GeM incident management: raising, appeals and suspension

An incident on GeM is the platform’s formal record of a deviation — anything you did (or failed to do) that varies from GeM’s terms and conditions of procurement. It can be raised against a bid, a contract or a catalogue, and it’s the mechanism through which a delivery dispute turns into a suspension that locks you out of bidding for 30, 60 or 365 days.

GeM runs on self-declaration, so it polices behaviour hard on the back end. The current Incident Management Policy (effective 21 July 2025, document GeM/Transition/IM/V14.9) spells out exactly who can raise an incident, what the timelines are, and what a suspension costs. Most sellers never read it until they’re already inside a show-cause window. Read it now instead — here’s the whole machinery, with the day-counts that matter.

Who raises incidents, and what triggers them

Five parties can raise an incident: the buyer, the seller or service provider (yes, you can raise one against a buyer), GeM Admin, a verifying agency appointed by GeM — and the GeM system itself, which auto-raises incidents from platform data. Nobody has to complain for some deviations to be caught.

What triggers an incident against a seller

The common triggers on the seller side:

• Non-delivery or incomplete delivery. The classic. You accepted the order and didn’t ship, or shipped short or late. (The policy notes these incidents close once the CRAC — the consignee’s receipt and acceptance certificate — is generated, so delivery genuinely completed is your way out.)
• Quality rejection. Supplying goods of inferior or substandard quality against the contract, or delivering fake, counterfeit or refurbished products — the latter is treated far more harshly.
• Wrong catalogue claims. Listing products with specifications, certifications or OEM status you can’t back up. Catalogue incidents are pre-contract incidents, and there’s no rectification option on those — the offending offering gets removed and action follows.
• Service-contract failures. Non-compliance on service contracts, not honouring warranty obligations, delaying wages or statutory payments (PF, ESI) for staff deployed at the buyer’s site.
• Not producing documents — certificates, test reports — when asked during inspection or assessment.
• Missing the paperwork after the award. Not furnishing the performance security (ePBG) on time, or entering incorrect shipment details that trigger an automatic CRAC, are listed incident reasons of their own.

The four severity grades

Deviations are graded into four severity levels: mild (impacts other stakeholders), serious (potential to adversely impact the market ecosystem), severe (adversely affects the procurement process or breach of contract), and grave (damages the credibility of the platform itself). The severity grade drives everything that follows, and GeM Admin has discretion to assign a level where a deviation isn’t already listed.

Incidents you can raise against a buyer

Annexure 1 also lists buyer-side reasons a seller can raise, all graded mild: delay in CRAC generation, delay in payment after CRAC, cancelling a contract after you’ve accepted it, refusing to receive the consignment, and rejecting goods without a valid reason. If a buyer is sitting on your CRAC or your payment, this is the formal route, and it builds a record you can point to later.

Which incident reasons carry which penalty?

Annexure 1 of the policy fixes a severity for each incident reason, and the severity sets the suspension. Here are the reasons sellers run into most, with the period for a first or second deviation and whether the fulfilment discount (more on that below) can apply.

Incident reason (Annexure 1)	Severity	1st/2nd deviation	Discount possible?
Listing in wrong category, or with wrong specs/image	Mild	30 days	Yes
Non-delivery or refusal to supply on a Direct Purchase / L1 order	Mild	30 days	Yes
Inferior quality, contract up to ₹10 lakh	Mild	30 days	No
Not producing documents or test reports at inspection	Mild	30 days	No
Non-delivery after bid/RA, contract up to ₹10 lakh	Serious	45 days	Yes
Withdrawing or modifying a bid within validity, up to ₹10 lakh	Serious	45 days	No
Misdeclaring country of origin, Make in India content or MRP	Serious	45 days	No
Inferior quality or unhonoured warranty, contract above ₹10 lakh	Serious	45 days	No
Non-delivery after bid/RA, contract above ₹10 lakh	Severe	60 days	Yes
Refusing to supply after a bid/RA contract	Severe	60 days	Yes
Not furnishing the performance security on time	Severe	60 days	No
Fake, counterfeit or refurbished products	Severe	60 days	No
Incorrect shipment details leading to auto CRAC	Severe	60 days	No
Violating one-bid-per-bidder (GTC Clause 29)	Severe	60 days	No
Fake documents, false certification claims, offline contract after a GeM bid	Grave	365 days	No

Two items close themselves once you fix the cause. A missing performance security incident is closed and your account restored when the PBG is furnished. Unpaid transaction charges or AMC are graded grave and handled as a temporary moratorium of up to 2 years or until you pay, with restoration within 24 hours of payment.

