India's Inventory-based Cross-border E-Commerce Facilitation Framework: Registration, Compliance, and Operational Procedures

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Dated: 08.08.2026

India’s Inventory-based Cross-border E-Commerce Facilitation Framework: Registration, Compliance, and Operational Procedures

India’s Directorate General of Foreign Trade (DGFT) has introduced a robust operational framework to facilitate inventory-based cross-border e-commerce exports. This initiative, outlined in Public Notice No. 25/2026-27, aims to streamline procedures, enhance transparency, and ensure compliance for exporters leveraging e-commerce platforms to reach global markets. This article provides a detailed overview of the framework, its requirements, and actionable steps for stakeholders.

Key Highlights of the Framework

1. Registration as Exporter-on-Record (EOR)

Application Process:
- Exporters must apply for registration as an Exporter-on-Record using Aayaat Niryaat Form (ANF) 9A.
- The application requires submission of key documents, including business details, foreign investment disclosures, e-commerce affiliations, export particulars, and warehouse information.
Change Notification:
- Any change in registration particulars must be reported to DGFT within 30 days using a revised ANF-9A.
- DGFT may review and update the registration status based on continued eligibility.

2. Inventory Management and Digital Repository

Digital Records:
- Exporters must maintain a digital repository accessible to DGFT and other authorized authorities.
- This repository links procurement records, GST invoices, and export documents to each Seller-on-Record.
Inventory Compliance:
- Exporters are responsible for ensuring that goods in export inventory match the declared descriptions and quality parameters.
- All goods must comply with destination country regulations, including labeling, packaging, certification, and safety requirements.

3. Financial Obligations and Export Benefits

Administrative Charges:
- Administrative charges cannot exceed 10% of the gross amount of export rebates and refunds.
Timely Disbursement:
- Seller-attributable export benefits must be disbursed to the Seller-on-Record within 30 days of receipt by the Exporter-on-Record.

4. Seller Rights and Visibility

Access to Records:
- Sellers-on-Record are entitled to access consolidated digital records related to their goods, including sale price, order status, and shipment tracking.
Brand Disclosure:
- The identity of the manufacturer or brand owner must be disclosed to buyers through product listings or other appropriate means.

5. Reverse Logistics and Returns

Return of Non-compliant Goods:
- Goods not meeting required standards must be returned to the Seller-on-Record within 7 days of acceptance.
Handling Returned Consignments:
- Returned or rejected consignments from overseas buyers must be re-exported, returned, or disposed of within 30 days.
- Agreements between sellers and exporters must clearly define terms for handling such goods.

6. Compliance Certification

Annual Certification:
- Exporters must obtain a compliance certificate from an independent professional (Chartered Accountant, Cost Accountant, etc.) confirming adherence to framework obligations.
- The certificate must be submitted to DGFT within 90 days of the financial year-end.
Record Keeping:
- All operational records must be preserved for five years, even after cancellation or surrender of registration.

7. Dispute Resolution

Grievance Redressal:
- Disputes between Exporters-on-Record and Sellers-on-Record can be referred to the Regional Authority of DGFT.
- The authority aims to resolve disputes within 30 days, with escalation to DGFT Headquarters if necessary.
- Micro and small enterprises retain rights under the MSME Development Act, 2006.

Step-by-Step Example: Registering as an Exporter-on-Record

Download and Complete ANF-9A: Fill in business, investment, export, and warehouse details.
Gather Required Documents: Board resolution, relationship evidence with e-commerce entities, warehouse documents, etc.
Submit Application: Email scanned copies to ecommerce-dgft@gov.in.
Maintain Digital Records: Set up systems to track inventory, link documents, and provide seller access.
Ensure Compliance: Regularly review inventory, update records, and obtain annual compliance certification.

Risks and Penalties

Non-compliance can result in:

Suspension or cancellation of EOR registration and Importer-Exporter Code (IEC)
Placement in the Denied Entity List (DEL)
Recovery of export rebates and refunds with interest
Legal action under relevant trade and tax laws

Conclusion

The Inventory-based Cross-border E-Commerce Facilitation Framework marks a significant step in supporting Indian exporters in the digital age. By adhering to these procedures, exporters can ensure smooth operations, regulatory compliance, and enhanced trust with sellers and buyers alike.

In case you face any issues related to Indirect Tax-Customs, GST, Foreign Trade Policy (FTP), Arbitration matters and Central Licensing and related advisory matters in India then please feel free to get in touch with SJ EXIM Services.

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Source: DGFT

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