India's New Inventory-Based Cross-Border E-Commerce Export Framework: What Exporters Need to Know

The Directorate General of Foreign Trade (DGFT) has operationalised India’s Inventory-based Cross-Border E-Commerce Facilitation Framework through Public Notice No. 25/2026-27 dated 5 August 2026. The notification introduces detailed operational procedures for businesses exporting through an Exporter-on-Record (EOR) model and notifies Aayaat Niryaat Form (ANF) 9A for EOR registration. The framework is effective immediately and establishes compliance requirements covering inventory management, seller transparency, reverse logistics, annual certification, and dispute resolution.

What Has DGFT Introduced?

DGFT has inserted a new operational framework under Chapter 9 of the Handbook of Procedures, 2023 to regulate inventory-based cross-border e-commerce exports. The framework lays down the responsibilities of the Exporter-on-Record and prescribes the registration process through ANF-9A.

Immediate Applicability

The framework comes into force with immediate effect and applies to entities seeking registration as an Exporter-on-Record.

Registration of Exporter-on-Record (EOR)

Businesses intending to operate as an Exporter-on-Record must submit ANF-9A along with the prescribed supporting documents.

Key Registration Requirements

  • Application through ANF-9A.
  • Intimation of any change in registration particulars within 30 days.
  • DGFT may confirm, modify, suspend, or cancel registration after examining revised information.
  • Registration amendments are also made through ANF-9A.

Inventory Management Obligations

The framework places significant responsibility on the Exporter-on-Record for maintaining export inventory.

Exporters Must Ensure

  • Proper digital inventory records.
  • Linkage between procurement records, GST invoices, and export documents.
  • Inventory segregation by Seller-on-Record.
  • Goods match declared specifications and quality.
  • Compliance with destination-country regulatory requirements before export.

Seller Visibility Requirements

The framework strengthens transparency between Exporters-on-Record and Seller-on-Record.

Exporters Must Provide

  • Access to consolidated digital inventory records.
  • Order status.
  • Shipment tracking details.
  • Destination country information.
  • Final sale price.
  • Appropriate disclosure of manufacturer, brand owner, or Seller-on-Record where applicable

Reverse Logistics Requirements

The notification also specifies timelines for handling rejected goods.

Important Timelines

  • Goods failing quality requirements must be returned to the Seller-on-Record within 7 days of acceptance or deemed acceptance.
  • Returned consignments received from overseas buyers must be re-exported, returned, or disposed of within 30 days.
  • The handling process must be clearly documented in agreements between the Exporter-on-Record and Seller-on-Record.

Annual Compliance Certification

Exporters are required to obtain an independent compliance certificate.

Certification Covers

  • Inventory segregation.
  • Prevention of domestic diversion.
  • Seller visibility obligations.
  • Payment settlement.
  • Export rebate and refund calculations.
  • Handling of returned goods.

The compliance certificate must be submitted to DGFT within 90 days from the end of each financial year. Records must be preserved for five years.

Dispute Resolution Mechanism

The framework introduces a structured mechanism for resolving disputes between Exporters-on-Record and Seller-on-Record.

Resolution Process

  • Complaints may be filed before the jurisdictional DGFT Regional Authority.
  • The authority will endeavour to resolve disputes within 30 days.
  • Matters requiring further examination may be referred to DGFT Headquarters.

Note:

The Public Notice also notifies ANF-9A, the application form for registration as an Exporter-on-Record under the Inventory-based Cross-Border E-Commerce Facilitation Framework. The form captures business registration details, export information, warehouse locations, e-commerce platform details, FDI disclosures, and amendment requests.

Conclusion

The operationalisation of the Inventory-based Cross-Border E-Commerce Facilitation Framework represents a significant procedural development for India’s inventory-led export ecosystem. Businesses planning to operate as an Exporter-on-Record should review the new registration requirements, strengthen digital inventory controls, establish compliant documentation practices, and prepare for annual certification obligations. Early alignment with these procedures can help exporters meet DGFT requirements while supporting transparent and compliant cross-border e-commerce operations.

Notification Reference:

DGFT
Public Notice No. 25/2026-27
05/08/2026

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