Law Updates

Subject

Summary: The Department of Telecommunications (DoT), under the Ministry of Communications, has brought Section 3(7) of the Telecommunications Act, 2023 into force from 21 August 2026. The change has been made through Notification S.O. 4616(E). The Central Government issued the notification using its powers under Section 1(3) of the Telecommunications Act, 2023. The Gazette clearly appoints 21 August 2026 as the date on which Section 3(7) becomes operational. That sounds straightforward, but there is an important distinction. S.O. 4616(E) is mainly a commencement notification. It does not contain a complete telecom KYC process, prescribe a new application form, or create a separate biometric licence. What it does is activate the statutory provision dealing with identification of users through verifiable biometric-based identification. The detailed position has to be understood by reading Section 3(7) together with the applicable User Identification Rules and DoT directions. For telecom operators, the change deserves attention because user identification is now tied directly to the framework of the Telecommunications Act, 2023. Businesses holding corporate telecom connections also need to understand their role, particularly where individual employees or other persons are using connections issued in the name of an organisation. Notification at a Glance Particular Details Issuing Ministry Ministry of Communications Department Department of Telecommunications Notification Number S.O. 4616(E) Notification Date 21 August 2026 Effective Date 21 August 2026 Governing Law Telecommunications Act, 2023 Power Used Section 1(3) Provision Brought into Force Section 3(7) Main Subject User identification through prescribed verifiable biometric-based identification Direct Compliance Procedure in S.O. 4616(E) Not specified Separate Application Form Not specified Separate Government Fee Not specified Separate Registration Not created by this notification Nature of Notification Commencement notification There is no gap between the date of this notification and the commencement date mentioned in it. Section 3(7) became effective on 21 August 2026 itself. What Does Section 3(7) Actually Say? Section 3(7) is fairly short, but its wording matters. Under the provision, an authorised entity providing a telecommunication service notified by the Central Government must identify the person receiving that service through a prescribed form of verifiable biometric-based identification. There are three parts to understand here. First, the provision places the responsibility on an authorised entity providing the relevant telecommunication service. Second, the provision refers to telecommunication services notified by the Central Government. This means the existence of Section 3(7) alone should not be read as proof that every type of telecom service is covered in the same manner. Third, Section 3(7) says that the biometric-based identification will operate as may be prescribed. In legal terms, that means the Act creates the requirement, while more detailed rules are needed to explain how the system operates. Section 56 of the Telecommunications Act also specifically gives the Central Government rule-making power regarding the verifiable biometric-based identification to be used under Section 3(7). That is why the Gazette notification cannot be read on its own. Why Does 21 August 2026 Matter? The Telecommunications Act was enacted earlier, but individual provisions of a law do not always become operational on the same date. Section 1(3) allows the Central Government to appoint commencement dates for provisions of the Act. S.O. 4616(E) uses that power specifically for Section 3(7). In practical terms, the position is: Stage What It Means Telecommunications Act, 2023 enacted Parliament created the legal framework Section 3(7) included in the Act Parliament created the statutory basis for biometric user identification. S.O. 4616(E) issued Government formally commenced Section 3(7) 21 August 2026 Section 3(7) became legally operational User Identification Rules and DoT instructions Detailed implementation has to be understood from these instruments This distinction matters because describing S.O. 4616(E) itself as a fresh "biometric KYC rule" would not be legally precise. The notification activates the section. It does not reproduce the entire operating framework. How Does the Wider User Identification Framework Fit In? DoT's Telecom e-Service Portal now specifically refers to the Telecommunications (User Identification) Rules, 2026 and states that the Rules have been made live on the portal. DoT has also published separate instructions relating to the implementation of the User Identification Rules. The Department's official resources page lists both the User Identification instructions and a consolidated list of earlier identification/KYC notifications. This creates a layered framework. The Telecommunications Act, 2023 provides the statutory basis. Section 3(7) creates the requirement for prescribed verifiable biometric-based identification for notified services. S.O. 4616(E) brings that provision into force. The User Identification Rules, 2026 provide a more detailed regulatory structure. Finally, DoT instructions deal with practical matters such as e-KYC, D-KYC, reverification, and business connections. For a compliance team, the real job is therefore not simply to read the two-page Gazette. The documents have to be read together. Who Is Expected to Follow the User Identification Requirements? The DoT instructions explain the categories of authorised entities to which the Rules may apply. These include entities holding an authorisation under Section 3(1)(a) of the Telecommunications Act, 2023, as well as certain entities continuing under licences granted under the Indian Telegraph Act, 1885 or migrating to the new