I. Introduction
India’s quick commerce sector has undergone major transformation in a short span of time. Quick commerce in India has evolved into an ultra-fast retail model, delivering groceries, essentials, household items, electronics and more within ten to thirty minutes. This model is now embedded in the everyday lives of urban Indian consumers. India’s quick commerce market was valued at USD 3.05 billion in financial year (FY) 2024 and is forecast to reach USD 13.38 billion by FY 2032, implying a compound annual growth rate of 20.3% over FY 2025-2032.[2]
This rapid growth raises important questions for competition regulation. Quick commerce does not fit neatly into pre-existing regulatory categories. As discussed below, it resembles marketplace e-commerce in certain respects and inventory-based retail in others. This hybridity complicates competition analysis under India’s existing legal framework.
This article examines potential competition concerns in the quick commerce sector by highlighting the proliferation of quick commerce and its distinctive features; mapping the allegations raised before the Competition Commission of India (CCI); analysing the potential market definition under the Competition Act, 2002 (Competition Act), incorporating insights from international regulators; looking at the plausible analysis under Section 3(4) and Section 4 of the Competition Act, and evaluating how the CCI may look into the market and the associated implications. Finally, the article also highlights potential concerns under the EU’s Digital Markets Act (DMA) and the now withdrawn Digital Competition Bill (DCB).
II. The proliferation of quick commerce in India
As noted in the report published by the 25th Standing Committee on Finance (SCF Report), the quick commerce boom in India is unique and “homegrown”.[3] This growth is driven by a combination of demographic, technological, and economic factors unique to the country’s urban ecosystems.[4] India’s major metropolitan areas are characterised by extremely dense populations, high consumer mobility, intense competition for convenience, and an increasingly digital-first approach to retail.[5] In such environments, instant delivery has found receptive consumers who value the ability to procure necessities at short notice.
‘Dark / ghost stores’ are the operational backbone of quick commerce. These are localised distribution hubs optimised for speed rather than in-store customer experience.[6] Swiggy, Instamart, Zepto and Blinkit together operate over 1,200 dark stores in India.[7] These stores rely heavily on algorithmic inventory management and cater to narrowly defined hyperlocal clusters, generally within a two-kilometre radius. They also operate with far more compressed procurement cycles than traditional supermarkets, often restocking multiple times a day based on real-time analytics.[8] These operational features create cost structures and competitive dynamics that arguably differ significantly from traditional retail stores and e-commerce marketplaces. The expansion of quick commerce has therefore raised several novel questions for competition authorities. The CCI will be required to conduct Section 3 and 4 analyses in a segment where cost structures are unique, and seller relationships are developing. As a result, quick commerce presents both a regulatory challenge as well as an opportunity to shape new precedent in India’s competition law jurisprudence.
III. Allegations raised in India
On 28 February 2025, the All-India Consumer Products Distributors Federation (AICPDF) filed a petition before the CCI against certain quick commerce players, alleging abuse of dominance in the form of deep discounting and predatory pricing practices (Complaint).[9] AICPDF had previously also written a letter to the CCI in October 2024 on similar grounds.[10]
AICPDF contends that e-commerce and quick commerce platforms are selling core FMCG products at prices unsustainable for traditional distributors (at a discount of at least 50% on the price sold in traditional retail), thereby distorting the competitive landscape.[11] They argue that such pricing strategies are designed to build scale and behavioural dependence, which may ultimately dismantle traditional distribution channels.
In addition to pricing concerns, AICPDF also alleges that quick commerce platforms engage in preferential treatment of specific sellers or private-label products.[12] They argue that platforms may be using their extensive control over logistics and search visibility to favour certain sellers, thereby effectively exercising indirect inventory control. This is a particularly sensitive issue in India, where Foreign Direct Investment (FDI) rules strictly differentiate between marketplace models and inventory-based e-commerce and explicitly prohibit foreign-backed marketplaces from controlling or holding inventory.[13] It is argued that quick commerce platforms operate on an inventory-based model (by holding stock in dark stores) while claiming to be marketplaces, which is prohibited for foreign-funded entities. Therefore, any evidence suggesting that a platform influences pricing, procurement, and other inventory decisions could potentially be interpreted as indirect inventory control, triggering not only competition scrutiny but also FDI compliance issues.
