Law Updates

Subject

Summary: The Department of Telecommunications (DoT) has brought two specific categories of telecom services within the biometric user-identification requirement under the Telecommunications Act, 2023. Through notification S.O. 4623(e), dated 21 August 2026, the central government has notified wireless access services and internet telephony services through mobile user terminals. Authorized entities providing these services are required to ensure verifiable biometric-based identification of their users in accordance with the Telecommunications (User Identification) Rules, 2026. The notification is only two pages long, but its wording has direct compliance consequences for the entities within its scope. At the same time, it should not be read more broadly than it is written. It does not say that every telecom service, every internet calling platform, or every user in India automatically falls under this particular notification. For telecom operators, the first job is therefore not to rush into a new verification process. It is to establish whether the service being offered is one of the services actually notified. Notification at a Glance Particular Verified Details Issuing authority Central Government Ministry Ministry of Communications Department Department of Telecommunications Document type Department of Telecommunications Notification number S.O. 4623(E) Date 21 August 2026 Gazette Gazette of India, Extraordinary Gazette section Part II, Section 3, Sub-section (ii) Legal basis Section 3(7) of the Telecommunications Act, 2023 Rules referred to Telecommunications (User Identification) Rules, 2026 Service 1 Wireless access services Service 2 Internet telephony service through mobile user terminals Entity responsible Authorized entities providing the notified services Main requirement Verifiable biometric-based identification of users Separate compliance deadline Not expressly specified in S.O. 4623(E) Transition period Not expressly specified in S.O. 4623(E) File number F. No. 800-22/2024-AS.II The notification is precise about three things: the services covered, who carries the responsibility and the requirement that identification must follow the Telecommunications (User Identification) Rules, 2026. It is much less detailed on implementation. There is no separate table of procedures, technology specifications, fees or transition dates in S.O. 4623(E) itself. The Regulatory Framework The August 2026 notification does not create an isolated biometric-KYC system. It sits within the broader structure of the Telecommunications Act, 2023 and the Telecommunications (User Identification) Rules, 2026. Section 3(7) of the Telecommunications Act, 2023 Section 3 of the Telecommunications Act deals with authorization. Sub-section (7) states that an authorized entity providing a telecommunication service notified by the Central Government must identify the person receiving that service through a verifiable biometric-based identification method as prescribed. This explains why S.O. 4623(E) matters. The Act creates the legal mechanism. The government then issues a notification identifying the telecom services to which that mechanism applies. S.O. 4623(E) names two such categories. This distinction also prevents an unnecessarily broad interpretation. The legal requirement under Section 3(7) is tied to services notified by the Central Government, rather than being worded in the notification as a blanket requirement for every telecom service. Telecommunications (User Identification) Rules, 2026 The second part of the framework is the Telecommunications (User Identification) Rules, 2026. DoT's Telecom e-services Portal confirms that these Rules have been made live on the portal. S.O. 4623(E) expressly states that the biometric identification of users has to be ensured in accordance with these Rules. That is why the notification and Rules have to be read together. A simple way to understand the structure is: Legal Instrument What It Does Telecommunications Act, 2023 Provides the legal power and wider authorization framework S.O. 4623(E), 2026 Identifies the telecom services covered by this notification Telecommunications (User Identification) Rules, 2026 Governs how user-identification requirements operate For a telecom business, reading only the Gazette notification is therefore not enough to design an operational KYC process. What Has Changed? The immediate change is that two categories of telecom services have now been expressly notified for Section 3(7). They are: wireless access services, and Internet telephony services through mobile user terminals. The responsibility rests with authorized entities providing those services. They are required to ensure verifiable biometric-based identification of the users to whom the services are provided. The practical position can be read as follows: Compliance Area Position Under S.O. 4623(E) Practical Meaning Wireless access services Expressly notified Relevant authorized providers come within the notification Internet telephony Covered where provided through mobile user terminals Exact service classification matters User identification Must be verifiable and biometric-based Provider must follow the applicable identification framework Responsible party Authorized entity Compliance responsibility lies with the service provider Manner of compliance According to the 2026 Rules S.O. 4623(E) cannot be read as the full operating procedure What should not be said is that telecom KYC itself started on 21 August 2026. The notification is narrower than that. Its job is to identify particular services for the biometric requirement under Section 3(7). Scope and Applicability of S.O. 4623(E) The most important compliance question is simple: does the service being provided fall within one of the two categories named in the notification? That question should be answered before technology, paperwork or internal processes are changed. Wireless Access Services Wireless access services are expressly mentioned in clause (a) of the notification. An authorized entity providing a service that falls within this category must therefore consider the biometric user-identification requirement and the corresponding 2026 Rules. The commercial name used for a service should not be the sole basis for determining applicability. The provider's regulatory authorization and the legal classification of the service should also be checked. Internet Telephony through Mobile User Terminals The wording of the second category deserves close attention. The Gazette does not simply say "internet telephony services." It says: "Internet telephony service through mobile user terminals." That qualification matters. A business should not assume that every VoIP product, internet calling platform, software application or online communication service automatically falls within this notification merely because voice communication takes place over the internet. The nature of the service, the way it is delivered, and the regulatory authorization under which it operates have to be looked at together. Applicability Matrix Service or Entity Position Under S.O. 4623(E) What Should Be Checked Wireless access service provider Expressly covered Authorization and user-identification process Internet telephony through mobile user terminals Expressly covered Whether the particular service fits the notified description Authorized entity providing either notified service Responsible for compliance Applicable User Identification Rules Other telecom service Not established by this notification alone Separate notification, Rules or authorization conditions General software or communication platform Cannot be decided from name alone Actual service model and telecom regulatory status This is one area where a telecom compliance consultant or internal regulatory team can add value. Applicability should be determined by the legal and operational facts rather than by assumptions about the technology being used. Who Is Responsible for the Biometric Identification Requirement? S.O. 4623(E) places the responsibility on the authorized entity providing the notified service. The relevant wording says that authorized entities shall ensure verifiable biometric-based identification of the users receiving those services. That may sound like a small drafting point, but it matters in practice. The user may have to participate in the verification process. The compliance responsibility under this notification, however, sits with the authorized service provider. For an operator, that turns biometric identification into more than a customer-KYC task. Legal, compliance, operations and technology teams may all have a role. The operator needs to know: Whether the service is covered, Which verification method is permitted under the Rules? Where verification takes place in the customer journey, Which team owns the process? How failures or exceptions are dealt with, and What evidence must be kept where the applicable Rules require it? Not every item in this list is separately written into S.O. 4623(E). They are practical questions that arise when an authorized entity converts the legal requirement into an operating process. What Does “Verifiable Biometric-Based Identification” Mean Here? The notification uses the expression “verifiable biometric-based identification”, but it does not provide its own detailed technical procedure. This is exactly where businesses need to avoid reading too much into a short Gazette notice. S.O. 4623(E) does not itself say that the only acceptable method is: Fingerprint verification, Facial authentication, Iris scanning, Aadhaar-based authentication, or Any particular biometric device or software. Those conclusions should not be added unless they are supported by the Telecommunications (User Identification) Rules, 2026 or another applicable DoT instruction. The safer compliance approach is first to identify the method permitted or prescribed by the official framework and then check whether the company's existing technology can support it. Buying a biometric solution and using a biometric solution that meets the applicable regulatory requirements are two different things. How S.O. 4623(E) and the User Identification Rules Work Together The notification answers “which notified services?” The Rules answer the wider question of “how user identification must be handled?” This division is important for management teams because otherwise businesses may treat the Gazette notice as if it were a complete implementation manual. It is not. The Department of Telecommunications also lists separate instructions on its e-services portal in connection with the Telecommunications (User Identification) Rules, 2026. The portal shows an item titled “Instructions to be specified on the portal in accordance with the Telecommunications (User Identification) Rules, 2026,” published on 9 August 2026. That tells affected entities something practical: the compliance framework extends beyond this single notification. The Rules and official instructions need to form part of the review. What Does This Mean for Wireless Access Service Providers? For a wireless access provider within the notified category, the issue moves from general awareness to operational readiness. The provider should first check how users are currently identified and whether that process fits the framework required under the 2026 Rules. Areas likely to require review include: Existing customer on boarding controls, Subscriber identity-verification procedures, Internal KYC responsibilities, Technology used for verification, Integration between customer and verification systems, Regulatory records maintained by the entity, and Internal escalation where verification cannot be completed. Some operators may already have mature digital on boarding systems. Others may rely on several systems or external service providers. The amount of work required will therefore differ from one authorized entity to another. S.o. 4623(e) does not prescribe a single implementation cost or a standard internal setup for every provider. What Does This Mean for Internet Telephony Providers? Internet telephony providers have an additional issue to settle before looking at compliance mechanics: service classification. The notification's reference is to internet telephony through mobile user terminals. A provider should therefore examine what service is actually being supplied, how the customer accesses it and under which telecom authorization the service is offered. This matters because internet-based communications can take many forms. A business may describe a product commercially as “calling,” “voice,” “communication”, or “VoIP,” but a marketing description by itself does not settle the regulatory position. If there is uncertainty, an applicability review should come before changes are made to KYC or biometric systems. How Could the Requirement Affect Telecom User On boarding? For affected providers, on boarding is likely to be one of the first business processes that needs examination. Biometric identification has to fit somewhere into the journey between a customer requesting a telecom service and that service being provided. The compliance team therefore needs to look beyond the verification screen itself. Questions worth checking include: At what point does the prescribed identification take place? Does the present KYC process use a method allowed under the Rules? Is verification connected correctly with service activation? How does the system deal with an unsuccessful verification? Who can approve an exception if the legal framework permits one? Are responsibilities clear between the KYC, technology and operations teams? Is the evidence required under the applicable Rules being captured correctly? These are practical review points. They should not be presented as separate duties created by S.O. 4623(E) unless the Rules expressly say so. Responsibilities across Telecom Teams A biometric user-identification requirement cannot normally be managed by one department working alone. Legal and Compliance Team The first responsibility is interpretation. This team should determine whether the service is covered, identify the relevant authorization and map the notification against the User Identification Rules and DoT instructions. A good compliance review should separate what is legally compulsory from what the company chooses to introduce as an internal control. KYC and Customer-On boarding Team The KYC team is responsible for turning regulatory requirements into a customer-facing process. If an existing process was designed under earlier instructions, it should be checked against the current framework rather than being carried forward automatically. Technology Team Technology teams need a clear legal requirement before they start changing systems. That reduces the risk of building a verification process around a technology that is not required or overlooking a condition that the applicable Rules actually prescribe. Operations Team Operations teams usually deal with what happens after a process goes live. They may need clear internal instructions covering staff responsibilities, unsuccessful verification, customer communication, and escalation. Information Security and Data Governance Biometric information requires careful