authorisation framework in accordance with Section 3(6). This distinction is useful because not every company connected with the telecom industry is automatically an "authorised entity" for this purpose. A software vendor working for a telecom operator, for instance, does not become the authorised entity simply because it supports a KYC system. The applicable authorisation or continuing licence position has to be checked. That is the first compliance question telecom businesses should answer: what is the regulatory status of the entity providing the service? What Does Verifiable Biometric-Based Identification Mean for Businesses? The expression is important because Section 3(7) does not simply refer to ordinary document verification. The provision specifically requires a form of identification that is both biometric-based and verifiable, with the detailed method governed through the prescribed framework. DoT's implementation instructions also make clear that the User Identification Rules work with processes such as e-KYC, D-KYC, and user reverification. Businesses should avoid oversimplifying this into a statement such as "all users must now complete Aadhaar KYC." That would go beyond what S.O. 4616(E) itself says. The correct method depends on the applicable Rules, the user's circumstances, and the relevant DoT instructions. For telecom operators, this means existing subscriber-verification systems should be checked against the current framework rather than assuming that an older KYC process continues unchanged. What Happens to Earlier Telecom KYC Instructions? Telecom KYC did not begin in 2026. DoT has issued subscriber-verification instructions for many years. Its current User Identification notification list refers to earlier directions covering matters such as: verification of new prepaid and postpaid mobile subscribers; Digital KYC; Self-KYC; Aadhaar-based e-KYC; reverification of existing mobile connections; additional KYC requirements for business connections; KYC requirements for Internet Telephony Services; and SIM replacement involving end users of business connections. For example, DoT's list records Digital KYC instructions from 2019, Self-KYC and Aadhaar-based e-KYC instructions from 2021, business-connection KYC instructions from 2024, and Internet Telephony KYC requirements from 2025. The 2026 framework therefore does not begin from an empty regulatory position. The better approach for operators is to identify which earlier instructions continue to apply, which have been absorbed into the new framework, and whether any newer direction changes the way an existing process must operate. Simply deleting every old KYC SOP would be as risky as assuming that nothing has changed. What Do the New Rules Mean for Existing Connections? One question businesses are likely to ask is whether every existing telecom user now needs immediate fresh biometric verification. S.O. 4616(E) itself does not say that. The commencement notification only brings Section 3(7) into force. It does not contain an instruction requiring every existing subscriber to report for fresh verification on 21 August 2026. DoT separately maintains instructions dealing with reverification of existing mobile connections. Its current consolidated list refers to reverification directions issued in December 2021 and February 2022. Any fresh verification requirement should therefore be linked to the applicable Rules or a specific DoT direction rather than assumed merely from the commencement notification. For operators, that means existing connections and new connections should not automatically be treated as the same compliance situation. Business Connections Need Special Attention Corporate connections deserve a closer look because there can be more than one person involved. The connection may be taken in the name of a company, LLP, partnership, government body, or another organisation. In contrast, the SIM or telecom connection is actually used by an employee or another individual. This creates three different roles that compliance teams may have to distinguish: The business user is the organisation in whose business context the connection is being used. The authorised representative is the person authorised to act for that organisation. The end user is the person actually using the relevant business connection. This becomes particularly important where connections are regularly reassigned between employees. DoT's implementation instructions specifically deal with changes in the end user of a business connection. What Happens When a Business SIM Is Given to a New End User? This is one of the areas where the DoT instructions provide a clear timeline. According to the instructions published on the Department's portal, the authorised representative of a business user must inform the authorised entity about a change in the end user of a business connection within three working days from the date of the change. The instructions also state that the authorised representative must ensure that the new end user undergoes biometric-based identification within seven working days from the date of the change. Business Connection Event Time Allowed Main Responsibility End user of the connection changes Within 3 working days Inform the authorised entity New person starts using the connection Within 7 working days from the change Ensure biometric-based identification of the new end user This has a very practical consequence for employers. A company that reallocates corporate SIMs between employees cannot treat the change as purely an internal administrative matter. HR, administration, IT and whoever manages the telecom account may need a process for notifying the telecom provider and completing the required identification. A simple employee-exit checklist may therefore need to connect with the company's telecom-connection records. What Should