Further, the Complaint also highlights adjacent concerns relating to consumer protection, food safety standards, and the localisation of dark stores.
Notably, the SCF Report also discusses the Complaint. In its response to the standing committee’s questions regarding the Complaint, the CCI confirmed that recent allegations of deep discounting by quick commerce companies prompted it to seek substantiating evidence from the informant in order to form a prima facie view and, where warranted, move to inquiry. The CCI’s response clarifies that complaints alleging below-cost pricing by large platforms are actionable in principle, but evidence on market power, cost structures and the design and funding of discounts is critical to trigger an investigation under the Competition Act.
IV. Market definition and the challenge of characterising quick commerce
Defining the relevant market is the analytical foundation of any competition assessment. In the case of quick commerce, this task is unusually complex. As discussed above, its defining features, including hyperlocal dark-stores, algorithmic assortment, and rapid delivery, raise the question of whether it should be understood as a distinct market or as part of the broader e-commerce, retail or FMCG ecosystems.
Under Section 2(s) and 2(t) of the Competition Act, in determining the relevant market, the CCI examines both demand-side and supply-side substitutability. Over the years, the CCI has shifted from treating online and offline markets as distribution channels within a single relevant market to defining them as distinct markets.[14] This shift was evident, for instance, in Delhi Vyapar Mahasangh v. Flipkart, where the CCI distinguished between the two channels and held that online marketplaces constitute a separate relevant market, distinct from traditional brick-and-mortar retail stores.[15] However, from a functional perspective, quick commerce offers a different value proposition from both supermarkets as well as e-commerce. Its defining characteristic is speed. Therefore, the key question before the CCI is whether immediacy or speed constitutes a quality dimension significant enough to justify a separate product market under the Competition Act.
International jurisprudence offers some insight into the issue. The UK Competition and Markets Authority (CMA) has expressly recognised the distinctiveness of rapid delivery. In Amazon / Deliveroo (2020), the CMA examined “online convenience groceries” which it defined as groceries ordered online for delivery within a few hours.[16] Considering the demand‑side substitution between this rapid segment and slower, scheduled online grocery stores, it concluded that the latter is not a close substitute for online convenience grocery.[17] The CMA further explained that brick‑and‑mortar convenience stores do not compete closely with on‑demand delivery, although they may exert out‑of‑market constraints given consumers’ willingness to travel to stores.[18] It further observed that online convenience grocery offerings meet different consumer needs than scheduled online delivery, with immediacy, smaller baskets, and different shopping missions.[19] It also noted limited scope for supply‑side substitution, because many grocers’ existing scheduled delivery operations are not suited to on‑demand logistics without significant investment in capability, routing, courier networks, and fulfilment processes.[20]
While the German Federal Cartel Office (Bundeskartellamt) looked at the rapid grocery delivery market in Gorillas / Getir, the case does not provide guidance on the issue of relevant market definition. However, the Bundeskartellamt assessed online beverage delivery in the Dr. Oetker / Radeberger-Flaschenpost merger, where it described Flaschenpost as an online beverage delivery service and discussed competitive constraints from both stationary food retail outlets and beverage cash-and-carry outlets.[21] Similarly, in Knuspr / Bringmeister, it left open the question as to whether online food retail constitutes a separate market or is to be included in an overall food retail market.[22]
Although not determinative, these insights may prove relevant for India, where quick commerce has evolved in ways that are both similar and distinct. Like many EU and UK operators, Indian platforms rely on dark-store networks and algorithmic pricing. However, Indian models are even more dependent on intensive discounting and high-order frequency, given the demographics of the country, arguably differentiating them further from supermarkets. First, India’s vast base of hyperlocal offline grocers (kiranas) already provide non‑scheduled, near-immediate deliveries. These neighbourhood stores operate within walking or short distances, extend informal credit, and often accept phone or messaging app orders. Second, the economics of the last mile are structurally more favourable in India. Dense urban clusters, ubiquitous two‑wheelers, and a large pool of flexible delivery partners keep costs per delivery low. This lowers the marginal cost and complexity of fulfilment relative to many European markets with higher wages, stricter vehicle rules, and more dispersed demand. Third, mainstream e‑commerce platforms like Amazon and Flipkart also offer relatively quick delivery, further shifting consumer expectations towards immediacy across categories, not just groceries.