handling. Any duty concerning storage, retention, access, sharing, or security should be derived from the applicable legal framework. S.O. 4623(E) itself does not prescribe a retention period or a detailed data-storage process. What the Notification Does Not Expressly Specify This section is just as important as explaining what the Gazette does say. S.O. 4623(E) does not expressly provide: A separate compliance deadline, A separate transition period, A standalone application form, A filing process for complying with this notification, A separate compliance fee, A new renewal procedure, A particular biometric device, A named biometric technology, A record-retention period, A product-testing requirement, or A separate penalty table. That does not mean these subjects can never arise under another provision. It means they should not be attributed to this notification without checking the Telecommunications Act, the 2026 Rules, relevant authorization conditions and other official DoT instructions. This approach matters because compliance content can easily become inaccurate when missing information is filled with assumptions. Is biometric identification required for every telecom service? No. S.O. 4623(E) by itself does not establish a biometric requirement for every telecom service in India. It expressly identifies two categories: Wireless access services, and Internet telephony service through mobile user terminals. A provider operating another telecommunications service should check its own legal position separately. The reverse is also true. A service not named in S.O. 4623(E) should not automatically be treated as free from every user-identification requirement. Other Rules, notifications, authorization terms or DoT instructions may still be relevant. The correct approach is service-by-service regulatory assessment. Compliance Requirements The clearest way to understand the legal position is to separate the requirements stated in S.O. 4623(E) from the wider implementation framework. What S.O. 4623(E) Expressly Requires For the services notified: An authorized entity is providing the relevant service, The service falls within one of the two specified categories, The authorized entity must ensure verifiable biometric-based identification of the user, and The identification has to be carried out in accordance with the Telecommunications (User Identification) Rules, 2026. What Must Be Checked Separately The following should be verified from the Rules and applicable DoT instructions rather than assumed from the Gazette notification: Permitted biometric identification method, User on boarding procedure, Any alternative identification route, Treatment of different categories of users, Re-verification requirements, Documents or records to be maintained, System or portal requirements, Timelines under particular circumstances, and Operational instructions issued by DoT. This separation helps keep the compliance position accurate. Compliance Readiness for Authorized Telecom Entities A practical review does not need to start with a large technology project. It can start with a few basic questions. 1. Confirm Whether the Service Is Covered Map the actual service against the two categories notified in S.O. 4623(E). If classification is unclear, settle that issue first. 2. Check the Authorization Position Identify the authorization or legacy licensing framework under which the service is being provided. The status of the entity and the nature of the authorized service can affect the compliance analysis. 3. Read the User Identification Rules alongside the Notification Do not treat S.O. 4623(E) as the complete procedure. The Rules should be mapped to the business model and customer on boarding process. 4. Review the Existing KYC Process Document how the entity currently identifies users. The objective is to determine whether the current process already meets the applicable requirements or needs changes. 5. Carry out a Compliance Gap Assessment A compliance gap assessment can examine the difference between the current process and the verified DoT requirements. The review may cover legal interpretation, on boarding procedures, technology controls, record management and internal ownership. 6. Check Technology Readiness Any biometric or digital verification system should be tested against the regulatory requirements before major changes are made. A provider should not assume that commercially available biometric technology is automatically acceptable under the telecom framework. 7. Give Each Team Clear Ownership Legal, KYC, technology, information-security and operations teams should know which parts of the process they are responsible for. 8. Keep Monitoring DoT Instructions The DoT portal continues to publish material linked to user identification. Regulatory teams should monitor official updates rather than relying only on the original Gazette notification. Impact on Businesses The effect will not be identical for every company. Stakeholder Immediate Impact Likely Operational Effect Main Concern Authorized telecom entities Need to confirm applicability Regulatory and process review Correct service classification Wireless access providers Service expressly notified User-verification process may need alignment Compliance with 2026 Rules Covered internet telephony providers Scope must be checked carefully KYC and technology review Whether service fits the notified wording Legal and compliance teams Need to map notification and Rules More regulatory coordination Whether service fits the notified wording KYC teams Existing process needs review Possible workflow changes Correct user identification Technology teams System capability may need assessment Integration or configuration changes Using the permitted verification method Management Cross-team ownership needed Resource and implementation planning Avoiding both under- and over-compliance The notification may appear to deal only with user verification, but its operational effect can extend across several parts of a telecom business. That is why telecom regulatory compliance services can be useful when service classification, existing KYC systems, and regulatory requirements need to be examined together rather than separately. Benefits for Businesses and the Telecom Ecosystem A stronger identification process can have practical value when it is implemented correctly. For authorized entities, clearer user-identification controls can improve the reliability of subscriber records and reduce uncertainty about how a connection was issued. Other possible benefits include: Better consistency in user-verification procedures, Clearer responsibility for customer identification, Stronger internal KYC controls, Improved traceability of the verification process, Better alignment between compliance and on boarding systems, and A more structured basis for internal audits and reviews. These should be treated as potential regulatory and operational benefits, not guaranteed outcomes. S.O. 4623(E) does not promise that biometric verification will eliminate fraud, reduce operating costs or make on boarding faster. Challenges and Cost Implications The harder part for many operators may be implementation rather than understanding the two-page notification. Existing Systems May Need Review A company may already have digital KYC tools in place. That does not automatically mean those systems satisfy the current Rules. The existing setup has to be checked against the actual legal requirement. Different Teams Need to Work Together If the legal team interprets the requirement one way while the technology team builds something different, the company may end up with a process that is expensive but still incomplete. Clear internal ownership reduces that risk. Smaller Operators May Have Fewer Resources Entities with limited in-house regulatory or technology teams may depend more heavily on external vendors. This can make it even more important to define the legal requirements before purchasing or modifying technology. Compliance Costs Will Differ S.O. 4623(E) does not prescribe a standard implementation fee or cost. Actual expenses, where they arise, may depend on existing systems, integration requirements, staffing, vendor arrangements and internal compliance work. No fixed figure should therefore be presented as a government-prescribed cost for complying with this notification. Is the Biometric Identification Requirement a Right Decision or an Additional Burden? The answer depends on which part of the change is being considered. Where the Requirement Can Help From a regulatory-control perspective, stronger identity verification can make subscriber records more dependable. It can also make responsibility clearer. The authorized entity knows that identification cannot simply be treated as an informal customer on boarding step where the notified service is concerned. A defined biometric framework may also improve consistency in how users are verified across regulated services. Where Businesses May Feel the Burden Implementation can require time and resources. Some operators may need changes to their technology. Others may need to revisit procedures, vendor contracts, training or internal controls. The burden may be greater when an entity starts with an older or fragmented KYC system. There is another risk as well: over-compliance. A business that assumes the notification requires more than it actually does could spend money on technology or procedures that are not legally necessary. A Balanced View S.o. 4623(e) is useful because it clearly identifies the services brought within the Section 3(7) mechanism. The practical difficulty lies in translating that requirement into the correct operating process. For most authorized entities, the sensible approach is not to treat biometric identification as either purely beneficial or purely burdensome. The better question is whether the company can implement the verified requirement accurately without building unnecessary layers around it. Regulatory and Implementation Risks to Avoid Several risks can be reduced simply by reading the wording carefully. Businesses should avoid: Treating the notification as applicable to every telecom service, Assuming every form of internet calling falls within the notified category, Ignoring the words “through mobile user terminals”, Assuming biometric verification automatically means Aadhaar-only verification, Selecting fingerprint, facial or iris technology without checking the Rules, Treating 21 August 2026 as a separate compliance deadline when S.O. 4623(E) does not state one, Assuming every existing customer needs immediate re-verification without verifying the applicable Rules, Treating internal best practices as legal obligations, Relying on the notification without reading the User Identification Rules, and Making technology decisions before settling service applicability. Avoiding these mistakes can save both compliance effort and unnecessary implementation cost. What Businesses Should Do Next These actions are a practical readiness plan. They should not all be described as separate legal duties written into S.O. 4623(E). Priority Action Responsible Team Expected Result High Confirm whether the service is covered by S.O. 4623(E) Legal/Compliance Clear applicability position High Review the Telecommunications (User Identification) Rules, 2026 Legal/Compliance Verified requirement mapping High Check the current user-identification process KYC/Operations Existing gaps identified High Review authorization status and service classification Legal/Regulatory Correct regulatory context Medium Assess technology readiness Technology/Operations Clear implementation requirements Medium Assign internal ownership Management/Compliance Defined accountability Medium Review documentation and controls Compliance/KYC Better audit readiness Ongoing Monitor official DoT instructions Regulatory Team Updated compliance position The starting point is always the same: find out exactly what service is being provided and which part of the regulatory framework applies to it. How Can Corpseed Help? For a telecom provider, the difficult question is often not whether biometric identification exists as a regulatory requirement. The harder part is deciding whether the requirement applies to the service, what the applicable Rules require and what needs to change inside the business. Corpseed supports businesses through relevant telecom regulatory compliance services, including: Applicability assessment: reviewing the service model and regulatory position to determine whether the notified categories are relevant. Telecommunications Act and User Identification Rules review: mapping the notification to the wider statutory and rule-based framework. Telecom authorization compliance support: reviewing the entity's authorization or regulatory status in relation to the service being provided. Compliance gap assessment: comparing the present KYC, on boarding and internal-control framework with verified DoT requirements. User-identification process review: examining how customer verification currently works and where regulatory alignment may be required. Regulatory documentation review: helping organize policies, records and internal responsibilities connected with telecom compliance. Implementation-readiness support: coordinating legal, compliance, operations and technology considerations before process changes are made. Ongoing telecom regulatory consulting: tracking relevant DoT notifications, instructions and changes that may affect the user-identification framework. Professional support should help a business understand and apply the rules correctly. It cannot guarantee a regulatory outcome or replace the authority of the Department of Telecommunications. For authorized entities that are unsure whether their service falls within S.O. 4623(E), working with a telecom compliance consultant can help settle the applicability question before money is spent on new systems or process changes. Businesses looking for telecom regulatory compliance services can also use professional support to review their current user-identification framework, identify gaps and organize implementation around the requirements that actually apply. Key Takeaways The DoT biometric user identification notification 2026 is focused rather than general. It brings two identified service categories within the biometric user-identification requirement under Section 3(7) of the Telecommunications Act, 2023. DoT issued S.O. 4623(E) on 21 August 2026. It has been issued under Section 3(7) of the Telecommunications Act, 2023. It covers wireless access services and internet telephony services through mobile user terminals. The responsibility lies with authorized entities providing those services. Users must be identified through a verifiable biometric-based process in accordance with the Telecommunications (User Identification) Rules, 2026. The notification does not itself specify a separate deadline, transition period, fee, biometric device or detailed operating procedure. Other telecom services should not automatically be treated as covered by this particular notification. Affected providers should first confirm applicability and then review their KYC, technology and operational processes against the applicable Rules.