Telecom Operators Review? For telecom operators, the regulatory change is less about creating one new form and more about checking whether the existing user-identification system still matches the law. A sensible review would start with the services being provided and the company's authorisation position. After that, the compliance team can look at the actual customer journey. Subscriber Onboarding Check how a new user is identified before a connection is provided. Existing e-KYC or D-KYC processes should be mapped against the current Rules and portal instructions. Business Accounts Enterprise connections often remain active for long periods while the individual end user changes. These accounts deserve separate controls because the person using the connection can be different from the company that originally obtained it. Reverification Teams should know what event or direction triggers reverification rather than treating it as an automatic requirement for every subscriber. Internal Records Subscriber records, authorised-representative information and end-user changes should remain consistent across customer, billing, KYC and enterprise-account systems. Staff and Channel Instructions A regulatory process can fail even when the written policy is correct if retail staff, enterprise teams or customer-support personnel follow an outdated procedure. That makes training and SOP review a practical part of implementation. What Should Companies Using Corporate Connections Do? The burden on an ordinary corporate user is different from the burden on the telecom operator. A company does not become responsible for operating the telecom provider's KYC system. It does, however, need control over the information it provides to the telecom company. Businesses with a sizeable pool of corporate connections should be able to answer a few basic questions without searching through several departments. Who is the authorised representative for the telecom account? Which employee or person is using each connection? When was a SIM last reassigned? Was the provider informed after the end user changed? Was the new user's required identification completed? These sound like small administrative details, but the three-working-day and seven-working-day requirements make them much more important for business connections. A useful internal arrangement is to connect telecom allocation with employee onboarding, transfers and exits. That reduces the chance of a company-owned connection continuing in the name of an old end user. Operator and Business User Responsibilities Are Not the Same Telecom Operator / Authorised Entity Corporate or Business User Apply the prescribed identification framework Provide accurate business and user information Carry out the required identification process Maintain an appropriate authorised representative Follow applicable DoT instructions Inform the provider of relevant end-user changes Maintain subscriber information required under the framework Keep internal SIM/end-user records current Handle applicable reverification Ensure the new end user participates in required verification Maintain regulatory controls around the process Coordinate telecom records with employee changes This distinction matters because articles on telecom KYC often speak about "business compliance" without explaining whether the obligation belongs to the telecom provider or to its customer. The two may have connected responsibilities, but they are not interchangeable. What About Misrepresentation of User Information? DoT's 2026 implementation instruction also refers to Rule 8 of the User Identification Rules and provides a format through which an authorised entity can inform the Central Government about specified misrepresentation. The format records the telecommunication identifier, the nature of the misrepresentation, and the steps taken by the authorised entity. This shows that user identification is not being treated merely as a one-time onboarding exercise. Accuracy of subscriber information remains relevant after the connection has been issued. For telecom operators, this means suspected identity misuse should be connected with the appropriate internal escalation and regulatory process. For businesses, it reinforces a simpler point: information relating to the actual user of a business connection should remain accurate. What S.O. 4616(E) Does Not Do Because the Gazette is so short, there is a risk of reading much more into it than it actually contains. S.O. 4616(E) does not, by itself: create a new telecom licence; ask operators to file a fresh registration application; provide a new application form; prescribe a government filing fee; list KYC documents; explain an e-KYC procedure; explain a D-KYC procedure; specify a separate compliance portal; create a periodic return; set a new audit frequency; provide a new inspection schedule; or contain its own penalty table. Its legal function is much narrower: it brings Section 3(7) into force from 21 August 2026. Operational details should therefore be taken from the applicable Rules and DoT instructions, not inserted into the commencement notification. Does This Notification Require a Fresh Telecom Licence? No. S.O. 4616(E) does not create a separate licence or registration simply for biometric user identification. Section 3(7) operates within the larger authorisation framework of the Telecommunications Act, 2023. Section 3(1) separately deals with the requirement to obtain Central Government authorisation for specified telecom activities. Existing and new authorisation matters therefore need to be assessed under the relevant authorisation provisions and rules. They should not be mixed with the commencement of Section 3(7). This distinction is particularly relevant for businesses researching compliance online because phrases such as "biometric telecom registration" or "Section 