Deemed ownership works. Adoption remains concentrated.

Four thousand four hundred and twenty-four.

That is how many “Transfer to Dealer” transactions the VAHAN public dashboard recorded across India from 1 January to 31 July 2026.

Cars24 generated 2,190 Form 29C uploads over the same period, according to Cars24’s internal deemed-ownership dashboard.

That is 49.5%. Roughly one in every two.

This is the clearest answer I have found to a simple question: how widely is India actually using deemed ownership?

When one operator accounts for about half of the national count, usage is clearly concentrated. My read is that the rail works wherever a dealer builds it into the handover; the market has yet to make that routine.

What exactly is being counted?

Deemed ownership is the legal bridge between a car seller and the car’s eventual buyer.

When the registered owner and an authorised dealer jointly sign and submit Form 29C electronically, the dealer becomes the deemed owner for the period in between. Responsibility then follows the dealer while the car is inspected, repaired, moved, displayed and resold. The process was created through G.S.R. 901(E), issued on 22 December 2022 .

The rules took effect on 1 April 2023. Rule 55B requires the joint electronic submission and provides for an acknowledgement from the portal. Rule 55C then places responsibility for the vehicle’s relevant documents and incidents on the dealer during custody.

For a seller, that acknowledgement is the important artefact. It converts a private handover into a government-recorded change in responsibility. The RC can remain in the seller’s name until the final transfer, while the dealer’s deemed-owner status covers the period in between. The timing of Form 29C therefore matters as much as the sale receipt.

This explainer on how deemed ownership works walks through Form 29C, the dealer’s role and the difference between deemed ownership and the eventual RC transfer.

An ordinary sale receipt does not, by itself, update the government’s registration record. In Naveen Kumar v. Vijay Kumar , the Supreme Court held that the person whose name remains in the registration record continues to be treated as the owner under the Motor Vehicles Act.

That gap between commercial sale and legal transfer is the problem deemed ownership is meant to solve. I explained the underlying risk earlier in this series: what happens when you sell your car but the RC is not transferred .

The VAHAN number records use of that administrative rail under the “Transfer to Dealer” category. It should be read as 4,424 recorded transactions during the seven-month period, rather than as a proxy for used-car sales or the number of dealers eligible to use deemed ownership.

An administrative count is useful because it captures action. A national adoption rate would also require a reliable denominator for every eligible dealer handover, which the public dashboard does not provide. The defensible conclusion from the available numbers is narrower: usage exists, and one operator accounts for 49.5% of it.

How many authorised-dealer registrations are on VAHAN?

Dealer registration shows a second kind of concentration.

On 3 August 2026, the VAHAN Dealer Authorisation portal listed 1,969 authorised-dealer registration records across its 36 state and Union Territory entries. This is a count of portal records and authorisation certificates, not necessarily 1,969 distinct dealer companies. Under the current framework, a dealer can hold registrations tied to different registering authorities.

Kerala accounted for 860 records, or 43.7% of the national total. West Bengal had 326 and Rajasthan 261. Together, those three states accounted for 1,447 registrations, or 73.5% of the total. Fourteen of the 36 state and Union Territory entries showed zero registrations.

We estimate that India has more than 50,000 used-car dealers. VAHAN’s 1,969 authorisation records amount to no more than 3.9% of that base. The share of distinct dealer businesses represented on the portal could be lower because one dealer can hold more than one registration.

More than three years after the rules took effect, this registration gap is one likely reason the national transaction count remains low. A dealer outside the authorisation system cannot complete a Form 29C handover.

• Andaman & Nicobar Island: 3
• Andhra Pradesh: 1
• Arunachal Pradesh: 0
• Assam: 112
• Bihar: 24
• Chandigarh: 0
• Chhattisgarh: 17
• Delhi: 0
• Goa: 0
• Gujarat: 8
• Haryana: 1
• Himachal Pradesh: 4
• Jammu and Kashmir: 29
• Jharkhand: 15
• Karnataka: 0
• Kerala: 860
• Ladakh: 0
• Lakshadweep: 0
• Madhya Pradesh: 36
• Maharashtra: 16
• Manipur: 0
• Meghalaya: 0
• Mizoram: 0
• Nagaland: 3
• Odisha: 114
• Puducherry: 0
• Punjab: 2
• Rajasthan: 261
• Sikkim: 1
• Tamil Nadu: 57
• Telangana: 0
• Tripura: 0
• UT of DNH and DD: 0
• Uttarakhand: 77
• Uttar Pradesh: 2
• West Bengal: 326
• India total: 1,969

A zero in this list means that the public VAHAN list returned no authorised-dealer record for that jurisdiction on 3 August. It does not, by itself, prove that the jurisdiction has not legally enabled the framework. Nor should 1,969 be used as the denominator for the share of eligible handovers: registrations describe the available dealer infrastructure, not the transaction universe.

