𝐒 𝐉 𝐄𝐗𝐈𝐌 𝐒𝐞𝐫𝐯𝐢𝐜𝐞𝐬

“Indirect Tax I Indirect Tax Litigation I Customs & FTP I Central Licensing I Arbitration I Advisory”

Dated: 05.09.2026

CBIC Streamlines EMI Scheme: Major Reduction in Documentation for Eligible Manufacturer Importers

The Central Board of Indirect Taxes & Customs (CBIC) has issued Circular No. 39/2026-Customs, introducing significant amendments to the documentation requirements under the Eligible Manufacturer Importer (EMI) Scheme. This move aims to simplify the application process, reduce compliance burdens, and facilitate smoother access to the deferred payment of Customs import duty for eligible manufacturers.

Background: EMI Scheme and Deferred Payment Facility

The EMI Scheme, introduced via Notification No. 12/2026-Customs (N.T.), allows eligible manufacturers to defer payment of Customs import duty under the Customs Act, 1962. The scheme is designed to support manufacturers by improving cash flow and operational flexibility.

Key Amendments Introduced by Circular No. 39/2026

1. Streamlined Data Submission

• Reduced Data Elements: Applicants now need to provide fewer details in Appendix-I. The following information is no longer required:
  • EXIM documents from the previous financial year
  • GSTIN status and manufacturing activity declaration in GST REG-01
  • GSTR-3B filing status, aggregate turnover, and GST payment details
  • Date of business commencement or GST registration
  • ITC-04 filing particulars
  • Factory/manufacturing premises details, property holding rights, book value of plant and machinery
  • Major raw materials and finished goods with HSN details
  • Job worker particulars
• Benefit: This reduction eases the application process for taxpayers, making it more accessible and less time-consuming.

2. Fewer Mandatory Document Uploads

• Document Requirements Cut from Ten to Three:
  • Only the following documents are now mandatory:
    1. UDYAM Registration Certificate (for MSMEs, if applicable)
    2. Chartered Accountant’s Certificate (with UDIN, as per Appendix-III)
    3. Authorization letter for the authorized signatory
• No Longer Required:
  • Copies of IEC, PAN, GST Registration Certificates
  • GSTR ITC-04 returns, GSTR-9C, audited financial statements for the last two years
  • Ownership/lease/rental documents for premises
• Benefit: This change drastically reduces paperwork and speeds up the application process.

3. Revised Chartered Accountant Certification

• Appendix-III Update: Chartered Accountants must now provide reasons if the applicant has negative net worth or negative net current assets. This ensures transparency while maintaining a simplified process.

4. Backend Verification

• IT System Integration: The CBIC will verify relevant particulars through backend IT systems, further reducing the need for physical documentation and manual checks.

5. Effective Date and Implementation

• New Application Format: The revised requirements apply to all applications for EMI Scheme enrollment from 15th September 2026.

How to Apply: Updated Process Overview

1. Fill Out the Simplified Application Form (Appendix-I):
   • Provide basic details such as IEC, PAN, MSME status, GSTINs, and manufacturing activity.
2. Upload Only Three Documents:
   • UDYAM Certificate (if MSME)
   • Chartered Accountant Certificate (Appendix-III)
   • Authorization Letter
3. Submit Declarations and Undertakings:
   • Confirm the accuracy of information and compliance with scheme requirements.
4. Await Backend Verification:
   • CBIC will verify details using IT systems, minimizing manual intervention.

Advantages for Manufacturers

• Reduced Compliance Burden: Less paperwork and fewer data points to submit.
• Faster Processing: Streamlined documentation leads to quicker application reviews.
• Greater Accessibility: MSMEs and other manufacturers can more easily participate in the EMI Scheme.

Conclusion

The amendments under Circular No. 39/2026-Customs mark a significant step towards ease of doing business for Indian manufacturers. By rationalizing documentation and leveraging IT systems for verification, the CBIC is making the EMI Scheme more efficient and user-friendly. Eligible importers are encouraged to take advantage of the simplified process starting 15th September 2026.

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.

We offer Legal advice and litigation support in matters related to Indirect Tax-Customs, FTP, other Indirect Tax matters & Arbitration law, all sorts of Central licensing and related matters. Come and explore the new way of doing business with us!

We specialize in paralegal services, litigation support, tax and regulatory matters, delivering reliable, efficient, and result-oriented legal assistance.

Source: CBIC, Ministry of Finance, Govt. of India

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