3(7) licence" can easily create the impression that a separate application has been introduced. The attached Gazette does not support that conclusion. Where Could the Real Compliance Difficulty Arise? The biggest challenge is unlikely to be understanding the two-page notification. The harder part is translating the wider framework into day-to-day operations. For a large telecom operator, user identification can touch several teams at once: legal, regulatory affairs, customer onboarding, enterprise sales, KYC operations, IT, fraud control, and customer support. A change that looks minor from a legal perspective may therefore require several systems to communicate correctly. Business accounts present another practical issue. A company may own hundreds or thousands of active connections spread across offices and employees. The telecom provider may have one record, while HR has another and IT asset management has a third. If those records are not aligned, identifying the actual end user can become difficult. The new framework makes that gap worth examining. What Should Telecom Businesses Do Now? Rather than redesigning every process immediately, businesses can start with a focused compliance review. Priority Practical Review 1 Confirm whether the entity falls within the relevant authorised-entity framework 2 Identify which of its telecommunication services are covered by the applicable notification 3 Review current e-KYC, D-KYC and reverification procedures 4 Check the process followed for business connections 5 Review how changes in corporate end users are recorded 6 Check whether the 3-working-day and 7-working-day business-user timelines have been built into internal processes 7 Review existing SOPs and staff instructions 8 Monitor the DoT portal for updated directions and clarifications The purpose of this exercise is not to create paperwork for its own sake. It is to find out whether what the business actually does matches the rules it is now expected to follow. Will the New Framework Increase Compliance Costs? Possibly, but the impact will not be the same for every operator. S.O. 4616(E) itself does not prescribe an implementation fee. The practical cost is more likely to arise from internal changes: updating technology, adjusting onboarding systems, training customer-facing teams, managing corporate-user records, and reviewing existing processes. Large operators may already have much of this infrastructure because DoT had KYC, Digital KYC, Aadhaar-based e-KYC, business-connection and reverification instructions before 2026. For such businesses, the work may be more about aligning existing systems with the new statutory framework. Smaller organisations may find the process heavier if user-identification controls have historically been spread across different systems or teams. No single implementation-cost figure should therefore be treated as applicable to the whole industry. What Are the Possible Benefits? There is a clear policy logic behind stronger identification of telecom users. A connection linked more reliably with its actual user can make subscriber records more dependable. It may also make it harder to maintain connections using false or outdated identities. For business connections, accurate end-user records can help answer a basic question that can otherwise become surprisingly difficult: who was actually using this connection at a particular time? Other possible benefits include: better traceability of telecom connections; more reliable subscriber information; clearer accountability for corporate SIMs; stronger controls when a business connection changes hands; better handling of suspected identity misuse; and greater consistency between user-identification systems and the new Telecommunications Act framework. These should be viewed as expected regulatory benefits, not guarantees that identity fraud will disappear. Is Biometric User Identification a Right Decision or an Additional Burden? It is both a stronger control and an additional operational responsibility. Positive Side Compliance Concern Better assurance about user identity More work in onboarding and account management Improved traceability Technology and system changes may be required Better corporate end-user records Companies need tighter SIM allocation controls More structured response to identity misuse Staff and channel teams need updated training Stronger statutory basis for user identification Operators must align old KYC processes with the new framework From the regulator's side, there is a reasonable case for improving the quality of subscriber identification. Telecom connections can be misused when identity information is false, outdated, or disconnected from the person actually using the service. From the business side, stronger controls do not come without effort. The biggest burden is likely to fall on organisations handling very large numbers of users or corporate connections. Updating a single connection is straightforward. Keeping thousands of employee connections correctly mapped while people join, leave or move roles is a different exercise. The policy therefore looks less like a completely new KYC system and more like an attempt to place a firmer statutory structure around user identification. Its success will depend on how workable the prescribed processes remain for both operators and genuine users. A Small but Important Issue in the DoT Implementation Circular There is also an unusual drafting point business should be aware of. The DoT PDF currently available on the official portal for instructions under the User Identification Rules contains blank placeholders in parts of its header. The displayed document shows an incomplete date and circular number, and the reference to the notified services is also left incomplete in the text. At the same time, the same document contains substantive directions, including