A reputed global manufacturer, with international quality certifications and decades of government supply history, applies for vendor assessment on the Government e-Marketplace. The application is rejected repeatedly on documentation grounds, with no guidance on what is missing or how to remedy it. For most foreign manufacturers, GeM vendor assessment has become the single largest barrier to entering India's public procurement market. What does the process actually demand, and how should a foreign manufacturer approach it?
Conventional tendering through the GFR framework and CVC guidelines governs a substantial share of government procurement, but for an increasing share of government purchasing the platform is GeM. The Government e-Marketplace is India's unified public procurement portal. Every central and state government entity is expected to procure goods and services through it. For a manufacturer to sell on GeM as an OEM, it must complete a Vendor Assessment (VA), a document-heavy verification process currently managed by RITES, a railway-sector public enterprise assigned this role.
For Indian companies, the process is procedurally dense but navigable. For foreign original equipment manufacturers, or Indian entities that function as deemed OEMs for products manufactured abroad, the process surfaces a set of structural frictions that go well beyond form-filling. What it actually requires is a sustained, multi-month regulatory engagement across the company's global corporate structure, its Indian legal and compliance teams, the GeM portal's technical architecture, and a verification agency whose mandate is to check documents against a template, not to assess whether the underlying intent of the requirement has been met.
GeM's VA framework was designed with a domestic manufacturing framework in mind. It asks for process flow diagrams of manufacturing, lists of machines used on the shop floor, test reports from Indian or NABL-accredited laboratories, production capacity details per month, and declarations on the nationality and shareholding of every director and significant beneficial owner, extending to parent entities and group companies that share a land border with India. Each of these requirements carries a specific policy rationale. The insistence on Indian quality certification reflects a broader push toward domestic testing infrastructure and a reluctance to treat international certifications, including CE marking and ISO, as automatically equivalent. The ownership and directorate declarations trace back to the 2020 amendments to the General Financial Rules, which restricted public procurement from entities in countries sharing a land border with India unless they met specific registration and clearance conditions.
The Public Procurement Division Order No. 4, dated 23 February 2023, further operationalised these conditions through Clause 26 of the GeM General Terms and Conditions, read with Rule 144(xi) of GFR 2017. The Annexure II undertaking, which must be signed by a registered director of each relevant entity in the corporate chain, operationalises this restriction. Individually, none of these requirements is unreasonable. Collectively, and especially when applied to a multinational corporate structure, they yield a compliance burden that the portal's workflow was not designed to absorb.
A single VA application can require separate director and shareholding disclosures for six, seven, or eight distinct legal entities spread across multiple jurisdictions: a Netherlands holding company, a Delaware-incorporated parent, a Swedish holding entity, a German manufacturing subsidiary, and so on, each with its own board composition and ownership trail. Where the ultimate parent is publicly listed on a stock exchange, the undertaking must account for the fact that its shareholding is dispersed and publicly traded. The applicant must reference securities filings in a foreign jurisdiction, proxy statements filed with a foreign securities regulator, to demonstrate that beneficial ownership does not trace to a land-border country. The declaration that one hundred percent of the ultimate holding company's shareholding is public must be formally executed and submitted alongside the layered entity-by-entity disclosures.
What the Annexure II requirement translates to, operationally, is a coordination exercise that spans the company's Indian legal team, its global corporate secretarial function, entity managers in multiple jurisdictions, and the authorised signatories of each legal entity in the chain. For a single product registration, this can involve aligning fifteen or more individuals across time zones, legal systems, and internal approval hierarchies. Each entity's documents must be executed by a director whose name appears on the relevant corporate registry. For foreign entities, in practice, this requires coordinating notarisation, cross-border validation, internal legal review, and multi-jurisdictional compliance clearances. The lead time for this is not days. It is weeks to months.
The exercise also collides with regulatory obligations in the other direction. The VA process requires passport copies of directors of the overseas manufacturer as part of the Annexure II undertaking. Where those directors are nationals of countries governed by the General Data Protection Regulation or equivalent privacy frameworks, disclosure of personal identity documents to a third-party assessor without the individual's explicit consent, and without a lawful basis recognised under the applicable foreign regulation, creates a compliance conflict that the applicant cannot unilaterally resolve. The applicant is caught between two regulatory systems: comply with the Indian assessment requirement and risk violating European privacy law, or comply with the foreign regulation and fail the VA. The VA framework does not acknowledge this tension, and no alternative mechanism exists to satisfy the identity verification objective through means that are compatible with both jurisdictions. And it must be repeated for each product category, because the VA is product-specific.
An assessment cleared for one product category does not automatically extend to another, even if the applicant entity and its corporate structure remain identical. The strategic calculation for most multinationals, therefore, is to identify one product category, complete the entire documentation exercise for it, get the OEM assessment live on GeM, and then extend to other products sequentially. This is not a one-time registration. It is a sustained regulatory engagement, sequenced product category by product category, that can span months before a single item is listed on the portal.
Many multinationals sell in India through a deemed OEM arrangement: the Indian entity is not the manufacturer but is authorised by the foreign OEM to sell its products in India. On GeM, the deemed OEM must submit not only its own corporate documentation but also brand authorisation letters from the legal manufacturer and deemed OEM declarations, each product-specific and each requiring execution by an authorised signatory of the foreign manufacturing entity. The complexity multiplies when a single Indian entity sells products manufactured by different legal entities within the same multinational group. A scientific instruments company might sell chromatography systems manufactured by one US subsidiary, immunoassay analysers made by a Swedish entity, diagnostic instruments from a German subsidiary, and microbiology systems yielded in the United Kingdom.
GeM's VA requires test reports from Indian government laboratories or NABL-accredited labs, but for many specialised product categories, particularly in scientific instruments and advanced medical devices, no Indian laboratory has the testing capability. The company must either wait for capacity to be built or seek a waiver that has no defined process.
GeM's portal architecture compounds the friction. Certain fields, once submitted, are non-editable. If an error is made during initial registration, it cannot be corrected without raising a support ticket, which has no guaranteed resolution timeline. Category mappings are rigid; a product that falls between two GeM categories may need to be listed under both, each requiring a separate assessment cycle.
RITES conducts document verification against a checklist. Its role is procedural, not discretionary. When a submission does not match the prescribed format, the non-compliance is flagged and returned to the applicant. RITES does not have the institutional mandate to assess whether a substantive compliance threshold has been met despite a formal deviation, nor to grant exemptions for patented products, accept alternative forms of attestation, or override a country-selection error on a locked portal field. The result is a circular dynamic. The applicant's remedy for a procedural non-compliance is to resubmit, but if the underlying issue is structural, resubmission does not resolve the problem. The only pathway is escalation: a direct approach to GeM officials, a request for a meeting, and a case-specific accommodation that sits outside the portal's standard workflow.
The most structurally consequential friction in the VA process is not documentation. It is the mismatch between institutional intent and operational execution. A senior GeM official meets the applicant, understands the constraint, a patented product cannot disclose its process flow, a publicly listed parent cannot yield a shareholding list of named individuals, and provides specific guidance: submit an undertaking, invoices, or alternative documentation in lieu of the prescribed format. The applicant follows the guidance. The third-party verification agency, operating against a checklist, raises a non-compliance on the same grounds the guidance was meant to resolve. The accommodation was verbal. It was not recorded in any system the assessor is bound by. The guidance and the checklist exist in parallel; one reflects the understanding, the other reflects procedural mandate; and the assessor's mandate is the checklist. This cycle can repeat across multiple applications over months, with no resolution.