Subject

Summary: Indian exporters now have a revised set of rules for deciding how export contracts can be priced and how export payments received in Indian Rupees will be treated under the Foreign Trade Policy. The Directorate General of Foreign Trade ( DGFT ) issued Notification No. 30/2026-27 on 20 August 2026, amending Para 2.52 and Para 2.53 of the Foreign Trade Policy (FTP) 2023 with immediate effect. The changes deal with two connected issues. Para 2.52 decides how export contracts and invoices may be denominated and how export proceeds can be realised. Para 2.53 explains when export proceeds received in Indian Rupees can be recognised for FTP benefits, incentives and fulfilment of export obligations. For exporters, the change gives more room for INR-based trade, but the rule is not identical for every destination. ACU countries, Nepal, Bhutan and Iran have to be looked at separately. RBI and FEMA requirements also continue to matter. Notification at a Glance Particular Details Issuing Authority Directorate General of Foreign Trade Ministry Ministry of Commerce and Industry Department Department of Commerce Notification Number 30/2026-27 S.O. Number S.O. 4601(E) Date 20 August 2026 Effective Date Immediate effect Policy Amended Foreign Trade Policy 2023 Paragraphs Amended Para 2.52 and Para 2.53 Governing Law Foreign Trade (Development & Regulation) Act, 1992 Main Subject Export contract currency and INR export realisation Main Stakeholders Exporters, businesses using FTP benefits and companies having export obligations Special Treatment ACU countries, Nepal, Bhutan and Iran Related Framework Foreign Exchange Management (Manner of Receipt and Payment) Regulations, 2023 The Gazette states that the Central Government has used powers under Sections 3 and 5 of the Foreign Trade (Development & Regulation) Act, 1992, read with the relevant provisions of FTP 2023, to make these amendments. For a business, this is not just a change in legal wording. It can influence the currency mentioned in a contract, the way an overseas buyer pays, and whether that payment can later be counted for an FTP benefit or export obligation. What Is the Regulatory Background Behind the Change? FTP 2023 lays down the broader policy framework for India's export and import system. It covers several matters connected with foreign trade, including authorisations, export obligations, incentives and the treatment of export proceeds. Within that framework, Para 2.52 deals with the denomination of export contracts. In simple terms, it answers a basic question: in what currency can an exporter raise the contract or invoice? Para 2.53 deals with a different question. If the exporter receives the payment in Indian Rupees, can that receipt still be recognised for benefits or obligations under FTP? These questions also overlap with India's foreign-exchange rules. DGFT may decide how an export is treated under FTP, but RBI and FEMA determine how cross-border payments can actually be received and settled. That is why exporters should not read the amended FTP paragraphs in isolation. The payment route has to work under both the foreign-trade framework and the applicable foreign-exchange rules. Why Did DGFT Amend Para 2.52 and Para 2.53? The amendment is intended to align the FTP provisions dealing with the denomination of export contracts, and eligibility for FTP benefits on INR export realisations with the Foreign Exchange Management (Manner of Receipt and Payment) Regulations, 2023. In practical terms, the older FTP wording had to be brought closer to the newer payment framework. This is useful because exporters often have to check two separate sets of rules. One set determines whether the payment route itself is permissible. The other determines how that payment will be treated under FTP. The revised wording reduces some of that mismatch. It does not, however, mean that any exporter can simply ask an overseas buyer to pay in Rupees and assume the transaction is compliant. The destination country, banking channel, RBI directions and the purpose for which the payment is later being used all remain relevant. What Has Changed Under Para 2.52? Para 2.52 deals with the currency of export contracts and invoices. The revised provision now separates transactions according to the country involved instead of placing every export under one broad rule. Export Contracts with Countries outside the ACU Framework For export contracts and invoices that do not involve a member country of the Asian Clearing Union, the revised provision allows them to be denominated either in: Foreign currency, or Indian Rupees. The export proceeds may also be realised either in foreign currency or in Indian Rupees. This distinction between denomination and realisation is worth understanding. Denomination simply refers to the currency written in the contract or invoice. Realisation refers to the actual receipt of money by the exporter. An invoice might be raised in one permitted currency, but the way the money is finally received still has to comply with the applicable regulatory and banking framework. What Happens in the Case of ACU Countries? Transactions involving member countries of the Asian Clearing Union are dealt with separately. For an ACU member country other than Nepal and Bhutan, the export contract is to be denominated in a currency determined by the ACU. The revised wording also allows such transactions to be denominated and settled according to directions issued by RBI from time to time. This means that an exporter dealing with an ACU country should not simply apply the same rule used for a buyer located in a normal non-ACU market. The current RBI instructions need to be checked as part of the transaction. What about Nepal and Bhutan? Nepal and Bhutan have been given their own treatment. The revised Para 2.52 says that export contracts involving Nepal and Bhutan are to be denominated and settled in Indian Rupees, or in accordance with directions issued by RBI from time to time. That makes the destination country particularly important. A company selling to Nepal or Bhutan should not copy the currency clause from a contract used for Europe, the Middle East or another overseas market without checking whether it fits the applicable rule. EXIM Bank and Government of India Lines of Credit The amended provision also keeps a specific rule for exports made under EXIM Bank or Government of India Lines of Credit. Contracts and invoices under these arrangements may also be denominated in Indian Rupees. The individual terms of the relevant Line of Credit would still need to be considered. Old Rules vs Revised Rules The amendment becomes clearer when the earlier and revised positions are compared directly. Area Earlier Position Revised Position What It Means for Business General export contracts Contracts could be in freely convertible currency or INR, but realisation was generally linked to freely convertible currency, subject to specified exceptions Non-ACU contracts can be in foreign currency or INR, and proceeds can be realised in foreign currency or INR INR realisation receives clearer treatment INR payment route Earlier Para 2.52 contained specific Vostro-related conditions Revised wording uses a broader country-based structure Businesses need to apply the current payment framework ACU transactions Specific ACU Dollar/ACU Euro provisions appeared in the earlier rule ACU-determined currency applies, with RBI directions also recognised Current RBI instructions become important Nepal and Bhutan Treated separately from some earlier INR routes Expressly covered under a separate clause These destinations require a separate check FTP benefits on INR receipts Earlier wording referred to specified INR arrangements Qualifying INR realisations can receive broader recognition More INR receipts may potentially qualify Iran Subject to special treatment Para 2.19 continues to apply Iran transactions need an additional review The real change is therefore wider than a simple statement that exporters can now "take payment in Rupees." INR settlement already existed within the regulatory framework. What DGFT has done is rewrite the FTP provisions so that they fit more closely with the current foreign-exchange rules and give clearer treatment to qualifying INR receipts. How Do the Rules Change From Country to Country? Destination Contract Currency Payment/Realisation What Needs Attention Non-ACU countries Foreign currency or INR Foreign currency or INR Applicable banking and FEMA rules ACU countries other than Nepal and Bhutan Currency determined by ACU As permitted under relevant framework/RBI directions Current RBI instructions Nepal INR or as allowed under RBI directions Subject to applicable RBI framework Separate treatment Bhutan INR or as allowed under RBI directions Subject to applicable RBI framework Separate treatment Iran Relevant Para 2.52 treatment INR may be recognised Para 2.19 must also be checked This is probably the most useful way for an exporter to approach the amendment. Before deciding the invoice currency or payment method, first identify the destination. The applicable rule can change based on that one fact. Why Does the Asian Clearing Union Matter? The Asian Clearing Union matters because FTP does not treat an ACU transaction in exactly the same manner as every other export. Under the revised Para 2.52, contracts involving ACU countries, other than Nepal and Bhutan, are tied to the currency determined under the ACU framework. At the same time, RBI directions may also govern how those transactions are denominated and settled. For an exporter, the practical question is therefore not simply, "Can my buyer pay me in Rupees?” The first question should be: "Which country is the buyer in, and which payment framework applies to that country?" The notification does not provide a complete list of ACU members or reproduce every payment procedure. Those details should be checked from the current official framework when a specific transaction is being planned.  What Has Changed Under Para 2.53? Para 2.53 deals with FTP schemes for exports where the proceeds are received in Indian Rupees. This part of the notification is especially relevant to businesses that: Claim an FTP export benefit, Use an export incentive, Hold an authorisation involving an export obligation, or Need to show eligible export realisation for an FTP purpose. Under the revised provision, exports to countries other than Nepal and Bhutan can qualify for FTP benefits, incentives and fulfilment of export obligations where the export proceeds are realised in Indian Rupees through the prescribed banking route. Such qualifying INR realisations can be treated at par with exports where the money is received in foreign currency. That is a useful change, but the words "qualifying INR realisation" are important. Simply receiving Rupees is not enough. Which INR Payments Can Actually Qualify? The revised Para 2.53 attaches conditions to the benefit. The export proceeds need to be realised through banking channels. The amount also needs to be credited to an Indian Rupee account of a person resident outside India, where that account has been opened under the applicable Foreign Exchange Management (Deposit) Regulations, as amended from time to time. Only after those conditions are considered does the FTP treatment become relevant. A business should therefore avoid this assumption: "The buyer paid us in INR, so the amount will automatically qualify for an export incentive." That is not what the amendment says. The correct question is whether the INR receipt satisfies the prescribed banking and account conditions and whether the underlying export independently qualifies under the FTP scheme being used. What Does "At Par With Foreign-Currency Realisation" Really Mean? This phrase can sound more complicated than it is. For the purposes covered by Para 2.53, an eligible export payment received in INR can be treated in the same manner as an eligible export payment received in foreign currency. That can matter where a business is relying on the export for: An FTP benefit, An incentive, or Fulfilment of an export obligation. But parity of currency treatment does not cancel the rest of the scheme. If an incentive requires certain product conditions, documentation or authorisation requirements, those still apply. If an export obligation must be completed within a particular framework, receiving the money in INR does not by itself prove that every obligation has been met. The amendment removes one possible barrier. It does not remove all the other eligibility conditions. What Is the Position for Exports to Iran? Iran continues to require a separate check. The revised Para 2.53 specifically states that, for exports to Iran, the INR treatment will apply subject to compliance with Para 2.19 of FTP. An exporter dealing with Iran should therefore not rely on Para 2.53 alone. The current requirements of Para 2.19 should be reviewed separately before the business treats the INR payment as eligible for an incentive or export-obligation purpose. The Gazette amendment does not reproduce the full text of Para 2.19, so it would be unsafe to assume its requirements from this notification alone. What Changes in Day-to-Day Export Work? For many businesses, the practical effect will show up first in contracts, invoices and bank records rather than in a separate filing. Export Contracts: Contract templates should be checked against the destination country. A standard contract used for several markets may contain a currency clause that no longer fits every transaction. The business should look at: Currency of the contract, Currency of the invoice, Payment method, Country of the buyer, and Proposed settlement route. Invoices: An invoice should not be prepared only from a commercial point of view. The currency stated on the invoice should also fit the applicable FTP and banking framework.  