the three-working-day and seven-working-day requirements for changes in business-connection end users. This does not justify ignoring the document, but it does mean compliance teams should keep watching the DoT portal for a corrected, replaced, or clarified version. Where a document itself contains a visible drafting gap, businesses should not fill it with assumptions. How Corpseed Can Help Telecom user identification is no longer something that can be checked by looking at one KYC circular. Depending on the business, the answer may involve the Telecommunications Act, the User Identification Rules, earlier DoT instructions, the company's existing licence or authorisation position, business-connection controls and the way end-user changes are handled internally. This is where a telecom compliance consultant can help a business turn the legal framework into a practical review of its existing processes. Corpseed can support relevant telecom operators and businesses with: Section 3(7) applicability assessment:  reviewing whether the provision and related user-identification requirements apply to the entity and service concerned; Telecom regulatory compliance services:  examining the wider DoT framework connected with the business activity; Telecom KYC compliance assessment:  comparing existing e-KYC, D-KYC and reverification processes with applicable requirements; Business-connection compliance review:  checking authorised-representative and end-user management processes; Compliance gap assessment:  identifying differences between written procedures and the actual operating process; SOP and regulatory-document review:  helping teams organise internal user-identification and escalation procedures; Telecom authorisation compliance support:  where separate authorisation requirements under the Telecommunications Act are relevant; and Ongoing regulatory monitoring:  tracking relevant DoT notifications, instructions and clarifications. The purpose of professional support is not to replace the Department of Telecommunications or to guarantee a regulatory outcome. It is to help businesses identify the correct rules, understand what applies to their operations and reduce avoidable gaps between regulatory requirements and day-to-day practice. Businesses that need help reviewing their user-identification, corporate connection or DoT compliance processes can work with a telecom compliance consultant for a focused assessment instead of treating every telecom notification as a separate filing requirement. Key Takeaways Section 3(7) of the Telecommunications Act, 2023 became operational on 21 August 2026 through S.O. 4616(E). The provision requires an authorised entity providing a notified telecommunication service to identify the user through prescribed verifiable biometric-based identification. The Gazette itself does not explain the complete KYC process. Detailed implementation has to be read with the Telecommunications (User Identification) Rules, 2026 and applicable DoT directions. DoT's current implementation instructions expressly refer to e-KYC, D-KYC, and user reverification. For business connections, an end-user change is particularly important. DoT's portal instructions require intimation within three working days and biometric-based identification of the new end user within seven working days from the change. Businesses should therefore focus less on creating unnecessary new filings and more on checking whether existing telecom KYC, corporate connection and user-management processes match the current framework.

Subject

Summary: Petroleum installations with large storage capacities now have a new set of fire and emergency-response requirements to examine. The Petroleum and Natural Gas Regulatory Board (PNGRB) has amended the Petroleum and Natural Gas Regulatory Board (Technical Standards and Specifications including Safety Standards for Petroleum Installations) Regulations, 2020 and inserted a new Part L dealing with Fire & Emergency Response Augmentation, or FERA. The notification is dated 17 August 2026. The Gazette issue carries the date 19 August 2026, and the amendment states that it comes into force from the date of publication in the Official Gazette. FERA focuses on petroleum locations that fall within the specified "Extreme Risk" or Priority Location category. For covered sites, the changes go beyond ordinary fire-safety documentation. The regulations deal with response time, water and foam availability, firefighting equipment, specialised workforce, cluster-level resource sharing, operating responsibility and audits. For operators, the first question is therefore simple: Does our installation fall within the new FERA framework, and if it does, how much of our present emergency setup needs to change? Notification at a Glance Particular Details Issuing authority Petroleum and Natural Gas Regulatory Board (PNGRB) Document Amendment Regulations, 2026 Notification date 17 August 2026 Gazette issue date 19 August 2026 File number F. No. PNGRB/Tech/7-T4SPI/(2)/2023 (E-4292) Governing law Petroleum and Natural Gas Regulatory Board Act, 2006 Regulations amended Technical Standards and Specifications including Safety Standards for Petroleum Installations Regulations, 2020 Main change Addition of Part L – Fire & Emergency Response Augmentation Common name FERA Broad coverage Specified Extreme Risk / Priority Locations Cluster distance mentioned Within a 10 km radius Implementation period 2, 3, or 5 years depending on storage band Response requirement Immediate response, but not later than 30 minutes Fire-control requirement Within 65 minutes from the start of firefighting Other major requirements Infrastructure, equipment, trained workforce, governance, training and audits The amendment makes FERA part of the existing petroleum installation safety framework by inserting Part L into Schedule 1 and adding a