But the distribution is still revealing. Nearly three quarters of registration records sit in three states, while fourteen state and Union Territory entries show none. The infrastructure is as concentrated as the usage.

Why does the Cars24 share matter?

The 49.5% figure measures the use of a public administrative process, rather than used-car market share. For the comparison, we counted Cars24 cases with a Form 29C upload date between 1 January and 31 July, matching the VAHAN period. Raw rows and distinct case IDs each returned 2,190, and every case in the period was completed.

For Cars24, Form 29C is part of the operating loop. The handover is not complete merely because the car has reached our yard and the seller has been paid. The legal bridge matters too. We have built teams, controls and reconciliation around it because the paperwork determines who carries the risk while the car is with us.

That operating loop followed the slower work of earning authorised-dealer status across multiple states . Registration made the process available to us. Cars24 reached this share by doing the paperwork and making the filing part of the transaction.

The 49.5% share says two things. Thousands of transactions show that the reform can be used when an operator makes the filing part of everyday execution. The same share shows how concentrated national usage remains. Adoption arrives only when the law, the portal and the form become one everyday operating process.

Why has deemed ownership not yet become routine?

The filing still has to compete with the way the used-car market has worked for years. A dealer has to register, collect the right information at handover, file Form 29C, preserve the acknowledgement, train the operating team, reconcile exceptions and accept the responsibility that comes with legal custody.

If any one of those steps sits outside the transaction flow, the old habit wins. The car changes hands commercially while the government record waits for the final buyer. Digitising the form helps; changing the market requires dealers to make the compliant path their default operating path. That is the remaining work.

What should happen to Cars24’s 49.5% share?

It should fall.

I would be happy to see our number of filings rise while our share of the national total falls. That would mean more dealers are using the same legal bridge and the denominator is expanding faster than our own count.

The opposite result would be easy to misread. If Cars24’s filings rise while the national total barely moves, our execution is improving but the reform remains concentrated. If the national total grows faster and our share falls, the framework is spreading. Both the numerator and the denominator matter.

The outcome that matters is a protected seller, whichever compliant dealer receives the car. The public count gives the market a baseline that anyone can revisit. Future updates should show both a bigger total and growth from a wider group of dealers using the process routinely.

Dealer registration must lead all the way through to handover, Form 29C acknowledgement and exception reconciliation, with the same discipline applied to payment and inventory.

The reform is not failing. It is waiting to become normal.

Next: The official clock says fourteen days. What does the system actually take?

Frequently asked questions

What is deemed ownership of a used car in India?

Deemed ownership is the legal status an authorised dealer assumes after the dealer and registered owner complete Form 29C. It covers the period between the dealer taking custody of a vehicle and its eventual transfer to the next buyer.

What is Form 29C?

Form 29C records the delivery of a motor vehicle by its registered owner to an authorised dealer. Once the transaction is recorded, the dealer assumes the responsibilities attached to deemed ownership while the vehicle remains in its custody.

How many Transfer to Dealer transactions were recorded from January to July 2026?

The VAHAN public dashboard recorded 4,424 “Transfer to Dealer” transactions across India from 1 January to 31 July 2026.

How many of those transactions came from Cars24?

Cars24 recorded 2,190 Form 29C uploads over the same seven months. That equals 49.5% of the 4,424 transactions shown on the national dashboard.

How many authorised-dealer registrations are listed on VAHAN?

The VAHAN Dealer Authorisation portal listed 1,969 registration records on 3 August 2026. Kerala accounted for 860, or 43.7%. Fourteen of the portal’s 36 state and Union Territory entries showed zero registrations. These are authorisation records, not necessarily distinct dealer companies.

What share of India’s used-car dealers are registered for deemed ownership?

Against Cars24’s current market estimate of more than 50,000 used-car dealers, 1,969 VAHAN authorisation records equal no more than 3.9%. The share of distinct dealer businesses represented could be lower because a dealer can hold more than one registration.

Why is deemed ownership adoption still concentrated?

Availability does not create routine use. A dealer must register, add Form 29C to the vehicle handover, retain the acknowledgement, reconcile exceptions and accept legal responsibility during custody. Adoption grows when those steps become part of the normal transaction flow.