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Law Update
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The Directorate General of Foreign Trade (DGFT) has made it easier for certain exporters to satisfy one of the conditions for One Star Export House status.
Through Notification No. 33/2026-27 dated 21 August 2026, DGFT amended Para 1.25(d) of the Foreign Trade Policy, 2023. The change takes effect immediately.
The practical change is fairly specific. An applicant outside the Gems & Jewellery sector seeking One Star Export House status can now have export performance in any two of the three preceding financial years. Earlier, export performance was required in all three preceding financial years.
That does not mean every exporter with two years of exports automatically becomes a One Star Export House. DGFT has made the relaxation subject to the other provisions of Para 1.25.
For exporters whose overseas business has not been continuous every year, this is the part of the amendment that deserves attention.
| Particular | Details |
| Issuing authority | Directorate General of Foreign Trade, Department of Commerce, Ministry of Commerce and Industry |
| Document type | Notification |
| Notification number | 33/2026-27 |
| Gazette reference | S.O. 4617(E) |
| Date | 21 August 2026 |
| Subject | Amendment in Para 1.25 of the Foreign Trade Policy, 2023 |
| Provision amended | Para 1.25(d) |
| Legal basis | Foreign Trade (Development & Regulation) Act, 1992 |
| Effective date | With immediate effect |
| Main change | One Star Export House applicants outside Gems & Jewellery can have export performance in any two of the previous three financial years for this condition |
| Gems & Jewellery covered by relaxation? | No |
| Separate transition period | Not expressly specified |
| Separate compliance deadline | Not expressly specified |
| File number | F. No. 01/94/180/16/AM-26/PC-I |
The notification is short, but its effect can be important for exporters who missed export performance during one of the three preceding financial years. Instead of failing this particular condition because of one inactive year, qualifying applicants can now rely on the other two years.
The notification comes from DGFT, which functions under the Department of Commerce in the Ministry of Commerce and Industry.
It forms part of the existing Foreign Trade Policy, 2023, rather than creating a new scheme or separate registration system. The specific provision being changed is Para 1.25(d).
The Gazette states that the Central Government exercised powers under Section 3 read with Section 5 of the Foreign Trade (Development & Regulation) Act, 1992, together with Para 1.02 and Para 2.03 of FTP 2023.
This is because the amendment should not be read on its own. The new proviso changes one part of the existing Status Holder framework. It does not wipe out the rest of Para 1.25.
Before this amendment, Para 1.25(d) required export performance in all three preceding financial years for granting status generally. For the Gems & Jewellery sector, the provision referred to export performance in both preceding financial years.
DGFT has retained that wording but added a proviso.
For One Star Export House status, an applicant outside the Gems & Jewellery sector can now satisfy this particular condition where export performance exists in any two out of the three preceding financial years.
Here is the change in simpler terms:
| Point | Earlier Position | Position After 21 August 2026 |
| One Star Export House applicant outside Gems & Jewellery | Export performance needed in all three preceding financial years | Export performance in any two of those three years is sufficient for this condition |
| Gems & Jewellery | Export performance referred to for both preceding financial years | No relaxation provided through this notification |
| Other Para 1.25 requirements | Applicable | Continue to apply |
| Effective date | Earlier FTP position | Revised condition applies with immediate effect |
This is not a complete rewrite of One Star Export House eligibility. It is a relaxation of the export-performance period requirement.
The easiest way to understand the revised provision is to separate it into its individual parts.
Suppose only the wording of this particular condition is being considered. The business no longer needs export performance in each of the three preceding years. Two years can be sufficient.
However, that should never be read as âtwo years of exports equals One Star statusâ. The rest of the eligibility framework still has to be checked.
The relaxation is most relevant to businesses that export regularly but may not have export activity during every financial year.
This can include:
These are practical groups that may benefit from the amendment. The notification does not create separate legal categories for MSMEs, manufacturers or merchant exporters.
A business still needs to see whether it satisfies the remaining conditions under Para 1.25.
The scope of the amendment is narrower than the headline may suggest.
| Applicant/Category | Does the New Relaxation Apply? | Position |
| One Star Export House applicant outside Gems & Jewellery | Yes | Export performance in any two of the preceding three financial years can satisfy this condition |
| Gems & Jewellery applicant | No | New proviso expressly excludes the sector |
| Applicant seeking another Status Holder category | Not expressly covered | Do not assume the same relaxation applies |
| Applicant failing other Para 1.25 conditions | Relaxation alone is not enough | Other requirements remain relevant |
The wording used by DGFT is important. The proviso names One Star Export House status specifically. It also specifically excludes the Gems & Jewellery sector.
Businesses should therefore resist the temptation to apply the amendment more broadly than DGFT has written it.