Where INR is being used, finance teams should know how that amount is expected to be received and through which account structure. Banking Records: Banking records become especially important if the exporter later wants to rely on that payment for an FTP benefit. The company should be able to connect the payment received with the actual export transaction. Internal Records A sensible internal file may bring together: Export contract, Invoice, Shipping documents, Bank advice, Export-realisation evidence, and Relevant FTP scheme records. These are sensible internal controls. The notification itself does not create a new mandatory document checklist for every exporter. Why Do RBI and FEMA Still Matter? The DGFT amendment does not replace India's foreign-exchange rules. RBI directions continue to matter, especially for ACU transactions, and trade with Nepal and Bhutan. Para 2.53 also directly connects qualifying INR realisation with accounts opened under the applicable FEMA deposit regulations. A business planning an INR export transaction should therefore answer three separate questions: Is the currency treatment allowed under FTP? Is the proposed payment route permitted under RBI/FEMA rules? Will the payment qualify for the FTP benefit or export obligation the business wants to rely on? If any one of these is ignored, the review is incomplete. What Does the Amendment Mean for Different Businesses? The amendment affects businesses differently, depending on their export structure, payment arrangements, banking relationships, and compliance responsibilities. Exporters The revised rules give exporters more clarity on when INR can be used. That can be commercially useful, especially where the overseas customer is comfortable settling in Indian Rupees. At the same time, businesses now need to pay greater attention to the destination country and the banking structure. MSME Exporters For an MSME, INR settlement may offer another workable payment option where the buyer and bank support it. The difficulty is usually not the wording of the rule itself. Smaller businesses may not have separate legal, treasury and foreign-trade teams to check the contract, bank route and FTP benefit together. A simple internal review before finalising the payment terms can therefore become valuable. Finance and Treasury Teams Finance teams may need to check: Invoice currency, Actual payment currency, Bank credit, Account structure, Realisation records, and Matching of payments against exports. Export Compliance Teams Compliance teams should pay close attention to: Country classification, Applicable part of Para 2.52, Conditions under Para 2.53, Relevant RBI directions, Incentive eligibility, and Export-obligation records. Business Impact at a Glance Stakeholder Likely Effect Main Area to Review Exporters More flexibility in permitted currency arrangements Contract and payment terms MSME exporters Another possible settlement route Banking and documentation Finance teams More attention to currency and realisation records Invoice and bank reconciliation Treasury teams INR may be considered for selected transactions Payment route Compliance teams Country and scheme conditions need closer mapping Para 2.52 and Para 2.53 Businesses claiming FTP incentives Qualifying INR receipts may be recognised Scheme eligibility Businesses with export obligations Certain INR realisations may count Authorisation and supporting records What Are the Main Benefits for Exporters? The revised rules can help businesses in a few practical ways. More Choice in Currency For many non-ACU transactions, the FTP wording now clearly recognises both foreign currency and Indian Rupees. That gives the exporter and overseas buyer more room to choose a commercially suitable currency, provided the applicable banking rules are followed. Better Treatment of INR Receipts A qualifying INR receipt can now be treated at par with a foreign-currency receipt for the FTP purposes covered by Para 2.53. For exporters using FTP incentives or working under export obligations, which can make INR settlement more practical. Better Match Between FTP and FEMA DGFT has expressly said that the amendment is meant to align the FTP provisions with the Foreign Exchange Management (Manner of Receipt and Payment) Regulations, 2023. That alignment should make it easier to read both frameworks together. It still does not remove the need for transaction-specific checks. What Could Still Be Difficult for Exporters? The revised rule is more flexible, but it is not completely uniform. Country Classification Comes First A business cannot decide the payment structure without knowing whether the buyer is in: A normal non-ACU market, An ACU country, Nepal, Bhutan, or Iran. More Than One Rule May Apply A single export transaction may involve: FTP, DGFT instructions, RBI directions, FEMA regulations, and The conditions of an individual export scheme. For a smaller business, keeping these rules connected can be difficult. INR Does Not Automatically Mean Eligible This is probably the biggest area where confusion can arise. INR payment is permitted in a wider set of situations, but that does not mean every INR payment qualifies for an incentive. The banking route and scheme conditions still matter. Is This a Right Decision or an Additional Burden? On balance, the amendment appears to offer more flexibility than an additional burden. The biggest positive is that the FTP now gives clearer recognition to eligible export payments received in Indian Rupees. This is useful for businesses that want to use permitted INR settlement without losing FTP treatment simply because the payment was not received in foreign currency. It also brings the trade-policy wording closer to the foreign-exchange payment framework. Exporters will still need to look at the rules that apply to each country rather than treating every INR transaction the same way. ACU transactions require a separate check, while Nepal and Bhutan follow their own provisions. Iran continues to fall under Para 2.19, and RBI and FEMA requirements also remain relevant alongside the FTP. For businesses that already have proper export and payment checks in place, this should be manageable. The problem arises when the amendment is reduced to a simple statement that "INR payment is allowed." The payment still needs to follow the correct route, meet the applicable country requirements and qualify under the relevant FTP conditions if a benefit is being claimed. Could This Encourage Wider Use of the Indian Rupee in Trade? The notification itself does not say that its purpose is to make the Rupee an international currency. Its stated purpose is regulatory alignment. Still, the change may make INR settlement more practical. An exporter is more likely to consider an INR-based payment arrangement when there is clearer certainty that an eligible Rupee receipt can still receive the required FTP treatment. Whether businesses actually choose INR will depend on commercial factors as well, including: Buyer's preference, Banking arrangements, Currency exposure, Availability of a permitted payment route, and Applicable RBI rules. The amendment supports the use of INR where it is commercially and legally suitable. It does not make INR mandatory. What Should Exporters Do Now? Exporters do not need to treat this as a new licence or registration requirement. The better approach is to review transactions that could be affected. 1. Check the Destination: First identify whether the buyer is located in: A non-ACU country, An ACU country, Nepal, Bhutan, or Iran. 2. Review the Contract Currency: Check whether the currency mentioned in the contract fits the revised Para 2.52. 3. Match the Invoice: The invoice currency should be consistent with the contract and the applicable regulatory treatment. 4. Confirm the Payment Route: Where the transaction will be settled in INR, confirm that the banking structure is permitted. 5. Check Para 2.53 before Claiming a Benefit: If the business wants to use that INR receipt for an FTP incentive or export obligation, verify the conditions under Para 2.53. 6. Review the Individual Scheme: The currency rule does not replace the requirements of the scheme or authorisation itself. 7. Keep the Records Consistent: Contract, invoice, shipping documents, bank records and FTP documentation should match each other. Exporter Review Checklist Review Point Type of Check Destination country identified Regulatory Para 2.52 treatment checked Regulatory Contract currency reviewed Regulatory/commercial Invoice currency checked Internal control Payment mechanism reviewed Banking/regulatory RBI directions checked where relevant Regulatory FEMA conditions considered Regulatory Para 2.53 eligibility checked Regulatory Individual FTP scheme checked Regulatory Export obligation reviewed where applicable Regulatory Iran Para 2.19 checked where relevant Regulatory Bank and export records matched Internal control The checklist is meant to help businesses organise their review. It should not be treated as a separate statutory filing requirement created by the notification Risks Exporters Should Avoid The revised rules can be used more effectively if businesses avoid a few obvious interpretation risks. These include: Using the general rule for an ACU transaction without checking the special provisions, Treating Nepal and Bhutan in the same way as every other destination, Assuming every INR payment is eligible for an incentive, Ignoring the banking channel through which the money was received, Failing to check whether the relevant INR account meets FEMA requirements, Claiming an FTP benefit without checking the scheme's other conditions, Treating INR receipt as automatic fulfilment of an export obligation, Ignoring Para 2.19 in an Iran-related export, and Allowing contract, invoice and bank records to show different payment terms without explanation. Most of these problems are easier to correct before the transaction is completed than after an incentive or export-obligation claim is questioned. What Business Opportunities Could the Change Create? The notification does not create a new export market, but it can make certain existing trade arrangements easier to structure. More Practical INR Settlement Businesses dealing with overseas buyers who are comfortable paying in INR may now find the FTP treatment easier to understand. That can give exporters another payment option in markets where the banking arrangement supports Rupee settlement. Better Treasury Planning Large exporters and businesses dealing with several countries may also review whether INR settlement makes sense for selected transactions. That decision should still be based on commercial terms and actual currency exposure rather than on the DGFT amendment alone. Greater Need for Transaction-Level Review As more payment options become available, companies may need better checks before finalising: Contract currency, Invoice currency, Payment channel, FTP benefit treatment, and Export-obligation records. How Corpseed Can Help The revised FTP provisions connect four things that businesses sometimes review separately: the destination country, contract currency, banking route and FTP benefit. Corpseed can support exporters in bringing these areas together before a transaction is relied upon for a regulatory or scheme-related purpose. FTP Applicability Review Corpseed can help examine: Export destination, Nature of the transaction, Applicable Para 2.52 rule, and Relevance of Para 2.53. Export Contract and Invoice Review Support may include checking whether: Contract denomination is consistent with the applicable FTP rule, Invoice currency matches the commercial terms, Payment provisions are correctly reflected, and Transaction documents are internally consistent. INR Export-Realisation Review For businesses receiving payment in Indian Rupees, Corpseed can assist in reviewing the available documents against the relevant FTP conditions. Banking approval or acceptance remains with the concerned authorised banking channel and applicable authority. FTP Benefit and Export-Obligation Assessment Where an exporter intends to rely on an INR receipt for an FTP purpose, Corpseed can support a review of: Applicable export benefits, Incentive conditions, Export-obligation requirements, and Supporting records. The actual benefit will continue to depend on the conditions of the relevant scheme or authorisation. Compliance Gap Assessment A document-level review can identify mismatches between: Contract, Invoice, Bank records, Export-realisation evidence, and FTP documentation. Ongoing Regulatory Support Para 2.52 itself refers to RBI directions issued from time to time. Businesses using INR trade arrangements may therefore need to keep track of later DGFT, RBI and FEMA changes. Corpseed's export compliance services can support businesses with regulatory interpretation, document review, DGFT-related compliance assistance and ongoing monitoring. Final recognition of export proceeds, incentives, export obligations or banking arrangements remains subject to the applicable rules and the competent authorities. Key Takeaways DGFT's Notification No. 30/2026-27 has changed Para 2.52 and Para 2.53 of FTP 2023 with immediate effect from 20 August 2026. For exporters, the practical points are straightforward: Non-ACU export contracts may generally be denominated in foreign currency or INR. Export proceeds in qualifying cases may also be realised in INR. ACU transactions need separate treatment. Nepal and Bhutan have their own rules. Eligible INR export proceeds can receive parity with foreign-currency realisations for specified FTP benefits and export obligations. INR receipt alone does not create automatic eligibility. Iran-related exports remain subject to Para 2.19. RBI and FEMA requirements still need to be checked alongside FTP. For businesses planning to use INR settlement, the safest approach is to check the destination, banking route and FTP purpose together before finalising the transaction.