corresponding reference under Regulation 6. Where Does FERA Fit in the Existing PNGRB Safety Framework? FERA is not a new licence or registration system. Nor does it replace the fire-protection rules that petroleum installations already follow. The parent framework is the PNGRB Technical Standards and Specifications, including the Safety Standards for Petroleum Installations Regulations, 2020. The Gazette notes that the principal regulations were notified on 11 November 2020 and refers to amendments made in 2023 and 2025. The 2026 amendment adds another technical layer to that framework. Part L specifically says that the requirements relating to FERA are meant to supplement Part E and other relevant provisions concerning fire-water, sprinkler systems, foam systems, emergency response, mutual aid and firefighting workforce. That distinction matters. An operator should not read FERA as permission to ignore an existing fire-protection requirement. The practical exercise is to take the existing fire-safety arrangement and check what additional capacity, workforce or coordination Part L now expects. What Has Actually Changed? The amendment makes a relatively small change to the structure of the regulations, but the new Part L itself is detailed. Regulation 6 now refers to Part L. Schedule 1 then receives the new FERA provisions. From an operator's perspective, the change introduces several new areas that need to be considered together: Area What the 2026 Amendment Adds Applicability Defined categories of Extreme Risk / Priority Locations Response time 30-minute outer limit for starting emergency response Fire control 65-minute target measured from initiation of firefighting Cluster arrangements Host Installation, shared resources and common emergency coordination Isolated sites Separate facilities and additional water/foam capacity in specified circumstances Equipment Fire-water, foam, pumps, HVLR, PPE, SCBA and related systems Manpower Dedicated round-the-clock specialist firefighting crew Training Defined competencies and recurring training Governance Governing Committee for cluster arrangements Outsourcing QCBS-based vendor selection requirement Audit Monthly, annual and other periodic assessments Seen this way, FERA is not one extra fire extinguisher or one additional report. It is an operating model for responding to a serious petroleum emergency. What Does FERA Mean? FERA stands for Fire & Emergency Response Augmentation. The word "augmentation" is important here. PNGRB is asking covered locations to strengthen their existing ability to respond to a major event rather than maintain the minimum equipment already available. The regulation links FERA with locations carrying an "Extreme Risk" classification and with the possibility of a Level-III emergency. A Level-III emergency, as described in the amendment, is an event that may have consequences outside the installation and may affect people, property and the environment both inside and outside the site. That could arise from a serious fire, leakage or spill. FERA therefore concentrates heavily on the early period after an incident begins. The idea is that specialist people, adequate resources and a workable command structure should already be available before the situation becomes larger and harder to control. Why Has PNGRB Introduced FERA? PNGRB spells out the objectives in Part L rather than leaving businesses to guess the policy purpose. The regulations seek to make sure that petroleum installations falling within the Priority Location category have modern firefighting and emergency-handling facilities and that those facilities remain operationally ready. Another objective is to control a major incident while it is still at an early stage. If a fire or spill can be brought under control quickly, the chance of it progressing into a Level-III emergency may be reduced. The framework also gives the specialised firefighting workforce a central role. Equipment by itself is of little value if trained personnel are not available to operate it correctly during the first minutes of an emergency. For clusters of installations, PNGRB has gone a step further. Part L encourages a coordinated arrangement under which nearby facilities can support one another instead of each site planning in isolation. Which Petroleum Installations Come Under FERA? This is the most important part of the amendment for businesses because FERA does not automatically apply to every petroleum installation. Part L identifies certain existing and upcoming locations as Priority Locations falling under the Extreme Risk category. Petroleum Installations Handling Class A and Class B Products The English text covers a petroleum installation where the total storage of Class A and Class B petroleum products is in excess of 150 TKL. Where Class C products are stored together with these products, Class C is also considered in the manner stated in the provision. Operators should therefore work from their actual tank and product records. A rough estimate of storage capacity is not enough for a proper applicability review. Crude Oil Storage and Receipt Terminals The English version also covers: crude oil storage terminals; coastal crude receipt storage terminals; and similar crude-handling terminals of strategic significance, where total storage is in excess of 150 TKL. There is, however, an important difference between the Hindi and English texts for this category. That needs separate attention and is explained below. Clusters of Petroleum Installations FERA can also apply where several installations are situated close to one another. The amendment refers to adjacent or nearby installations situated within a 10 km radius. For the English provision, the cumulative storage must be in excess of 150 TKL of Class A and Class B petroleum products, with Class C considered where co-existing. This means