service Providers tables, with a link to each app's actual filing.

Do ONDC buyer apps have to reveal their full ranking algorithm?

No. In its own published consultation record, ONDC clarified that it does not require Buyer Apps to disclose actual algorithms or parameters, only key factors and fair treatment, "without actually being required to disclose business secrets." The discretion for how much detail to publish sits with each app.

How many buyer and seller apps have filed ONDC disclosures?

As reviewed, the registry lists 20 Buyer App filings and 52 Seller App and logistics-provider filings, 72 combined, filed between August 2023 and November 2024, though some rows remain marked "Pending."

What happens if a buyer app's filed disclosure link is broken?

In at least one case reviewed here, the filed sorting-mechanism URL now redirects to a generic company homepage with no disclosure content. The registry itself does not appear to routinely check that filed links still resolve, so a filing being listed is not proof it is currently readable.

Does this disclosure requirement apply outside ONDC?

The underlying rule, Clause 5(3)(f) of the Consumer Protection (E-Commerce) Rules, 2020, applies to e-commerce entities generally, not only ONDC participants. ONDC's June 2023 notification is its own network-level enforcement of that broader obligation for its registered Buyer Apps.

Provenance

Sources

  1. ONDC, Notification No. 2023/06/06/01, "Publishing information on parameters affecting ranking of goods/services or sellers," 6 June 2023 (primary, established)ondc-static-website-media.s3.ap-south-1.amazonaws.com
  2. ONDC, "Chapter [2]: Business Rules," Version 1.0, including Summary of Consultation on Clause 2.3.3(k) (primary, established)ondc-static-website-media.s3.ap-south-1.amazonaws.com
  3. ONDC Resources & Knowledge Base, "Disclosures" registry (primary, established)resources.ondc.org
  4. MyStore, "Product Sorting Parameters for Search Results" (primary filing, established)mystore.in
  5. Pincode / PhonePe, filed sorting-mechanism URL, verified as redirecting to phonepe.com (primary filing, live-checked)pincode.com
  6. PayTM, filed listing-guidelines URL (primary filing, live-checked)paytmmall.com
  7. Entrepreneur India, "MSME Ministry Unveils TEAM Initiative with INR 277.35 Cr Budget to Empower Small Businesses," January 2025 (established)entrepreneur.com
  8. SMEStreet, "ONDC Expands Digital Commerce Access for MSMEs and Local Sellers" (established)smestreet.in

Every figure above is attributed to a real, dated source and tagged with its evidence tier. Where a claim could not be verified to a primary source, it is not stated as fact.

About this analysis

A ranking-parameter disclosure filed in a government registry is one signal among several that determine how a marketplace decides which sellers buyers see first. The same discoverability question extends across every surface an MSME sells and is found on: classic search, the local map pack, AI answers, and marketplace or ONDC listings alike. Few business owners have a single, consolidated read of where a business stands across those surfaces at once. Raveneye's Machine-Readiness Score is built on the same kind of primary-source verification applied in this analysis, so a business can see what is actually shaping its visibility rather than relying on whichever filing it happens to come across.

diagnostic Surface Intelligence Audit A specialist-reviewed read of where a business stands across search, marketplace and map listings, and AI answers, setting out the parameters and gaps that shape its ranking in plain language. See how it works

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