Subject

Summary: Television advertising rules in India changed on 21 August, 2026 when the Ministry of Information and Broadcasting notified the Cable Television Networks (Amendment) Rules, 2026 through G.S.R. 751(E). The amendment is short. Its effect, however, deserves careful reading. The Government has omitted Rule 7(11) of the Cable Television Networks Rules, 1994. That was the provision which contained the well-known 12-minute-per-hour advertising limit, divided between commercial advertisements and a channel's own promotional content. The amendment took effect on the date it was published in the Official Gazette. For broadcasters and advertisers, this gives rise to an obvious question: does this mean television channels can now carry advertisements without any time limit? The answer is not as simple as the headline suggests. Rule 7(11) has gone, but the rest of the Advertising Code has not. A separate TRAI framework on advertisement duration also needs to be considered. Notification at a Glance Particular Details Issuing authority Ministry of Information and Broadcasting Government Government of India Notification Cable Television Networks (Amendment) Rules, 2026 Notification number G.S.R. 751(E) Date 21 August 2026 Governing law Cable Television Networks (Regulation) Act, 1995 Principal Rules Cable Television Networks Rules, 1994 Provision affected Rule 7(11) Change made Rule 7(11) omitted Effective date 21 August 2026 Separate transition period Not specified New application required No new application prescribed New registration required No new registration prescribed New Government fee Not prescribed Main area affected Television advertising duration The Government used its rule-making powers under Section 22 of the Cable Television Networks (Regulation) Act, 1995 to make the amendment. The Gazette does not replace Rule 7(11) with another formula. It simply removes the sub-rule. That is why businesses need to distinguish between what has actually been deleted and what continues elsewhere in the regulatory framework. How Television Advertising Is Regulated Under the Cable Television Framework The starting point is the Cable Television Networks (Regulation) Act, 1995. Section 6 of the Act deals with the Advertisement Code. In simple terms, advertisements transmitted or retransmitted through cable service must comply with the prescribed Advertising Code. The detailed requirements are set out in Rule 7 of the Cable Television Networks Rules, 1994. Rule 7 covers much more than advertisement duration. It sets requirements for what advertisements may contain, how certain claims are presented and other standards that apply to television advertising. Rule 7(11) was only one part of this wider framework. This distinction matters when reading the 2026 notification. It does not say that Rule 7 has been omitted altogether. Instead, it specifically states that sub-rule (11) of Rule 7 shall be omitted. In other words, the amendment removes one provision from the Advertising Code, while the rest of Rule 7 continues to apply. What Did Rule 7(11) Say before It Was Removed? Rule 7(11) was introduced in 2006. Before the 2026 amendment, it provided that a programme could not carry advertisements exceeding 12 minutes in one hour. That 12-minute period could include: up to 10 minutes of commercial advertisements, and up to two minutes of the channel's own promotional programmes. The original 2006 Gazette amendment contains this 10+2 structure. The rule therefore worked as an advertising-time ceiling under the Cable Television Networks Rules. For a broadcaster, it was not simply a content standard. It directly affected how much commercial and self-promotional material could be fitted around television programming. For advertisers and media agencies, the rule also influenced the amount of television inventory that a channel could offer during a given period. That is the provision that has now been removed from the Cable Television Networks Rules. What Has Actually Changed Under G.S.R. 751(E)? The cleanest way to understand the amendment is to separate the legal change from its possible commercial effect. The legal change is straightforward: Rule 7(11) no longer forms part of the Cable Television Networks Rules, 1994 from 21 August 2026. This means the following 10+2 formula has been removed from those Rules: 10 minutes of commercial advertisements Two minutes of self-promotion Total ceiling of 12 minutes per hour There is no replacement formula in G.S.R. 751(E). The notification also does not introduce any of the following: A different advertisement-duration limit A new application A new registration A Government approval process A reporting form A new fee A separate compliance deadline Taken together, this makes the amendment a deregulatory change rather than a new filing-based compliance requirement. But the wording still needs to remain precise: the amendment removes Rule 7(11). It does not expressly repeal every other rule or regulation dealing with television advertisements. Old Rule 7(11) vs the Position after 21 August 2026 Area Earlier Position Position After 21 August 2026 What It Means Rule 7(11) Formed part of Rule 7 Omitted The sub-rule no longer applies under the Cable Television Networks Rules Total advertising time Maximum 12 minutes per hour under Rule 7(11) No replacement limit inserted in Rule 7(11) The old limit has been removed from these Rules Commercial advertising Up to 10 minutes per hour The deleted sub-rule no longer sets this limit Broadcasters need to check the wider regulatory position Channel promotion Up to two minutes per hour The deleted sub-rule no longer sets this limit The former 10+2 division is removed Other Rule 7 provisions Continued separately The deleted sub-rule no longer sets this limit Advertising content compliance continues to matter Commencement Old rule applied before amendment Change effective from 21 August 2026 No separate grace period is stated For businesses, the most useful takeaway is that an old scheduling restriction has disappeared from one legal instrument, but the entire television advertising framework has not disappeared with it. When Did the Amendment Take Effect? There is no waiting period. The Cable Television Networks (Amendment) Rules, 2026 state that they come into force on the date of publication in the Official Gazette. That date is 21 August 2026. The notification does not provide a separate: implementation window, transition period, grace period, or future compliance date. For legal registers and internal regulatory trackers, 21 August 2026 is therefore the relevant date. The practical question for broadcasters is not when the amendment begins. That part is clear. The harder question is how it sits alongside the separate TRAI regulation on advertisement duration. Can Television Channels Now Carry Unlimited Advertisements? This is where businesses should be careful. From the perspective of the Cable Television Networks Rules, the old 12-minute provision in Rule 7(11) has been removed. The Government had already announced on 14 August 2026 that it had decided to remove the 12-minute advertisement-duration cap. The Ministry linked the decision to changes in the broadcasting market, digitisation, competition and ease of doing business. However, television advertising duration has also been dealt with separately by the Telecom Regulatory Authority of India (TRAI). TRAI's Standards of Quality of Service (Duration of Advertisements in Television Channels) Regulations, 2012, together with the 2013 amendment, form a separate regulatory instrument. TRAI's official consolidated-regulations page currently continues to list those regulations under broadcasting and cable services. That means a broadcaster should not read G.S.R. 751(E) in isolation and immediately assume that there is no other advertisement-duration rule to consider. A safer reading is: The 12-minute restriction contained in Rule 7(11) has been removed from the Cable Television Networks Rules. The position under any separate applicable TRAI regulation should also be checked before operational changes are made. That wording is less dramatic than saying “TV advertising is now unlimited,” but it is much more useful from a compliance point of view. Has the Government Removed the Entire Advertising Code? No. Only Rule 7(11) has been omitted. Other parts of Rule 7 continue to matter because they deal with the content and acceptability of advertisements, not just how much advertising can be shown. For example, the Ministry of Information and Broadcasting stated in March 2026 that the Advertising Code continues to cover matters such as: Advertising claims that are difficult to prove Advertisements that may endanger children or encourage unhealthy practices Advertisements that violate the Advertising Standards Council of India (ASCI) self-regulatory code The Ministry specifically referred to Rule 7(5), Rule 7(7) and Rule 7(9) while explaining the existing television advertising framework. So, broadcasters still need to consider two separate questions: How much advertising can be carried? And is the advertisement itself legally acceptable? The 2026 amendment changes the first question to the extent that Rule 7(11) has been removed. It does not make the second question irrelevant. What Still Matters after Rule 7(11) Is Removed? The biggest mistake would be to treat this amendment as complete deregulation of television advertising. Advertising content still needs to be checked against the applicable Advertising Code. A channel cannot assume that an advertisement is acceptable simply because the time-limit provision has been removed. The Ministry has continued to describe private satellite television channels as being required to follow the Programme Code and Advertising Code. It has also referred to enforcement action where those codes are violated. This means legal and compliance teams still need to look at issues such as: misleading or unsubstantiated claims, treatment of children, prohibited or restricted advertising, applicable ASCI requirements, sector-specific advertising rules, and other obligations that may apply to the product being promoted. Rule 7(11) was about time. The rest of advertising compliance goes much further than time. Who Should Pay Attention to This Change? The amendment is most relevant to businesses that either sell, plan, buy or monitor television advertising. Television Broadcasters and Channels Broadcasters are the most directly affected. Their commercial, programming and compliance teams may need to review any internal system built around the old 10+2 limit. This could include scheduling tools, advertising policies, operational manuals and legal checklists. Advertisers and Brands For brands, the change may eventually influence how television advertising packages are structured. A channel with greater scheduling flexibility may offer different combinations of advertising inventory. That does not mean every brand will automatically receive more or cheaper airtime. Pricing will still depend on commercial factors such as audience size, programme demand, time slot and negotiations with the broadcaster. Advertising and Media-Buying Agencies Media agencies may have to reconsider assumptions built into campaign planning. If broadcasters change the way they structure commercial breaks, or inventory, agencies may see new placement options. Contractual and compliance terms will remain important. Cable Television Operators The notification does not create a new application or filing obligation for cable operators. Their main concern is ensuring that the wider Cable Television Networks framework is not misunderstood merely because one sub-rule has been removed. Legal and Compliance Teams For compliance teams, this amendment is less about submitting something to the Government and more about keeping internal rules accurate. An old SOP that still states “Rule 7(11) requires 12 minutes per hour” will no longer correctly describe the Cable Television Networks Rules after 21 August 2026. How Could Broadcasters Be Affected? The first likely effect is greater flexibility in commercial planning under the Cable Television Networks Rules. Previously, Rule 7(11) gave broadcasters a fixed numerical ceiling. With that provision removed, broadcasters may have more room to review how they organise: Commercial breaks Channel promotions Advertising inventory Programme schedules Premium advertising slots Advertiser packages However, this does not mean every broadcaster will automatically move towards longer advertising breaks. A channel still has to keep viewers engaged. More advertising could create additional inventory and revenue opportunities, but too many interruptions could also make programmes less attractive to the audience. The commercial impact will therefore depend on more than just the removal of the earlier limit. Broadcasters will need to balance advertising revenue, viewer behaviour, programme quality and competition when deciding how to use the additional flexibility. Before making any major change to advertising practices, the separate TRAI position should also be reviewed from a legal and regulatory perspective. What Does This Mean for Advertisers and Media Agencies? Advertisers may eventually have more choice, but there is no guaranteed commercial outcome. If broadcasters restructure their inventory, advertisers could see: different break lengths, more placement options, additional programme-specific packages, greater flexibility during high-demand periods, or new combinations of promotional slots. Media buyers may also have to compare channels differently. A larger quantity of inventory does not automatically mean better inventory. A slot during a popular programme may still carry a premium, while less attractive airtime may remain difficult to sell. The amendment therefore gives the industry greater room to make commercial decisions. It does not decide those commercial decisions for them. What Could Change for Television Viewers? Viewers may notice a difference only if broadcasters choose to change their advertising schedules. Some channels may use the regulatory change to adjust the length or frequency of commercial breaks, while others may keep their current format if they believe it works well. Audience behaviour will also play an important role. A broadcaster that carries too much advertising could irritate viewers, particularly when audiences can easily switch to another television channel or digital platform. This is also part of the wider market context cited by the Government when announcing the policy. The Ministry noted that India had only 62 television channels in 2006, compared with more than 900 today, alongside fully digitised television-distribution platforms. The regulatory limit may be changing, but competition still provides a practical check on how far broadcasters can go with advertising. Why Did the Government Remove the 12-Minute Cap? The Gazette notification itself does not give a detailed explanation, but the Ministry's announcement of 14 August 2026 provides some context. The Government said the television market has changed significantly since the 12-minute limit was introduced in 2006. At that time, there were far fewer television channels and cable distribution was largely analogue. Today, television distribution through cable, Direct-to-Home, HITS and IPTV is digital, and viewers have access to hundreds of channels. The Ministry also pointed to the growing competition from digital media. Traditional television channels now compete with online platforms for both viewers and advertising budgets, while digital platforms do not follow the same television advertisement-duration structure. The Government presented the change as a step towards fair competition and ease of doing business in the broadcasting sector. That is the official policy explanation. Whether individual broadcasters actually earn more from the change will still depend on what advertisers are willing to buy and how viewers respond. Possible Benefits for the Television Industry There are clear commercial reasons why broadcasters may welcome the change. More scheduling freedom: Removing the old Rule 7(11) formula gives channels more freedom under the Cable Television Networks Rules to think about how advertising is arranged. Better inventory planning: Broadcasters may have more flexibility when planning advertising around programmes with different levels of audience demand. Greater commercial choice: A fixed 10+2 structure leaves little room for variation. Its removal allows businesses to consider different commercial models, subject to the wider legal framework. Closer competition with digital platforms: This is one of the areas specifically highlighted by the Government. Less dependence on an old market structure: Television today operates very differently from the analogue broadcasting environment of 2006. These are potential benefits, not guaranteed outcomes. A broadcaster still needs advertiser demand before additional inventory has commercial value. Where Could Businesses Face Difficulty? The main challenge is not understanding what the Gazette says. That part is relatively straightforward. The difficulty lies in applying the change correctly while considering the wider regulatory framework. There are a few areas that businesses should review before changing their broadcasting practices. The MIB and TRAI Frameworks Need to Be Read Together Rule 7(11) has been removed from the Cable Television Networks Rules, but TRAI's official regulatory pages continue to list its advertisement-duration regulations. Legal and compliance teams should therefore review the MIB and TRAI frameworks together before making operational changes. Old Policies May No Longer Be Accurate Many internal SOPs and compliance manuals may have been prepared around the earlier 12-minute rule. These documents should be reviewed and updated where necessary. At the same time, removing references to Rule 7(11) should not result in other advertising requirements being removed by mistake. The Advertising Code remains broader than the deleted duration provision. Removing Too Much Is Also a Risk Updating the compliance manual for the removal of Rule 7(11) should not mean deleting other advertising requirements. The Advertising Code still covers more than the duration limit. Commercial Teams May Move Faster Than Compliance Teams Sales teams may see the amendment as