The timeline: 7 days to resolve, 5 to respond, 10 before the system acts

For post-contract incidents, the sequence runs like this. Every number below is calendar days, from the policy itself.

Stage	Window
Resolution between buyer and seller before escalation	7 days from incident creation
Incidents created by GeM Admin	Escalate after 48 hours
Your response to the show-cause notice (SCN)	5 days (warning if silent)
System acts automatically if SCN still unanswered	10 days after SCN issue
Reply to a “further clarification” from GeM Admin	5 days
Reminder to the raising party if not escalated	Day 22 from creation
Auto-closure if the raising party never escalates	37 days from creation

Stage one: resolution. Once an incident is raised, the party it’s raised against gets a resolution period of 7 calendar days to rectify the deviation and report it through the IM module. Fix it here and the reporter can close the incident — no further action, no mark. This window is the cheapest exit you will ever get. Use it.

Stage two: escalation and show-cause. If nothing’s resolved, the reporter escalates to GeM Admin and a show-cause notice lands on your dashboard. You’re expected to respond, or report corrective action, within 5 calendar days. Miss that and the system issues a warning. If you still haven’t clicked “respond to SCN” 10 days after issue, the system takes action against you automatically — no human review of your side, because you never gave one.

Stage three: clarification and decision. GeM Admin may seek further clarification after your response; you get 5 calendar days to answer. Then GeM decides on facts and merits. One procedural point: everything happens on the IM dashboard. Emails don’t count as responses, and you’re not supposed to reveal identifying details (names, phone numbers) in dashboard comments.

If the raising party never escalates at all, the system closes the incident 37 days after creation. One more rule worth knowing: the policy version that governs your case is the one in force on the date the incident was created, not the date it’s decided.

How to answer a show-cause notice

The policy doesn’t prescribe a format for your reply, so what follows is practice, not rule. The rule part is short: reply on the IM dashboard, inside 5 days, without names or phone numbers. Everything else is about giving the decision-maker a reason to close the incident.

Know who will read your reply

For most incident reasons, GeM Admin decides on platform data plus both sides’ comments. But a set of reasons can’t be checked from data alone: quality complaints, warranty, service non-compliance, wages and PF/ESI, fake products, missing documents and incorrect shipment details. When a buyer raises one of those, clause 2.2(ii) sends your reply to the buyer organisation first. Its Competent Authority reviews it and uploads a decision, and GeM acts only after that.

So for those reasons, your reader is a senior officer in the buyer organisation as well as GeM. Keep it factual, dated and polite.

Evidence worth attaching

Match the evidence to the incident reason. Useful documents, depending on the case:

• Delivery disputes: dispatch proof (LR or docket number, e-way bill), signed delivery challan, the PRC if the consignee issued one, and any written request you made to extend the delivery period.
• Delays you didn’t cause: the buyer’s own communications, or your force majeure notice. The GeM GTC requires that notice, with supporting documents, within 10 days of the event.
• Quality and specification complaints: test reports, certificates and OEM authorisation matching the contract specification.
• Performance security: proof of submission and the date the buyer received it.

Strip identifying details from attachments where you can, since the policy bars them on the dashboard. And if you’ve already fixed the problem, say so plainly and attach the proof. The policy lets you report corrective action as your SCN response.

Your SCN reply is your real defence. The appeal only hears evidence you couldn’t have produced the first time.

Rectification: a second chance, but only with buyer consent

The policy gives sellers a real rectification path after escalation, and it’s worth understanding precisely because the windows are short.

Within 5 calendar days of receiving the SCN, you can express willingness to rectify the deviation, on the IM dashboard itself. The buyer then has 5 calendar days to consent. No response from the buyer in that window is treated as no consent, and GeM proceeds under the policy.

If the buyer does consent, the incident is marked “Corrective Action Initiated”, you fix the problem, and both sides confirm the rectification with documents. The buyer can then close it through mutual resolution — though any liquidated damages remain the buyer’s call under the contract.

Two catches. If you commit to rectify and then don’t deliver, the buyer can re-escalate after 10 calendar days, and now you’re facing the original incident with a broken promise attached. And there’s no rectification option at all for pre-contract (catalogue) incidents.

Mutual closure, even after action is taken

Clause 10 of the policy leaves one more door open. Once the deviation is resolved, you can raise a mutual closure request. Before action is taken, the buyer can accept it. After action, the request goes to the buyer’s primary user (HOD), and if they approve, the incident closes and all its impact is removed.