a site cannot always assess FERA by looking only at its own tanks. If several petroleum installations fall within the specified radius, cumulative capacity becomes relevant. There Is a Difference Between the Hindi and English Gazette Text One point in the Gazette deserves particular care. The Hindi and English versions appear to give different thresholds for the crude oil terminal category. Text Threshold Appearing in Gazette Hindi version More than 200 TKL English version In excess of 150 TKL The Hindi text appearing on page 2 refers to total storage above 200 TKL for crude oil storage terminals, coastal crude receipt storage terminals, and similar strategically important crude-handling terminals. The English version on page 8 states in excess of 150 TKL. For a terminal well above 200 TKL, that difference may not affect the practical result. It becomes much more important for a facility between 150 TKL and 200 TKL. The Gazette extract itself does not reconcile the two figures. It would therefore be risky to select one threshold and present it as undisputed silently. A crude oil operator affected by this difference should confirm the position from PNGRB or any subsequent official clarification before taking a final applicability decision. How Much Time Is Available to Implement FERA? PNGRB has not given every covered installation one common deadline. Instead, implementation time reduces as storage capacity increases. Storage Capacity Time Allowed for FERA Implementation 150–200 TKL Within 5 years 200–300 TKL Within 3 years 300 TKL and above Within 2 years The schedule says these periods are counted from publication in the Official Gazette. The practical message is easy to understand: installations in the largest storage band have the least time. For a facility that needs new water storage, pumps, pipelines, a FERA station, additional equipment and specialised personnel, two years can pass quickly once engineering, procurement, construction and commissioning are taken into account. That does not mean every covered site should immediately purchase equipment. The sensible first step is to establish exactly what is missing. The 30-Minute Rule and the 65-Minute Rule Two numbers sit at the centre of the new emergency-response framework: 30 minutes and 65 minutes. They measure different things. Response Must Begin Within 30 Minutes For a fire, leakage, or spill, the emergency response is to start immediately and, in any event, not later than 30 minutes from the occurrence of the incident. This makes mobilisation time a real operating issue. It raises practical questions such as: Where is the firefighting crew stationed? How quickly can the team receive an alarm? Who has authority to mobilise shared equipment? Can a mobile monitor physically reach the affected area? Are communication channels working? Can another installation in the cluster release water or foam quickly enough? These are operational questions rather than new legal wording, but they matter because the response-time requirement cannot be met on paper alone. Fire Should Be Controlled or Extinguished Within 65 Minutes Once firefighting begins, the regulation says the fire should be controlled or extinguished within 65 minutes from the initiation of firefighting. The timing therefore works as follows: Requirement Time Clock Starts From Start emergency response Immediately, not later than 30 minutes Occurrence of fire/leakage/spill. Control or extinguish fire Within 65 minutes Initiation of firefighting Businesses should keep these two trigger points separate when designing procedures, conducting mock drills and reviewing response records. How Does FERA Work in a Petroleum Cluster? The cluster model is one of the more practical parts of the amendment. Instead of requiring every installation located close together to build the same enhanced emergency capability, Part L allows a coordinated structure around a Host Installation. The Host Installation is preferably the installation in the cluster having the largest-diameter tanks. FERA facilities are to be established and maintained there in the manner described by the regulation. The cluster can share: fire-water; foam; firefighting equipment; rescue equipment; and other emergency-response resources. The regulation allows up to 50% of available fire-water and foam to be shared with other installations in the cluster during an emergency. This arrangement can be useful, but it creates another question: who is authorised to release those resources when something goes wrong? That is why the regulations also deal with common emergency control, activation protocols and the Governing Committee. Integrated Emergency Control Centre The FERA arrangement should include an Integrated Emergency Control Centre (IECC). Where possible, the IECC is to be set up at the existing Emergency Control Centre of the Host Installation. The control centre is expected to have the communication and emergency-management arrangements required for the cluster, including matters such as: required documents; communication systems; hotline service; alarm systems; CCTV monitoring; and drones. For a continuous cluster, the amendment also calls for an integrated ERDMP document. The purpose is practical. During an emergency involving more than one company, a fragmented command structure can create delays. A common control point makes mobilisation and communication easier to organise. What if a Common Cluster Arrangement Is Not Possible? Not every petroleum installation is located in a place where common FERA resources can be shared efficiently. The amendment addresses this situation. Where the cluster provisions relating to the Host Installation, resource sharing, or common control are not practically workable because of geographical constraints or other reasons, each isolated location has to develop its own firefighting and emergency-response