an immediate opportunity to create additional advertising inventory or revise packages. Compliance teams, however, may need more time to assess the wider regulatory position. Both sides should work from the same interpretation before any operational changes are introduced. Is This a Business-Friendly Change or an Additional Compliance Concern? Area Regulatory certainty Point to Watch Advertising schedules Greater flexibility under the Cable Television Rules Other applicable regulations need review Commercial inventory More room to structure airtime More inventory does not guarantee demand Broadcaster revenue Potential opportunity Revenue growth is not automatic Advertisers More placement flexibility may develop Pricing remains market-driven Media agencies New planning options may emerge Contracts and broadcaster policies may differ Compliance One old restriction has been removed Remaining Advertising Code requirements continue Viewers Broadcasters can experiment with formats Longer breaks may affect viewer experience Regulatory certainty G.S.R. 751(E) is clear on Rule 7(11) TRAI position should continue to be monitored For broadcasters, the amendment is generally business-friendly because it removes a fixed restriction from the Cable Television Networks Rules. But it would be risky to interpret that as permission to ignore every other advertising requirement. The sensible approach is to use the added flexibility only after checking the complete legal position. Does the Amendment Require a New Registration, Filing or Approval? No new standalone compliance filing has been created by G.S.R. 751(E). The notification does not prescribe a new: licence, registration, application, certificate, approval, Government fee, return, or filing portal. Its operative change is simply the omission of Rule 7(11). This distinction is useful for businesses because not every regulatory amendment creates a new Government process. In this case, the immediate work is mainly internal: understand the change, check the remaining rules and update business practices where appropriate. Compliance Risks Businesses Should Avoid There are a few interpretations that could create unnecessary problems. Treating Rule 7 as deleted: It has not been deleted. Only sub-rule (11) has been removed. Assuming television advertising is completely unregulated: Advertisement content remains subject to the wider framework. Ignoring TRAI: Broadcasters should review the separate advertisement-duration regulations rather than relying only on the MIB notification. Using outdated compliance manuals: Old references to Rule 7(11) should be identified and reviewed. Changing contracts without legal review: Agreements between broadcasters, agencies and advertisers may contain clauses linked to advertising duration. Assuming more inventory means more revenue: The Gazette does not promise any financial benefit. Relying on headlines instead of the notification: The exact legal wording is much narrower than many simplified headlines. Missing later clarification: MIB and TRAI updates should continue to be tracked. What Should Broadcasters and Advertisers Do Now? Before changing advertising practices, businesses should first understand the amendment, review existing controls and check the wider regulatory position. Priority Action Team Involved Purpose Immediate Read G.S.R. 751(E) Legal/Compliance Confirm the exact amendment Immediate Review the latest Rule 7 position Legal Identify what remains applicable Immediate Check TRAI advertisement-duration regulations Regulatory/Legal Understand the wider duration framework High Find internal references to Rule 7(11) Compliance Remove outdated legal references High Review advertising and scheduling SOPs Operations/Programming Align internal controls Medium Check broadcaster-agency contracts Legal/Commercial Identify clauses linked to the former limit Medium Brief sales and media teams Management/Compliance Avoid inconsistent interpretation Ongoing Track MIB and TRAI developments Regulatory Affairs Capture any further clarification None of these internal actions should be confused with a new statutory filing requirement. They are practical steps for keeping business operations aligned with the changed position. What Should Advertising Compliance Teams Review Internally? An internal compliance review does not need to become a large exercise if the organisation knows where Rule 7(11) was being used. Start with documents that directly affect advertising operations. These may include: television advertising SOPs, programming manuals, compliance checklists, media-sales policies, automated scheduling rules, advertising contracts, agency agreements, legal reference sheets, employee training material, and regulatory trackers. Any reference to Rule 7(11) should be checked against the amended position. At the same time, controls linked to the remaining Advertising Code should stay in place. For businesses that do not maintain a dedicated regulatory team, a focused compliance gap assessment can help identify which documents are actually affected instead of rewriting every policy unnecessarily. What Should Businesses Watch Next? The next area to watch is the relationship between the MIB amendment and TRAI's separate advertisement-duration framework. The Government has clearly removed Rule 7(11) from the Cable Television Networks Rules. TRAI's official consolidated-regulations section, however, currently continues to display the Standards of Quality of Service (Duration of Advertisements in Television Channels) Regulations, 2012 and its related amendment. Broadcasters should therefore keep an eye on: any TRAI amendment, withdrawal or repeal of the existing regulation, official clarification, changes to related directions or reporting requirements, and further MIB communication. Until another official development occurs, compliance teams should work from the actual published instruments rather than assuming what the next step will be. How Corpseed Can Help The Cable Television Networks (Amendment) Rules, 2026 are a good example of why a short notification can still require careful regulatory work. The Gazette clearly removes Rule 7(11), but a broadcaster may still need to answer several practical questions before changing its advertising schedule. Which parts of Rule 7 remain relevant? Does another regulatory instrument apply? Are internal SOPs outdated? Do advertising or agency contracts refer to the old limit? Corpseed's regulatory compliance services can support businesses in reviewing these issues in a structured way. Relevant support may include: Regulatory applicability assessment to understand how the 2026 amendment relates to the business and its television advertising activities. Media regulatory compliance review covering the Cable Television Networks Act, Rules and other relevant broadcasting requirements. Rule 7 and Advertising Code assessment to separate the deleted duration provision from continuing content obligations. MIB and TRAI regulatory review where different regulatory instruments need to be read together. Compliance gap assessment for existing advertising policies, manuals and internal controls. Advertising SOP and policy review to identify outdated references to Rule 7(11). Contract and compliance-document review support where broadcaster, advertiser or agency agreements refer to advertisement duration. Ongoing compliance support and regulatory monitoring for later MIB or TRAI amendments and clarifications. Good compliance consulting services should help a business understand what the law actually requires before it changes an established operating process. They should not be used to create unnecessary filings or make promises about how a regulator will decide a future issue. Corpseed can assist broadcasters, advertisers, agencies and other media businesses that need regulatory advisory services to review the effect of the 2026 amendment, identify compliance gaps and bring internal advertising practices in line with the applicable framework. Professional support does not replace the Ministry of Information and Broadcasting, TRAI, a court or another competent authority. It also cannot guarantee a regulatory interpretation or commercial outcome. Businesses looking for regulatory compliance services for television advertising, media regulation or related internal compliance reviews can use professional assistance to organise the legal position before making changes to schedules, policies or commercial agreements. Key Takeaways The Ministry of Information and Broadcasting issued G.S.R. 751(E) on 21 August 2026. The notification creates the Cable Television Networks (Amendment) Rules, 2026. Rule 7(11) of the Cable Television Networks Rules, 1994 has been omitted. Rule 7(11) earlier contained a 12-minute-per-hour advertising ceiling, consisting of up to 10 minutes of commercial advertising and two minutes of self-promotion. The amendment took effect on 21 August 2026 and does not specify a separate transition period. The amendment does not delete Rule 7 as a whole. Other Advertising Code requirements remain relevant to television advertising. TRAI's separate advertisement-duration regulations should also be checked before broadcasters treat television advertising duration as completely unrestricted. G.S.R. 751(E) does not create a new registration, application, fee or standalone Government filing. Broadcasters and advertisers should review internal policies, contracts and compliance references rather than relying only on simplified headlines about removal of the advertising cap.

Subject

Summary: 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. Notification at a Glance 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 Regulatory Framework Behind the Amendment 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. What Exactly Has DGFT Changed? 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 New One Star Export House Eligibility Rule in Simple Words The easiest way to understand the revised provision is to separate it into its individual parts. Status involved: One Star Export House. Applicant covered: An applicant outside the Gems & Jewellery sector. Period DGFT looks at under this clause: Three preceding financial years. What is now sufficient: Export performance in any two of those three financial years. When the change applies: Immediately from the notification. What still matters: Other applicable provisions of Para 1.25. 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 “two years of exports equals One Star status”. The rest of the eligibility framework still has to be checked. Who Is Likely to Benefit from the Change? The relaxation is most relevant to businesses that export regularly but may not have export activity during every financial year. This can include: exporters with performance in two of the previous three financial years businesses that had a temporary break in exports during one year growing exporters whose overseas business became active only during part of the three years MSMEs with an uneven export cycle exporters that had previously found the all-three-years condition difficult to satisfy. 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. Scope and Applicability 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. Why the Gems & Jewellery Sector Needs Separate Attention The two-out-of-three-year relaxation does not apply to the Gems & Jewellery sector under this notification. DGFT has expressly used the words “other than for Gems & Jewelry Sector” 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. Which Financial Years Have to Be Checked? 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. What Has Not Changed? 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: all other Status Holder requirements have been removed exports during two years are enough on their own every Export House category gets the same relaxation Gems & Jewellery exporters can use the two-out-of-three-year condition approval becomes automatic once the performance-period condition is met. For businesses assessing eligibility, this is where a complete review matter. Reading only the new proviso can give an incomplete picture. Does the Relaxation Cover Two Star, Three Star, Four Star or Five Star Export Houses? 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. When Does the Amendment Take Effect? 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. Why This Change Matters for Exporters with Uneven Export History 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. Impact on MSMEs, Manufacturers and Merchant Exporters 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 “MSME concession”. 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. Is Export Performance in Two Years Enough to Get One Star Status? 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. What the Notification Does Not Introduce There is also value in looking at what is missing from the notification. Notification No. 33/2026-27 does not expressly introduce: a new government fee a new application form a fresh document list a new penalty a separate filing deadline a new transition period a processing timeline a special approval route. 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. What Are the Practical Benefits for Eligible Exporters? The amendment's strongest benefit is flexibility. One inactive year carries less weight. 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. The rule better accommodates uneven export cycles. International orders can fluctuate. The revised condition is less rigid for qualifying exporters whose performance was not continuous across every year. Growing exporters may find the condition easier to meet. 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. Challenges Businesses Still Need to Consider 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. Is This a Helpful Relaxation or an Additional Burden? 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: businesses have more flexibility when reviewing their export history one inactive year does not necessarily end the assessment some exporters can reconsider eligibility growing exporters may find the requirement easier to satisfy. 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. What Exporters Should Check Before Relying on the New Rule Before treating the amendment as applicable, businesses should work through a few basic checks. Confirm that the business is seeking One Star Export House status. Check whether the applicant falls outside the Gems & Jewellery sector. Identify the three preceding financial years relevant to the assessment. Confirm whether export performance exists in at least two of those years. Review the remaining applicable provisions of Para 1.25. Match the export-performance information with internal financial and export records. Check whether DGFT has issued any later amendment affecting the position. Make sure the information proposed for filing is consistent with supporting records. These last record-review measures are practical controls rather than fresh obligations created by Notification No. 33/2026-27. Risks to Avoid The amendment is simple enough to read quickly, which is exactly why some details can be missed. Businesses should avoid: treating two years of exports as automatic One Star approval applying the relaxation to Gems & Jewellery assuming the same rule applies to all Export House categories overlooking the remaining provisions of Para 1.25 using the wrong financial-year period relying on inconsistent export-performance information using an old version of FTP requirements when preparing an application. A proper pre-application check is usually easier than correcting an eligibility assumption after documents have already been prepared. What Businesses Should Do Next Review the Status Category First Start by confirming that the proposed application is actually for One Star Export House status. The new proviso is specifically linked to this category. Check Sector Eligibility Determine whether the Gems & Jewellery exclusion applies. If it does, the new two-out-of-three-year relaxation should not be relied upon. Examine Export Performance Across the Relevant Period 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. Review the Rest of Para 1.25 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. Reconcile Records Before Filing Export, finance and compliance records should be checked together. Any mismatch is better identified before the application process begins. Check the Latest DGFT Position The amendment is effective from 21 August 2026, but exporters should still review later DGFT notifications or public notices before making a filing. Business and Regulatory Perspective 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. Future Outlook 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: DGFT notifications public notices amendments to FTP 2023 changes to Para 1.25 procedural changes affecting Status Holder applications. A later amendment, if issued, should be read separately on its own terms. How Corpseed Can Help? 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: One Star Export House eligibility assessment based on the applicant's export profile review of the relevant three-year export-performance period interpretation of the applicable FTP 2023 Status Holder provisions Status Holder application support where the applicant is eligible to proceed review and organisation of supporting regulatory and export records DGFT filing assistance based on the applicable procedure export compliance services for businesses dealing with wider DGFT requirements monitoring of relevant DGFT notifications and policy changes. 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. Key Takeaways 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. DGFT issued Notification No. 33/2026-27 on 21 August 2026. The notification amends Para 1.25(d) of FTP 2023. The amendment applies with immediate effect. A One Star Export House applicant outside Gems & Jewellery can have export performance in any two of the three preceding financial years for this condition. The Gems & Jewellery sector does not receive this relaxation under the notification. The new proviso does not expressly extend to other Status Holder categories. Other provisions of Para 1.25 remain applicable. Two years of export performance do not automatically result in One Star Export House recognition. 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.