You get one request to the buyer and one to the HOD. The option isn’t available on pre-contract incidents, or on incidents raised by GeM Admin or the system.

What suspension actually costs — the day-counts

If your explanation is found unsatisfactory, suspension follows, graded by severity and repetition:

Severity	1st & 2nd deviation	3rd & subsequent	Repeat window
Mild	30 days	45 days	within 90 days
Serious	45 days	60 days	within 120 days
Severe	60 days	90 days	within 180 days
Grave	365 days	—	—

Suspension can run up to 2 years with the approval of GeM’s Chief Marketplace Officer. Mild, serious and severe cases are typically handled through a “temporary moratorium”, which bites the same way in practice: you can’t participate in bids or RAs, your catalogues come down, you can’t add or update offerings, and your dashboard access is restricted.

You can still complete transactions already finalised — deliveries and payments on existing orders continue. The suspension and your incident history are visible on the marketplace, and they hit your seller rating.

What happens to your running orders and open bids

Running contracts carry on: you deliver, the consignee issues the CRAC, and you get paid. Open bids depend on which kind of restriction you’re under. Clause 11 checks a suspended seller’s status at two points:

• At bid opening: a suspended seller is automatically marked “disqualified due to suspension” in technical evaluation.
• Before the contract, when the buyer creates the demand: the offer is disqualified the same way, and L2 is treated as L1.

Under a temporary moratorium, bids you had already submitted are processed as usual. OEMs face an extra layer under clause 15: five or more incidents within 90 days of action on certain reasons (wrong category or specifications, brand or OEM-rights misuse, fake documents), or a single Rule 144(xi) misdeclaration, removes the brand, the OEM dashboard and all catalogues.

The GeM GTC (Version 1.29, 25 March 2026) widens the blast radius further. Allied firms are hit equally by action against any one of them. So are separate proprietorship concerns registered under the same PAN.

The fulfilment discount, and where it doesn’t apply

There’s a genuinely useful mitigation clause here. If you had at least 20 contracts in the past year and no more than two same-reason incidents in the last 30 days, your fulfilment rate buys the period down: 98%+ fulfilment cuts the suspension to 30% of the standard period, 95–98% to 40%, and 90–95% to 50%. Minimums of 10, 15 and 20 days apply for mild, serious and severe. “Fulfilled” means every CRAC on the contract is generated.

The catch is clause 7.3: the discount applies only to incident reasons marked eligible in Annexure 1. Non-delivery, refusal to supply and several catalogue reasons qualify. Quality, warranty, fake products, missing performance security and misdeclarations don’t. Neither do grave incidents or buyer-ordered debarments.

There’s a separate reduction where the complaining buyer itself owes you payment beyond timelines on more than two contracts with CRAC generated. The clause says “reduced to 30%”, while the policy’s worked examples apply it as a further 30% cut; either way the same floors hold. The worked matrix shows a first mild deviation with 98%+ fulfilment falling from 30 days to the 10-day floor. Your track record is literally a discount on future punishment; protect it.

Suspension vs debarment: different animals

Suspension is GeM’s own administrative action under this policy. Debarment is a different track: a buyer organisation, ministry, state or the Department of Expenditure conducts its own proceedings under its own guidelines and issues a debarment order — signed at Joint Secretary/Additional Secretary level (GM and above for CPSEs). GeM then implements it on the platform, and on that SCN you can only contest clerical discrepancies in the entry, not the merits of the debarment itself.

A Department of Expenditure debarment blocks you for all buyers on GeM, for the entire order period, and buyer organisations can name allied firms for action alongside the debarred one.

Banning, blacklisting, suspension: the same word in DoE rules

In the Department of Expenditure’s debarment guidelines (OM No. F.1/20/2018-PPD of 2 November 2021, reproduced in the Manual for Procurement of Goods, Second Edition, 2024), “banning”, “suspension” and “black-listing” all carry the same meaning as debarment. GeM’s IM-policy suspension is a separate, platform-level thing.

Action	Who orders it	Scope	Maximum
Suspension / temporary moratorium	GeM, under the IM Policy	GeM marketplace	365 days standard; up to 2 years with CMO approval
Debarment by GeM	GeM, under the GTC and DoE guidelines	GeM portal	Up to 2 years
Debarment by one ministry	That ministry or its delegated CPSE/body	Its own offices and CPSEs	Up to 2 years
Debarment across all ministries	Department of Expenditure	All central ministries and CPSEs	Up to 3 years (GFR Rule 151 convictions)

The GTC adds one GeM-specific debarment: withdrawing a bid within its validity, false bid documents, or failing to furnish the performance security can forfeit your bid security, and GeM may debar you for a minimum of 3 months on a first offence.

