The Ministry of Corporate Affairs (MCA) has issued a Request for Proposal (RFP) dated November 3, 2025, seeking an agency to conduct a market study on “Qualitative and Quantitative Thresholds for Big Tech Companies and Core Digital Services (CDS).” The study aims to re-examine how India should identify Systemically Significant Digital Enterprises (SSDEs) and determine which digital services fall within the scope of the proposed Digital Competition Bill (DCB).
The RFP marks the government’s first major step since pausing the DCB earlier this year, following concerns that its ex-ante framework could overreach and harm startups and Micro, Small and Medium Enterprises (MSMEs).
Bidders must submit their proposals by December 17, 2025, through the Government e-Marketplace (GeM). The MCA will hold a pre-bid consultation on November 20, conduct technical presentations on January 7 and 8, 2026, and open financial bids on January 15.
The MCA has described the study as a way to gather empirical evidence on how digital market regulation should evolve in India before revisiting the Bill.
What the RFP Seeks to Study
The RFP outlines a detailed plan to review the effectiveness of the DCB’s core provisions. The study will focus on four key areas: thresholds for SSDEs, the scope of Core Digital Services, the legal and institutional framework, and strategies to ensure fair competition while promoting innovation.
1. Thresholds for Systemically Significant Digital Enterprises
The first component of the study will evaluate the DCB’s criteria for identifying SSDEs. Clause 3 of the draft Bill includes both quantitative and qualitative thresholds. The selected agency will assess whether these parameters are suitable for India’s digital ecosystem and propose revised or alternative indicators if necessary.
In addition, the RFP calls for a comparative analysis with global benchmarks such as the European Union’s Digital Markets Act (DMA), Japan’s Fair Digital Platform Act, and South Korea’s amendments to the Telecommunications Business Act. The goal is to determine whether India’s framework should align with these international models or evolve into a context-specific system tailored to domestic realities.
2. Review of Core Digital Services
The second area of inquiry concerns Schedule I of the draft Bill, which lists nine Core Digital Services. The study will examine whether this list is comprehensive and relevant to India’s current market structure. It will also identify key players, assess competition levels, and analyse emerging sectors like quick commerce that were not considered when the original Committee on Digital Competition Law (CDCL) drafted its report.
Furthermore, the agency will assess how ex-ante obligations affect pricing, innovation, and consumer choice across these services, and determine whether additional categories should be included or excluded.
3. Legal and Institutional…
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