The question therefore becomes whether, in the Indian context, there is sufficiently strong evidence that the immediacy of quick commerce is determinative, so as to offset the theoretical substitutability of offline and online retail, as well as substitutability within online retail. If the CCI adopts a broader market definition, encompassing offline supermarkets or even just traditional e-commerce, then dominance becomes less likely, given the intensity of competition across channels and the prevalence of consumer multi-homing.
However, if the CCI ultimately concludes that quick commerce comprises a separate relevant market, the implications for dominance analysis could be substantial (and dominance is a pre-condition to any finding of abuse of dominance). It is unlikely that any one quick commerce player will be found dominant in an India-wide quick commerce market, given the intensity of competition, recent entries, and consumer multi-homing (similar to markets like e-commerce or food aggregation that the CCI has previously analysed). On the other hand, if the CCI takes a different view on geographic market and adopts a narrow market definition based on hyperlocal fulfilment, a platform could be considered dominant within a city or zone, even if it lacks national-level market power.
Thus, as international regulators continue to refine their understanding of rapid-delivery markets, India has the opportunity to align with emerging global standards while adapting them to its own retail and regulatory environment.
V. Dominance analysis under Section 4
Dominance under Section 4 of the Competition Act depends on whether an enterprise enjoys a position of strength enabling it to operate independently of competitive forces or affect the market in its favour, evaluated through the non‑exhaustive factors in Section 19(4) of the Competition Act, including market shares, entry barriers, countervailing buyer power, network effects, and dependence of consumers or sellers. Quick commerce presents a mixed picture. As of Q1FY25, at the national level, Blinkit holds 46% market share in the quick commerce market, with Zepto and Instamart at 29% and 25% respectively, suggesting a national market that is not dominated by any one player.[23] Given the fact that quick commerce relies on hyperlocal networks, it is possible that the CCI will look at the market not at a national but at the city / neighbourhood level, where the competitive realities maybe different. Nevertheless, given the dynamic nature of the market, the market shares fluctuate, and consumers frequently multi-home between apps. In practice, most consumers have multiple quick commerce apps downloaded on their devices, and frequently compare product prices on various platforms before placing their order.
While it may be argued that entry barriers exist, rival platforms continue to invest aggressively, and competition remains intense. In the last few months itself, multiple new players have also entered the market, suggesting that the barriers to entry are surmountable and the market is getting more competitive day-by-day. Amazon launched its quick commerce service, ‘Amazon Now’, in India with a pilot program in December 2024, followed by an official, broader launch in Bengaluru in June 2025.[24] Flipkart also launched ‘Flipkart Minutes’ in August 2024, marking its entry into the market.[25] Overall, India tops the quick commerce landscape with approximately 50 quick commerce related enterprises, ahead of the United States with 15 and the United Kingdom with 13.[26]
Additionally, even if the CCI ultimately concludes that dominance cannot be established, certain practices may still be vulnerable under Section 3(4) of the Competition Act, which addresses vertical restraints. This aspect is not covered by the allegations levied by AICPDF, but remains a potential area of concern, as noted in the SCF Report. For example, actions like exclusive arrangements with sellers could all fall within the ambit of Section 3(4) even in the absence of dominance under the Competition Act, considering positions that the CCI has taken previously. Having said that, any analysis under Section 3(4) would require a clear demonstration of appreciable adverse effect on competition (AAEC), which would include balancing the pro-competitive and pro-consumer benefits of these quick commerce platforms with their alleged anti-competitive outcomes. As noted by the Supreme Court in CCI v. Schott Glass, net competitive harm must be shown before liability can attach.[27] This requires the CCI to undertake a balancing exercise of the conduct’s likely anti-competitive impact against any demonstrated efficiencies that accrue to consumers.