The two-out-of-three-year relaxation does not apply to the Gems & Jewellery sector under this notification.
DGFT has expressly used the words âother than for Gems & Jewelry Sectorâ in the revised proviso.
For the Gems & Jewellery sector, Para 1.25(d) continues to refer to export performance in both preceding financial years.
This distinction should be checked at the beginning of an eligibility review. A business in the excluded sector should not build its application around the new two-out-of-three-year rule.
The notification refers to the three preceding financial years.
For a qualifying non-Gems & Jewellery applicant seeking One Star Export House status, export performance in any two of those three years is sufficient for the amended condition.
The Gazette does not provide a separate worked example showing exactly which financial years apply to an application made at a particular point in time.
That means businesses should identify the relevant preceding financial-year period under the DGFT framework applicable when the application is being considered.
The amendment changes the number of years in which export performance must exist. It does not give applicants freedom to pick any unrelated financial years.
This part is just as important as the relaxation itself.
DGFT clearly states that the change is subject to the other provisions of Para 1.25 of FTP 2023.
So, the notification should not be interpreted as removing the rest of the eligibility framework.
It does not say that:
For businesses assessing eligibility, this is where a complete review matter. Reading only the new proviso can give an incomplete picture.
The notification does not say so.
The new proviso specifically uses the term One Star Export House status.
There is nothing in Notification No. 33/2026-27 stating that the same relaxation has been extended to Two Star, Three Star, Four Star or Five Star Export House categories.
Businesses seeking another Status Holder category should therefore examine the provisions relevant to that category instead of applying this amendment automatically.
There is no waiting period.
Notification No. 33/2026-27 is dated 21 August 2026, and the Gazette states that the amendment is made with immediate effect.
No separate transition period is provided.
No later commencement date is mentioned.
The notification also does not expressly state a separate retrospective date. Businesses should therefore rely on the legal position stated by DGFT rather than assuming that the amendment automatically applies retrospectively to every earlier case.
Export activity is not always identical from one year to the next.
A manufacturer may have strong overseas orders in one year and very little business in another. An MSME may spend a year developing a foreign market before exports resume. A merchant exporter may also experience a temporary break in international orders.
The earlier wording could create a problem for such businesses because export performance was required in all three preceding financial years.
The revised rule is more flexible.
If a qualifying non-Gems & Jewellery applicant has export performance in two of those three years, the absence of export performance during the third year does not by itself prevent satisfaction of this particular One Star condition.
That may encourage some exporters to review eligibility again rather than assuming that the gap year automatically puts One Star status out of reach.
The notification does not create separate rules for each type of exporter, but its practical effect may differ depending on the business.
1. MSME Exporters
MSMEs often build export activity gradually. Some may have strong exports during two years but little or no performance during the third. For such businesses, the revised rule removes one possible hurdle from the One Star eligibility assessment.
It should not, however, be described as an âMSME concessionâ. DGFT has not created a special MSME provision through this notification. MSMEs benefit only where they otherwise fall within the scope of the One Star proviso.
2. Manufacturer Exporters
Manufacturers considering Status Holder recognition should revisit the export-performance period used for their assessment.
A gap in one of the previous three years may no longer disqualify them from satisfying this part of the One Star requirement.
3. Merchant Exporters
Merchant exporters may also need to reassess their export history if they are considering One Star status and fall within the covered category.
Again, the basic question is whether export performance exists in at least two of the three preceding financial years and whether the other applicable conditions are satisfied.
4. Finance, Export and Compliance Teams
The amendment may also change the way internal teams approach an eligibility check.
Export teams may have the shipment history. Finance teams may hold the financial-year data. Compliance teams need to understand whether the revised FTP provision can actually be relied upon.
Before a filing is prepared, those records should tell a consistent story.
No.
This is probably the biggest misunderstanding businesses should avoid.
The Gazette does not say that any business with export activity in two years automatically becomes a One Star Export House.
It says that export performance in any two out of the three preceding financial years is sufficient for the amended condition, subject to the other provisions of Para 1.25.
So the right way to read the amendment is:
Two qualifying years may satisfy the revised export-performance-period requirement. They do not replace the rest of the eligibility assessment.
Final recognition continues to depend on the applicable DGFT framework and assessment by the competent authority.
There is also value in looking at what is missing from the notification.
Notification No. 33/2026-27 does not expressly introduce:
It also does not say that One Star status will automatically be granted within a particular period.
Businesses should therefore avoid adding requirements to the notification that DGFT itself has not included.
If another requirement exists under the broader FTP or DGFT procedure, it should be supported by that separate provision rather than attributed to this amendment.
The amendment's strongest benefit is flexibility.
