The Directorate General of Foreign Trade, Department of Commerce, Ministry of Commerce & Industry, has operationalised the Inventory-based Cross-border E-Commerce Facilitation Framework under the Handbook of Procedures, 2023.
The operational procedures have been notified through Public Notice No. 25/2026-27 dated August 05, 2026 and have come into effect immediately. The Public Notice has been issued in exercise of the powers conferred under paragraphs 1.03 and 2.04 of the Foreign Trade Policy, 2023. It inserts the relevant procedures under Chapter 9 of the Handbook of Procedures and introduces Aayaat Niryaat Form-9A, or ANF-9A, for registration of Exporters-on-Record.
Under the notified procedures, an entity seeking registration as an Exporter-on-Record, or EOR, must submit an application in the form and manner prescribed in ANF-9A, together with the specified supporting documents. Any change in the particulars furnished at the time of registration must be intimated to the DGFT through a revised ANF-9A within 30 days of such change.
On receiving information regarding a change in the registered particulars, the DGFT may examine whether the Exporter-on-Record continues to meet the eligibility conditions prescribed under the framework. Based on such examination, the DGFT may confirm, modify, suspend or cancel the registration, as considered appropriate.
The Exporter-on-Record will be required to maintain a comprehensive digital repository for export inventory. The repository must remain accessible to the DGFT and other authorised authorities and must continue to remain operational irrespective of the number or location of warehouses where the export inventory is held.
The digital repository must link procurement records, GST invoices and export documents of the Exporter-on-Record with the records of each Seller-on-Record. The Exporter-on-Record will also be responsible for ensuring that goods held as export inventory correspond with the descriptions, specifications and quality parameters declared by the concerned Seller-on-Record.
The Exporter-on-Record will have sole responsibility for ensuring that goods held in the export inventory comply with applicable laws, regulations and requirements of the destination country before export. These obligations include testing, inspection, certification, accreditation, registration, licensing, approvals and conformity assessments, as well as requirements relating to labelling, packaging, marking, product information and safety warnings.
The Public Notice further provides that the administrative charge retained by the Exporter-on-Record from export rebates and refunds must not exceed 10 per cent of the gross amount of such rebates and refunds. Seller-attributable export benefits must be disbursed to the concerned Seller-on-Record within 30 days of receipt of the export rebates and refunds by the Exporter-on-Record. The DGFT may review the process and modalities for claiming such benefits during the pilot phase.
Enhanced Visibility and Information Access for Sellers
To strengthen transparency, every Seller-on-Record must be provided access to consolidated digital records concerning the management and segregation of the export inventory supplied by that seller.
The information accessible to the Seller-on-Record must include, at a minimum, the final sale price charged to the overseas buyer, the status of the export order, shipment-tracking details and the destination country.
The Exporter-on-Record must also ensure appropriate disclosure of the identity of the manufacturer or brand owner of the goods. Where the Seller-on-Record is different from the manufacturer or brand owner, the identity of the Seller-on-Record must be disclosed to the overseas buyer through the product listing or any other applicable means.
Time-Bound Reverse Logistics and Returned-Consignment Management
Goods received from a Seller-on-Record that do not conform to the required description, specifications or quality parameters must be returned by the Exporter-on-Record within seven days of their acceptance or deemed acceptance.
Returned or rejected consignments received from buyers located outside India must be re-exported, returned to the Seller-on-Record, destroyed or disposed of through another mutually agreed method within 30 days from the date of their receipt in India.
The agreement between the Exporter-on-Record and the Seller-on-Record must clearly specify the terms governing cancellation, return or rejection of export orders, repair, re-export, destruction and disposal of goods. Such terms must be fair, transparent and verifiable.
Annual Compliance Certification and Five-Year Record Retention
The Exporter-on-Record will be required to obtain a compliance certificate from an independent Chartered Accountant, Cost Accountant or another professional specified by the DGFT.
The certification will cover compliance relating to maintenance and segregation of export inventory, prohibition on diversion of goods to the domestic market, seller visibility and brand disclosures, payment settlements, disbursal of export rebates and refunds, accuracy of benefit-apportionment calculations and the handling or disposal of returned and rejected consignments.
The compliance certificate must be furnished to the DGFT within 90 days from the end of each financial year, or at such other intervals as may be prescribed by the DGFT.
All books, records and documents relating to operations under the framework must be preserved for five years from the end of the financial year in which the relevant export inventory is finally exported, re-exported, returned, rejected, destroyed or otherwise disposed of. This obligation will continue even after cancellation, suspension or voluntary surrender of the Exporter-on-Record registration.
Dispute-Resolution Mechanism through DGFT Regional Authorities
A dispute or grievance between an Exporter-on-Record and a Seller-on-Record may be referred to the DGFT Regional Authority having jurisdiction over the place of business of the Seller-on-Record from which the disputed supply was made.
The Regional Authority will provide both parties a reasonable opportunity to be heard and will endeavour to facilitate resolution of the complaint within 30 days from its receipt. Where the matter remains unresolved or requires further examination, it may be referred to DGFT Headquarters for appropriate administrative directions or recommendations.
The dispute-resolution procedure will not affect the statutory rights of micro and small enterprises under the Micro, Small and Medium Enterprises Development Act, 2006, including their right to approach the Micro and Small Enterprises Facilitation Council.
ANF-9A Introduced for Exporter-on-Record Registration
The newly notified ANF-9A requires applicants to furnish details relating to their IEC, PAN, GSTIN, legal constitution, registered office, authorised signatory, foreign-investment structure, relationship with the associated e-commerce entity, export turnover, proposed export destinations, e-commerce platforms and warehouse or export-inventory locations.
Applicants must also disclose whether any inventory location is situated in an E-Commerce Export Hub and provide information regarding ownership, storage capacity and operation of each warehouse.
The completed ANF-9A, together with scanned copies of the supporting documents listed in the annexure, is to be submitted through the prescribed channel. The supporting documents include authorisation in favour of the authorised signatory, documentary evidence of the applicant’s relationship with the e-commerce entity, and details of warehouse or inventory locations.
The Public Notice operationalises the framework by establishing procedures for registration of Exporters-on-Record, digital inventory management, seller visibility, reverse logistics, compliance certification and dispute resolution. It also introduces the application mechanism required for entities seeking to undertake export-only inventory-based cross-border e-commerce operations.
The Public Notice has been issued with immediate effect.
The Public Notice can be accessed at: https://a2ztaxcorp.net/wp-content/uploads/2026/08/PN-25-English.pdf