Finally, consolidation in rapid delivery could also attract scrutiny under the merger control regime in light of introduction of the Deal Value Thresholds (DVT) by the Competition (Amendment) Act, 2023 (2023 Amendment Act), which captures high‑value digital combinations even where traditional financial thresholds are not met, facilitating review of acquisitions that could potentially entrench market power in dark‑store networks.
VI. Concerns under the DMA and erstwhile DCB
While competition law provides a case-specific, ex-post framework, many of the concerns in quick commerce overlap with issues addressed by emerging ex-ante regulation. India’s now withdrawn DCB and the EU’s DMA offer forward-looking models for regulating the structural power of digital platforms. These frameworks become relevant if large quick commerce platforms are designated as ‘systemically significant digital enterprises’ under the DCB or ‘gatekeepers’ under the DMA. The following concerns can arise in the context of quick commerce players:
(i) Self-preferencing: One of the most significant concerns for ex-ante regulation is self-preferencing. Quick commerce platforms, by virtue of controlling both the marketplace interface and the fulfilment infrastructure, may have the ability and incentive to favour private-label products or affiliated sellers. The DMA specifically prohibits such conduct under Article 6(5).
(ii) Data-use: Another area of concern is data use. Quick commerce platforms generate data relating to consumer behaviour, hyper-local demand patterns, pricing sensitivity and seller performance. If dominant platforms use any non-public data generated by independent sellers to design competing private-labels or to optimise/prioritise their own inventory, this may raise questions of unfair leveraging and self-preferencing. The DMA addresses this explicitly, under Article 5(2)(a)-(d) and Article 6(2). Article 5(2)(a)-(d) prohibits gatekeepers from using non-public data generated by business users or their customers to compete against those business users, including for the development or positioning of private-label products. Article 6(2) further requires gatekeepers to ensure effective technical and organisational separation between data collected from third-party business users and data used for their own commercial activities, unless such data use is strictly necessary and appropriately safeguarded.
(iii) Logistics and delivery: Control over logistics and delivery infrastructure is also central to the quick commerce model. Platforms may be able to determine which sellers receive faster delivery slots or more reliable logistics allocation. Such control could influence competition among brands and create obstacles for sellers who do not align with the platform’s commercial priorities. The DMA requires gatekeepers to offer business users fair, reasonable, and non‑discriminatory conditions of access to key services, creating a non‑discrimination baseline for how access affects distribution and visibility under Article 6(12). It also prevents tying of gatekeeper IDs, browser engines, or payment rails, reducing leverage over related infrastructure under Article 5(7).
(iv) Algorithmic pricing: Algorithmic pricing presents yet another dimension of concern. Quick commerce platforms frequently engage in personalised or dynamic pricing based on behavioural insights, such as purchase history, location, time of day or inferred willingness to pay. While such pricing can improve efficiency, it raises concerns around transparency, potential discrimination, and the use of behavioural nudges that may distort consumer choice. International regulators have begun to scrutinise such practices more closely, and ex-ante regimes seek to impose disclosure, auditability and fairness obligations on the use of algorithmic pricing. The DMA adds transparency by requiring an independent audit and description of the profiling techniques used across core services: what data is used, how and why it is processed, how long it is kept and how user consent is obtained. This helps scrutinise personalised and dynamic pricing under Article 15. In parallel, the DMA also targets the design-based manipulation that can accompany algorithmic pricing. Articles 13(3)-(7) prohibit gatekeepers from undermining user choice through design/interface tricks or behavioural techniques (commonly referred to as dark patterns) and forbids lowering of quality when users exercise their legal rights. Together, these provisions aim to ensure that algorithmic pricing does not operate in a manner that covertly steers consumer behaviour or penalises informed choice.