What the DoE guidelines promise you

Under the 2024 Manual, the debarring body must give you a reasonable opportunity to represent, including a personal hearing if you ask for one. The order must state its reasons, ordinarily runs at least six months, and doesn’t touch contracts concluded before it was issued. The Manual’s suggested timeline runs about 12 weeks from noticing the default to the final order, with 2 weeks to appeal to the ministry’s Secretary.

The appeal: one shot, ten days, no pause

The appeal provisions are tight, so treat them as a scalpel rather than a safety net:

• File within 10 calendar days of the suspension or temporary moratorium being imposed.
• One appeal per incident. There is no second appeal.
• Grounds must be additional material evidence that wasn’t available when the decision was taken — not a rehash of arguments already made.
• The suspension remains in effect during the appeal, whatever the outcome.
• The appellate authority can decrease the period — or increase it.
• If you don’t answer clarifications on the appeal within 5 calendar days, GeM Admin can decide on what it has.
• No appeal on GeM for buyer-specific debarments, or for the clause 2.2(ii) reasons decided by the buyer’s Competent Authority (quality, warranty, service non-compliance, wages, PF/ESI, fake products, missing documents). Those you take up with the buyer organisation outside the platform.

The practical implication: the SCN response is your real defence, not the appeal. By appeal stage you need new evidence, you’re already suspended, and you have one attempt. Put your best, documented case in at the show-cause stage, inside the 5-day window.

Check the classification before you accept the period

Separately from the appeal, clause 12 lets GeM’s CEO or CVO condone a period in part or in full, or enhance it, depending on the circumstances. And the severity table binds GeM too. In ANV Digi Solutions Pvt. Ltd. v. Government e-Marketplace (W.P.(C) 11136/2026, decided 6 October 2026), the Delhi High Court cut two 365-day suspensions for one-bid-per-bidder violations to 90 days. Annexure 1 classes that reason as severe, and 90 days is the severe maximum.

The court didn’t rule on whether the violation happened. It only held GeM to its own table, which is why it pays to compare the period you got with the severity Annexure 1 assigns to your incident reason.

How to never need any of this

Every suspension I’ve seen up close traces back to a decision made before the incident existed. The prevention list is short and boring.

Before you bid or list

• Treat every live listing and every bid as a commitment, because it is. Under the GTC, a Direct Purchase or L1 order on your listed stock needs no acceptance from you, and declining one can itself draw an incident. Refusing to supply after a bid or RA contract is graded severe. So the real decision point is when you list stock or submit a bid, not when the order lands. I went deeper on order discipline in the GeM seller playbook.
• Quote delivery windows you can miss by a week and still meet. Buffer is not weakness. The policy counts calendar days; so should your planning.
• Keep your catalogue honest. Every specification and certification you claim is a deviation waiting to be reported if it isn’t true. Catalogue incidents have no rectification path.
• One firm, one bid. Under GTC Clause 29, bids from a sister concern or related party count as multiple bids from you. All of them are rejected, the bid security is forfeited, and the violation is a severe incident.

After the contract lands

• Furnish the ePBG inside 15 days. The GTC gives you 15 days from award for performance security on bid/RA contracts, and payments only fall due after the buyer receives and verifies it. Missing it is a severe incident.
• Enter shipment and invoice details exactly. Incorrect shipment details that trigger an automatic CRAC are a severe incident of their own.
• Ask for a delivery extension before the period expires, not after. The GTC lets the buyer extend on your request, usually with liquidated damages of 0.5% per week, capped at 5% of contract value (10% for inordinate delay). That costs money, but far less than a non-delivery incident that takes your account offline.
• Get the CRAC generated, always. It closes non-delivery incidents, it’s your proof of acceptance, and it’s the same document that starts your payment clock under the MSME 45-day payment rule. Chase it as hard as you chase the money.
• Pay GeM’s transaction charges on time. Non-payment is graded grave and handled as a temporary moratorium until you pay.
• Watch your dashboard daily when anything is disputed. SCNs appear on the dashboard, and the clocks — 5 days, 10 days — run whether you’ve seen the notice or not.
• Respond to everything, in the window, with documents. Silence is the one strategy the policy punishes automatically.

The same discipline that keeps your bids from getting rejected keeps your account from getting suspended: read what you’re agreeing to, claim only what you can prove, and answer every notice in writing, on time. GeM’s incident machinery is strict, but it’s also predictable — and predictable systems reward the seller who knows the day-counts cold.