Subject

Summary: The Directorate General of Foreign Trade ( DGFT ) has changed the import policy condition for raw sugar under Exim Code 170114. Through Notification No. 31/2026-27 dated 20 August 2026, DGFT has allowed imports under a 10-lakh metric tonne Tariff Rate Quota (TRQ) on a duty-free basis up to 31 October 2026. The notification also deals with businesses that have already imported raw sugar under certain Advance Authorisations. Existing authorisations issued under SION E52 have been given a one-time option to move from the Advance Authorisation Scheme to the TRQ Scheme for the quantity of raw sugar actually imported up to the date of the notification. That option comes with conditions. A business choosing conversion has to pay the exempted GST availed when the raw sugar was imported. Refined sugar made from that imported raw sugar must also be sold in the domestic market by 31 October 2026. There is one more point business should keep in mind. The notification announces the policy, but it does not provide the complete operating procedure. DGFT will issue a separate Public Notice explaining how the TRQ and the one-time conversion will be administered. Notification at a Glance Particular Details Issuing Ministry Ministry of Commerce and Industry Department Department of Commerce Authority Directorate General of Foreign Trade Notification No. 31/2026-27 S.O. Number S.O. 4600(E) Date 20 August 2026 Law referred to Foreign Trade (Development and Regulation) Act, 1992 FTP reference Paragraphs 1.02 and 2.01 of Foreign Trade Policy, 2023 ITC (HS) 2022 – Schedule I (Import Policy) Chapter Chapter 17 Exim Code 170114 Product Raw Sugar Import policy Free TRQ quantity 10 lakh MT Duty treatment Duty-free within the notified TRQ TRQ available till 31 October 2026 Special conversion facility One-time conversion from Advance Authorisation to TRQ SION covered SION E52 Quantity considered for conversion Raw sugar actually imported up to 20 August 2026 GST condition Exempted GST availed at import must be paid Refined sugar condition Must be sold in the domestic market Domestic-sale deadline 31 October 2026 Detailed procedure To be issued by DGFT through a Public Notice The notification is short, but it makes two changes that matter commercially. One is the fresh duty-free TRQ. The other is the special option given to certain businesses that have already imported raw sugar under SION E52 Advance Authorisations. What Is the Regulatory Framework Behind the Notification? DGFT has issued the notification using powers available under Section 3 of the Foreign Trade (Development and Regulation) Act, 1992. It also refers to paragraphs 1.02 and 2.01 of the Foreign Trade Policy, 2023. For an importer, the legal background does not need to be made more complicated than it is. The practical point is that this is an official change to the import policy condition for one specific tariff entry. ITC (HS), 2022 and Exim Code 170114 India's import policy is organised through ITC (HS) classifications. Each product is placed under a tariff or Exim code, and the policy attached to that code determines how the product can be imported. The present notification deals with Raw Sugar under Exim Code 170114 of Chapter 17. That product-specific wording matters. A company dealing with another form of sugar should first check its classification rather than assuming that the same TRQ automatically applies. What Has Actually Changed in the Raw Sugar Import Policy? The policy entry for raw sugar continues to show the word “Free.” What has changed is the policy condition attached to that entry. Under the revised condition, raw sugar can be imported as “Free” subject to a 10 lakh MT duty-free TRQ up to 31 October 2026. Area Position Shown Earlier Position After Notification Import policy Free Continues to be shown as Free TRQ condition No condition shown in the earlier column 10 lakh MT duty-free TRQ introduced Time limit No such TRQ deadline shown Up to 31 October 2026 Existing SION E52 authorisations No conversion option shown One-time conversion option provided GST on conversion Not applicable under the earlier column Exempted GST availed at import must be paid Refined sugar sale No such condition shown Domestic sale by 31 October 2026 for conversion cases Detailed procedure Not applicable DGFT Public Notice to prescribe procedure “Free” Does Not Mean the Same Thing as “Duty-Free” This distinction is easy to miss. When the import policy says “Free,” it refers to the policy status of the product. It does not automatically mean that every import comes without customs duty, GST or procedural conditions. The expression “duty-free” in this notification is specifically linked to the 10 lakh MT TRQ. That is why an importer should not read the notification as saying that all raw sugar imports have become duty-free. The benefit is linked to the notified quota and the applicable conditions. What Is the 10 Lakh MT Raw Sugar TRQ? A Tariff Rate Quota is a system under which a fixed quantity of a product receives a particular tariff benefit. Here, DGFT has fixed the quota at 10 lakh metric tonnes of raw sugar and allowed duty-free treatment within that quota up to 31 October 2026. The quantity is important because this is not an unlimited duty concession. The notification also does not say that every eligible importer will receive a fixed share of the 10 lakh MT. How the quota will be administered is to be explained separately by DGFT. Until that procedure is available, businesses should not assume how allocation will take place. Three Things an Importer Should Read Together Quantity: The TRQ is limited to 10 lakh MT. Duty treatment: Imports falling within the notified TRQ receive duty-free treatment. Time: The benefit is available only up to 31 October 2026. If any one of these points is ignored, the notification can easily be misunderstood. Which Imports Fall Within the Notification? The scope is fairly narrow. The notification expressly covers: Raw Sugar Exim Code 170114 Chapter 17 ITC (HS), 2022 – Schedule I It does not say that every sugar product or every tariff classification under Chapter 17 receives the same treatment. Product or Situation Position Under This Notification Raw Sugar under Exim Code 170114 Covered Raw sugar under another classification Requires separate review Refined sugar imported directly under another code Not brought within this TRQ merely by this notification Raw sugar imported under eligible SION E52 Advance Authorisation May be relevant to the one-time conversion provision For this reason, product classification should be checked before a business treats the TRQ as applicable. That is a sensible compliance check. It is not a new classification procedure created by this notification. Who Is Most Likely to Be Affected? The immediate impact falls mainly on businesses involved in importing or refining raw sugar. Raw Sugar Importers Importers now have a possible duty-free sourcing route within the 10 lakh MT quota. The opportunity, however, comes with a short time window. Any import plan would need to consider the 31 October 2026 cut-off as well as the procedure DGFT will announce. Importers also need to avoid assuming that announcement of a TRQ is the same as receiving an allocation under it. Sugar Refiners Refiners may benefit if the TRQ makes qualifying imported raw sugar commercially attractive. For refiners that already imported raw sugar under SION E52 Advance Authorisations, the decision is more complicated. They may have to compare the existing Advance Authorisation position with the new conversion option. Production status also matters because the notification covers refined sugar that has already been produced as well as refined sugar that is still to be produced from the relevant imported raw sugar. Existing SION E52 Advance Authorisation Holders This group has received a specific one-time option. DGFT has not given a general conversion right to every Advance Authorisation holder. The wording is tied to Advance Authorisations already issued under SION E52. That difference should be checked before a business starts planning a conversion. How Does the One-Time Advance Authorisation Conversion Work? The conversion provision is separate from the general 10 lakh MT TRQ. DGFT states that Advance Authorisations already issued under SION E52 can be converted once from the Advance Authorisation Scheme to the TRQ Scheme, subject to the conditions in the notification. The quantity covered is not simply whatever appears on the authorisation. The notification specifically refers to the quantity of raw sugar actually imported under that Advance Authorisation up to 20 August 2026. This creates an important distinction: The authorisation may permit one quantity. The business may actually have imported a smaller quantity. For the purpose described in this notification, the actual imported quantity is the relevant figure. That can make a real difference when a company begins checking its records. Is Conversion Compulsory? No. The notification describes it as a one-time option. An eligible business therefore needs to decide whether conversion works commercially for its situation. The answer may differ from one importer to another because GST, inventory, production and domestic-sale plans can all affect the result. Which Advance Authorisations Qualify? Three points can be taken directly from the notification. The Authorisation Must Already Exist- DGFT refers to Advance Authorisations already issued. The notification does not say that future authorisations will automatically receive the same conversion facility. It Must Be Under SION E52- The provision specifically names SION E52. A company should not assume that an authorisation issued under another Standard Input Output Norm is covered. Actual Imports Are the Relevant Quantity- Raw sugar must have actually been imported under the relevant authorisation by the date of the notification. This is why a business considering conversion should first reconcile the authorisation with its actual import records. What About Raw Sugar That Has Already Been Refined? DGFT has addressed this point directly. The conversion provision includes refined sugar that has already been produced from the imported raw sugar. It also covers refined sugar that will be produced from the relevant imported raw sugar still available under the Advance Authorisation. This is useful because raw sugar imported earlier may no longer exist entirely as raw stock. A refinery may already have processed part of it. Before deciding on conversion, the business may therefore want to know: How much raw sugar was imported? How much remains in stock How much has already been refined How much refined sugar is available? How much more refined sugar may be produced from the remaining imported material The notification does not itself prescribe this as a formal reconciliation statement or mandatory document. It is simply a sensible way to understand whether the business can meet the conversion conditions. What Conditions Come with the Conversion Option? The conversion is not just a switch from one scheme to another. DGFT has attached clear conditions. Condition What It Means GST payment Exempted GST availed at import must be paid Domestic sale Refined sugar made from the relevant imported raw sugar must be sold in India Deadline Domestic sale must be completed by 31 October 2026 Additional conditions DGFT may prescribe further conditions Procedure Detailed process will come through a Public Notice Exempted GST Has to Be Paid This is probably the first financial issue an eligible business should check. Where GST exemption was availed at the time of import, conversion is subject to payment of that exempted GST. So, while the TRQ offers a duty advantage, conversion should not be presented as a cost-free choice. A company needs to understand the tax benefit already taken and the payment that may arise if it changes schemes. The notification does not provide a universal GST calculation, so the amount cannot be estimated correctly without looking at the actual transaction. Refined Sugar Must Be Sold Domestically The second major condition relates to what happens after refining. Refined sugar manufactured from the imported raw sugar covered by the conversion must be sold in the domestic market by 31 October 2026. The word “sold” matters. The condition should not be loosely rewritten to mean that the sugar merely has to be used, moved or held in India. More Conditions May Follow DGFT has also said that the conversion will be subject to such other conditions as may be prescribed. That makes the forthcoming Public Notice important. A company should not assume that payment of GST and domestic sale are the only procedural matters it will ever have to deal with. What Is the GST Impact of Conversion? The GST condition could determine whether conversion makes business sense. An importer may look at the TRQ and see the possibility of duty-free treatment. But if the company previously received GST exemption under the Advance Authorisation route, that exemption cannot simply be ignored when it switches schemes. The notification requires payment of the exempted GST availed at import. For management, the right comparison is therefore not: “Advance Authorisation versus a duty-free TRQ.” A more useful comparison is: “What is the full financial result after considering the duty position, GST payment, existing stock, production and domestic-sale plan?” That calculation will be different for different businesses. The notification does not give a fixed GST rate, payment formula or universal cost. Those points should be checked against the actual imports and applicable tax provisions. Why Is 31 October 2026 So Important? Businesses will see 31 October 2026 more than once in the notification. The same date is being used for two different purposes. It is the TRQ cut-off- the 10 lakh MT duty-free TRQ is available up to 31 October 2026. For importers, this makes timing important. Procurement, shipment and whatever procedure DGFT prescribes will need to be considered within a relatively short period. It Is Also the domestic-sale deadline for businesses using the one-time conversion option; relevant refined sugar must be sold in the domestic market by the same date. The two conditions should not be mixed up. One concerns access to the