The DCB framework mirrored the above concerns in the DMA. In light of concerns raised by global tech majors, domestic platforms, and other parts of the government during inter-ministerial consultations, the Government of India withdrew the DCB in August 2025.[28] However, the Ministry of Corporate Affairs has already commissioned a comprehensive market study, involving consultations with other ministries and extensive engagement with industry stakeholders, before coming up with a new legislation.[29] The request for proposal identifies e-commerce platforms, but not specifically quick commerce platforms, as one of the stakeholders in the market study.[30]
Concurrently, the 2023 Amendment Act has enhanced the CCI’s toolkit with settlements and commitments, enabling timely, proportionate remedies for digital conduct, and introduced the DVT to capture strategic combinations. The CCI has also established a Digital Markets Division to develop specialist capacity for complex platform cases.[31]
Therefore, taken together, these concerns and the ongoing market study suggest that quick commerce is likely become a significant focus of India’s digital regulation efforts, especially as platforms grow and consolidate.
VII. Conclusion
Quick commerce represents a transformative shift in India’s retail economy. Its appeal lies in its efficiency and convenience, but its operation raises complex questions for competition law. The CCI will likely need to address several novel issues, including whether quick commerce constitutes a distinct relevant market, how dominance should be assessed in hyperlocal delivery ecosystems, how platform-seller relationships should be evaluated, and how any potential anti-competitive effects must be weighed against the pro-competitive, pro-consumer benefits that a new market segment brings.
The regulatory landscape for quick commerce in India is also evolving rapidly, and stakeholders across the ecosystem including platforms, brands, sellers, investors, and policymakers, must prepare for heightened scrutiny under both competition law and digital regulation.
For platforms, the most immediate challenge is to anticipate the direction of market definition analysis. If the CCI adopts an approach aligned with the practices of CMA, it may conclude that quick commerce forms a distinct market characterised by the immediacy of service, the reliance on dark stores, and the behavioural patterns of consumers. Platforms may therefore need to gather extensive economic evidence demonstrating substitutability with offline retail or traditional e-commerce in order to avoid being categorised as dominant within narrowly defined quick commerce markets. They must also prepare for increased scrutiny of their seller relationships, especially any arrangements that could be interpreted as granting preferential visibility or logistic prioritisation to certain sellers or private labels. Seller‑facing transparency on search ranking, discounting rules, and contract changes - areas highlighted in the CCI’s e‑commerce market study - can mitigate risk under both Sections 3 and 4 of the Competition Act.
Further, in line with the CCI’s market studies on e-commerce and artificial intelligence, the CCI should consider whether a focused study on the quick commerce market, highlighting concerns, best-practices and self-regulation guidelines, will prove beneficial for all the stakeholders involved. The CCI has an opportunity to be a first-mover in this regard, considering the widespread growth of the market in India and the lack of guidance from foreign regulators.
Ultimately, the sustainability of the quick commerce ecosystem will depend on coordinated regulatory oversight. Competition authorities, consumer protection bodies, food safety regulators, labour regulators, and agencies involved in digital infrastructure such as Open Network for Digital Commerce (i.e., ONDC) must collaborate to ensure that innovation is not stifled while maintaining safeguards for fair competition and consumer welfare. By embracing a proactive compliance culture and transparent operational practices, industry stakeholders can ensure that quick commerce continues to deliver value without sacrificing fairness or accountability.