A business with export performance in two years can still satisfy this part of the One Star assessment even if the third year does not show export performance.
Businesses that previously stopped considering One Star status because of a gap year may now have reason to revisit their position.
International orders can fluctuate. The revised condition is less rigid for qualifying exporters whose performance was not continuous across every year.
A business that has built exports over the last few years but does not have performance across all three years may find the revised provision more relevant.
None of these points guarantees Status Holder recognition. They describe the likely practical value of the change itself.
The amendment removes one difficulty, but it does not eliminate the need for careful assessment.
Identifying the Correct Financial Years
Businesses need to establish which three preceding financial years are relevant to their application.
The notification does not provide a worked example.
Checking Export Performance Properly
The performance being relied upon should be backed by consistent records.
The notification itself does not prescribe a fresh list of supporting documents, so the applicable DGFT procedure should be checked separately.
Confirming Sector Coverage
The Gems & Jewellery exclusion is express. A business should know whether that exclusion affects its case before relying on the relaxation.
Reading the Rest of Para 1.25
A business may satisfy the two-year requirement and still have other eligibility issues.
The amendment should therefore form part of a wider Status Holder review.
For the businesses covered by it, the change looks more like a practical relaxation than an additional compliance burden.
Earlier, an exporter could fall short of this condition simply because one of the three preceding financial years did not show export performance. The new proviso removes that rigidity for eligible One Star applicants.
There are clear benefits:
At the same time, the amendment does not make the wider process automatic.
Applicants still have to check whether they fall within the covered category, whether the correct financial years have been used and whether the other provisions of Para 1.25 are satisfied.
So the rule eases one condition. It does not remove the need for a proper eligibility review.
Before treating the amendment as applicable, businesses should work through a few basic checks.
These last record-review measures are practical controls rather than fresh obligations created by Notification No. 33/2026-27.
The amendment is simple enough to read quickly, which is exactly why some details can be missed.
Businesses should avoid:
A proper pre-application check is usually easier than correcting an eligibility assumption after documents have already been prepared.
Start by confirming that the proposed application is actually for One Star Export House status. The new proviso is specifically linked to this category.
Determine whether the Gems & Jewellery exclusion applies. If it does, the new two-out-of-three-year relaxation should not be relied upon.
Check the three preceding financial years and identify the years in which export performance exists. For a covered applicant, performance in two of those years can now satisfy this part of the requirement.
Do not make the filing decision on the basis of Para 1.25(d) alone. The notification itself says that other provisions continue to matter.
Export, finance and compliance records should be checked together. Any mismatch is better identified before the application process begins.
The amendment is effective from 21 August 2026, but exporters should still review later DGFT notifications or public notices before making a filing.
From a business standpoint, the amendment recognises that an exporter may have a genuine overseas track record even if activity was not recorded in every one of the previous three years.
That is particularly relevant where exports are influenced by project cycles, market entry, buyer demand or temporary commercial interruptions.
From the regulatory side, DGFT has not dismantled the Status Holder framework. It has simply added flexibility to one eligibility condition for the lowest specified category covered by the proviso.
The wording shows a targeted change: The One Star category is named, Gems & Jewellery is excluded, and the rest of Para 1.25 remains in place.
That makes the amendment easier to understand once its limits are kept in view.
Notification No. 33/2026-27 does not say that DGFT plans to extend the same relaxation to other Status Holder categories.
It also does not announce another phase or a later review date.
Exporters should therefore work with the rule that has actually been notified rather than assuming that similar changes will follow.
Businesses considering Status Holder recognition should continue monitoring:
A later amendment, if issued, should be read separately on its own terms.
The new rule may look straightforward, but an actual eligibility review can involve more than checking whether exports took place in two years.
The business first needs to confirm that the proposed category is One Star Export House, that the Gems & Jewellery exclusion does not apply, that the correct financial-year period has been considered and that the remaining FTP requirements have not been overlooked.
Corpseed can support exporters through relevant DGFT registration services and export compliance assistance, including:
A DGFT consultant can also help where the business is unsure whether its export history satisfies the amended condition or whether another provision of Para 1.25 affects eligibility.
Professional support is useful for understanding the applicable rule, identifying gaps and preparing consistent information. It does not replace DGFT's decision-making role, and no consultant can guarantee One Star Export House recognition.
Businesses reassessing their eligibility after Notification No. 33/2026-27 can consider Corpseed's DGFT registration services for a structured review of the applicable Status Holder requirements and filing position.
The change in One Star Export House eligibility 2026 is narrow but commercially relevant for exporters whose performance has not been continuous over the previous three financial years.
For exporters affected by a one-year gap in their export history, the amendment is worth reviewing carefully rather than assuming that the earlier three-year position still applies.
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