duty-free TRQ the other concerns what must happen to refined sugar in a conversion case. Advance Authorisation and TRQ: What Is Different for an Existing Holder? The notification is not a full comparison of the two schemes. It only deals with the areas connected with this special conversion. Point Existing Advance Authorisation Position Position After Conversion Eligibility for this option Must be an already-issued SION E52 authorisation Can use the one-time conversion option if conditions are met Quantity considered Authorisation may mention an approved quantity Actual quantity imported up to notification date is relevant GST Exemption may have been availed at import Exempted GST must be paid Refined sugar May already have been produced Already-produced and future refined sugar from relevant imports are included Market Original scheme treatment applies Already-produced and future refined sugar from relevant imports are included Sale deadline Not created by this notification for ordinary AA cases Already-produced and future refined sugar from relevant imports are included Procedure Existing AA framework Conversion process to be prescribed by DGFT For an eligible holder, the new option is therefore more of a business decision than an automatic compliance step. Some businesses may find the domestic-market route attractive. Others may find that the GST payment or the short deadline makes conversion less useful. Implementation Timeline Event Date Why It Matters DGFT Notification No. 31/2026-27 issued 20 August 2026 Policy change announced Cut-off for raw sugar actually imported under eligible existing authorisations Up to 20 August 2026 Determines the quantity relevant for conversion 10 lakh MT duty-free TRQ Up to 31 October 2026 Time available under the notified quota Domestic sale of refined sugar in conversion cases Up to 31 October 2026 Express conversion condition DGFT Public Notice Yet to be specified in the notification Will explain administration and conversion procedure The calendar matters here because the period between the notification and the 31 October deadline is not very long. Businesses that may use the notification should therefore do the internal checking now rather than wait until the last stage of the process. What Will DGFT Explain Through the Public Notice? The notification answers the “what”, but not the complete “how.” DGFT has stated that a Public Notice will set out the procedure for: Administration of the TRQ One-time conversion from Advance Authorisation Scheme to TRQ Scheme That leaves several operational questions that businesses will naturally want answered. For instance: How will the TRQ be administered? How will a business seek conversion? What records will have to be submitted? How will quantities be verified? What procedural conditions will apply? These are questions, not confirmed requirements. Until DGFT publishes the procedure, businesses should not treat any assumed form, portal route or document list as final. What Does the Notification Mean for Raw Sugar Importers? For importers, the biggest attraction is straightforward: a large quantity of raw sugar has been placed under a duty-free TRQ for a limited period. That may affect procurement decisions. A business that was already planning imports may now want to check whether its product falls under the correct Exim Code and whether it can participate in the TRQ once the administration process is clear. Timing may be the harder part. The notification was issued on 20 August 2026, and the TRQ runs only up to 31 October 2026. Import planning, contracting, shipment schedules and regulatory procedures therefore have to be looked at together. What Does It Mean for Sugar Refiners? Refiners need to look at more than the import duty. Raw sugar is an input. Its real value depends on whether the refinery can bring it in, process it and sell the finished product in line with its business plan. For a refinery that already holds an eligible SION E52 Advance Authorisation, the new option may also affect existing stock. The company may need to review raw sugar still lying in stock, refined sugar already manufactured and production that is still pending. Where conversion is chosen, the ability to sell the relevant refined sugar in the domestic market by 31 October 2026 becomes part of the decision. What Are the Main Benefits for Businesses? The notification can be useful, but the benefits will not be identical for everyone. Duty-Free Import Opportunity A TRQ of 10 lakh MT is substantial. Businesses that receive access under the final procedure may be able to import qualifying raw sugar without the normal customs-duty burden applicable outside the concession. More Sourcing Flexibility For refiners, another import route can widen raw-material sourcing options during the notified period. That may help businesses that need additional raw sugar and can work within the deadline. A Second Option for Existing SION E52 Holders The one-time conversion provision gives some existing Advance Authorisation holders a choice that they did not have under the earlier position shown in the notification. That flexibility may be useful if the company's commercial plan has changed. Existing Production Is Not Ignored The notification considers refined sugar that has already been produced from the imported raw sugar. That is particularly relevant where imports were made earlier, and the raw material has already moved through part of the production cycle. What Could Make the Scheme Difficult to Use? The benefit looks attractive on paper, but businesses still have practical issues to work through. The GST Payment Can Change the Economics An importer should not decide on conversion based only on the word “duty-free.” If exempted GST has to be paid, the financial advantage may look different after the full tax position is calculated. The Window Is Short 31 October 2026 is close to the notification date. That may put pressure on businesses that still need to study the policy, understand the DGFT procedure, make a conversion decision, manage stock and complete domestic sales. The Detailed Procedure Is Still Important The notification itself does not explain quota allocation or the complete conversion process. That uncertainty makes it difficult to plan the administrative side until the Public Notice is available. Records Need to Tell a Clear Story A conversion assessment may involve several connected figures: Quantity authorised Quantity actually imported Raw sugar still available Refined sugar already produced Remaining production GST exemption availed If those numbers do not match across records, a company may have to spend time reconciling them before it can confidently proceed. Is This the Right Decision or an Additional Burden? For most businesses, the answer will depend on which part of the notification they are looking at. The 10 lakh MT duty-free TRQ is clearly an opportunity. It can make imported raw sugar more commercially attractive for businesses that obtain access to the quota and can complete their transactions within the time available. The one-time conversion option is also useful because it gives certain existing SION E52 Advance Authorisation holders more flexibility. But conversion comes with a price. The exempted GST has to be paid. The relevant refined sugar must be sold domestically by 31 October 2026. The business also has to fit within the eligibility language of the notification and follow whatever procedure DGFT subsequently prescribes. Positive Side Practical Concern 10 lakh MT duty-free TRQ Quota access is not automatic Lower duty exposure for qualifying imports Limited period up to 31 October One-time conversion choice Limited to specified existing authorisations Refined sugar already produced can be covered GST exemption has to be repaid Domestic-market sale becomes possible under conversion Domestic sale must meet the deadline Domestic-market sale becomes possible under conversion Full procedure depends on DGFT Public Notice The policy therefore looks favourable for a business that can genuinely use the TRQ or the conversion route. It becomes less attractive where the GST payment is high, the domestic-sale deadline is difficult to meet, or the business's existing authorisation does not fall squarely within SION E52. The sensible approach is to treat conversion as a case-by-case decision rather than assuming that it is automatically beneficial. Risks Businesses Should Avoid A few misunderstandings could cause problems. 1. Do not assume every raw sugar import is now duty-free. The concession is tied to the TRQ and its conditions. 2. Do not treat 10 lakh MT as an individual entitlement. The notification states the total TRQ. It does not give every importer 10 lakh MT. 3. Do not assume every Advance Authorisation can be converted. The notification specifically names already-issued authorisations under SION E52. 4. Do not use only the authorised quantity. The notification refers to raw sugar actually imported up to the date of the notification. 5. Do not overlook GST. The exempted GST availed at import has to be paid if the conversion route is chosen. 6. Do not ignore the sale deadline. Refined sugar covered by the conversion arrangement must be sold domestically by 31 October 2026. 7. Do not invent the DGFT procedure. The notification says that a separate Public Notice will explain how the TRQ and conversion will be administered. What Should a Business Check Before Choosing Conversion? An eligible Advance Authorisation holder can start with seven basic checks. 1. Is the Authorisation Already Issued? The notification refers to existing authorisations. The status and date of the authorisation should therefore be checked. 2. Is It Under SION E52? This is one of the clearest eligibility points in the notification. 3. How Much Raw Sugar Was Actually Imported? The company should separate the authorised quantity from the quantity actually imported up to 20 August 2026. 4. What Is Still in Stock? The business should know how much of the imported raw sugar remains available. 5. How Much Has Already Been Refined? Production records can help identify the refined sugar already made from the relevant imported raw sugar. 6. What GST Exemption Was Taken? This should be understood before management decides whether the conversion makes financial sense. 7. Can the Domestic-Sale Deadline Be Met? The company needs to judge whether the relevant refined sugar can realistically be sold in the domestic market by 31 October 2026. These checks are practical due diligence. They are not a substitute for the formal procedure DGFT will prescribe. What Should Businesses Do Now? The notification gives businesses enough information to begin their internal assessment even though the detailed procedure is still to follow. A sensible order would be: Confirm that the product falls under Exim Code 170114. Check whether the business wants to participate in the general TRQ or assess the conversion route. For conversion, confirm that the Advance Authorisation was already issued under SION E52. Reconcile the quantity of raw sugar actually imported up to 20 August 2026. Review raw sugar stock and refined sugar production. Assess the exempted-GST payment that conversion may trigger. Check whether the 31 October 2026 domestic-sale deadline is commercially achievable. Review the DGFT Public Notice as soon as the procedure is formally issued. The main point is not to rush into the conversion simply because a duty-free TRQ has been announced. The tax and operational side deserve the same attention as the import benefit. How Can Corpseed Help? The notification brings several parts of an import transaction together. Product classification, Advance Authorisation status, imported quantity, GST exemption, stock records and the DGFT procedure can all affect the final position. Corpseed can support raw sugar importers and refiners with a focused review of these areas. Raw Sugar Import Policy Review Corpseed can help examine the product description, Exim Code 170114 and the scope of Notification No. 31/2026-27 to determine whether the business falls within the relevant import-policy entry. TRQ Applicability Assessment Businesses considering the new quota can get support in understanding the notified 10 lakh MT TRQ, the 31 October 2026 cut-off and the issues that still depend on DGFT's detailed procedure. Advance Authorisation and SION E52 Review For an existing authorisation holder, Corpseed can assist in checking: Whether SION E52 applies Whether the authorisation falls within the notification Quantity actually imported Relevant conversion conditions Refined sugar and inventory position Import and Record Review Import documents, authorisation records and internal stock or production records can be reviewed together so that inconsistencies are identified before a conversion request is prepared. GST Coordination Because conversion is linked to payment of exempted GST, a transaction-specific tax review may be needed. Corpseed can coordinate the compliance side with the appropriate tax professionals where required. DGFT Procedure and Filing Support Once DGFT issues the Public Notice, Corpseed can help businesses understand the actual procedure, prepare the required documentation and support the filing process where applicable. Corpseed's role is to help businesses understand the regulatory position and prepare the required compliance work. Quota allocation, acceptance of conversion, tax treatment and final decisions remain with the competent authorities under the applicable law. Raw sugar importers, refiners and eligible SION E52 Advance Authorisation holders can consider a notification-specific review before committing to the conversion route. Key Takeaways DGFT issued Notification No. 31/2026-27 on 20 August 2026. The notification covers Raw Sugar under Exim Code 170114. A 10 lakh MT duty-free TRQ is available up to 31 October 2026. Existing Advance Authorisations issued under SION E52 receive a one-time conversion option. Conversion is linked to raw sugar actually imported up to the notification date. Exempted GST availed at import has to be paid where conversion is chosen. Refined sugar covered by the conversion must be sold in the domestic market by 31 October 2026. DGFT will separately issue the procedure for administering the TRQ and carrying out the conversion.