facilities for dealing with a major incident. For these locations, PNGRB also requires 20% additional water and foam storage capacity and pumping rate over the basic design requirements. This 20% requirement is tied to the isolated-location situation described in the clause. It should not be presented as an automatic extra requirement for every installation covered by FERA. Fire-Water and Foam Are a Major Part of FERA Planning The amendment gives considerable attention to the availability and movement of fire-water and foam. The basic design of the fire-protection system is to follow Part E of the existing regulations and applicable NFPA standards, whichever is higher. Any augmentation of the fire-water and foam system is to be based on risk assessment, taking cumulative storage into account. The assessment also needs to consider whether existing systems create bottlenecks. Depending on the site, technical review may therefore need to cover: water storage; foam storage; pump capacity; pump suction lines; discharge pipelines; delivery pressure; flow rate; network interconnection; and ability to transfer water or foam within the cluster. Where existing networks cannot support adequate sharing, the regulation expects modification. If additional pumping is necessary, augmentation should preferably be carried out at the installation having the highest pumping capacity, with the discharge arrangement extended to support other installations in the cluster. What Happens to Resources After They Are Used? A major emergency can consume a large volume of water, foam and other firefighting resources. Part L therefore does not stop once the fire is under control. It sets out how quickly emergency capacity needs to be restored. Stage Resource Level Required Time Initial replenishment At least 50% of statutory minimum requirement Within 12 hours from initiation of firefighting Full replenishment 100% of statutory minimum requirement Within 24 hours of the all-clear siren These are two separate clocks. From an operating point of view, businesses may need arrangements with suppliers, internal stores or cluster members that make such replenishment possible after a serious event. FERA Infrastructure at the Host Installation The FERA station is meant to be an operational emergency facility rather than a room carrying the FERA name. The regulations refer to equipment and supporting infrastructure including: fire and foam protection systems; fire-water systems; water and foam storage; fire-water pumps; interconnected pipelines; mobile firefighting equipment; emergency communication systems; protective equipment; and emergency-control facilities. The dedicated FERA station should be positioned so that it can house both workforce and equipment and allow an efficient response to installations that it is meant to support. Part L says the station should preferably be near the IECC and at a location from which response time to assisted installations can be optimised. For an existing terminal, this may require more than buying new equipment. The layout itself may need to be examined. What Firefighting Equipment Does FERA Refer To? The regulation mentions several pieces of specialised equipment. These include: fixed and mobile HVLR monitors; trolley-mounted mobile units; suitable hoses; fire proximity suits; SCBA sets; PPE; fire-water pumps; and firefighting and rescue equipment. SCBA means Self-Contained Breathing Apparatus, while PPE refers to Personal Protective Equipment. The equipment needs to support the actual fire-water flow and range required for the installation. For the largest-diameter tank, the regulation requires either one high-capacity variable mobile HVLR foam monitor meeting the maximum requirement or two medium-capacity variable mobile monitors that together address the stated requirement. The important point is that equipment should follow the risk and hydraulic requirement. Purchasing a monitor simply because it is labelled "high capacity" would not by itself demonstrate that the system meets Part L. HVLR Design and Certification PNGRB also gives a specific technical benchmark for HVLR equipment. For HVLR capacity up to 12,500 litres per minute, approximately 3,300 GPM, the design is to comply with IS 15811. For units above 12,500 LPM, the material specification must conform to IS 15811. Until the Bureau of Indian Standards notifies an applicable standard for the remaining specifications, matters such as flow and range are to follow specifications finalised by the Technical Committee for T4S for the Petroleum Installations Regulations, 2020. The HVLR must also be listed or approved by a recognised national or international certification organisation such as: BIS; UL; FM; or an equivalent recognised HVLR certification agency. The wording gives recognised alternatives. Businesses should not read it as requiring approval from all three organisations. FERA Needs a Dedicated 24×7 Firefighting Crew One of the clearest differences between FERA and a simple equipment-based approach is the workforce requirement. A dedicated firefighting crew must support the FERA station on a round-the-clock basis. Each shift is to have four personnel, including one shift officer. A separate officer is also required in the general shift with expertise in overall firefighting operations, safety, and training. That creates a continuing workforce requirement. Operators need to think beyond the number of people presently employed in a general safety department. The FERA positions come with defined qualifications and experience. Qualification and Experience Required for FERA Personnel FERA Position Role Qualification Minimum Firefighting Experience in Hazardous Industry FERA In-charge General Shift In-charge BE/B.Tech in Fire Engineering or Fire & Safety Engineering 7 years FERA Officer Shift In-charge Graduate with Station Officer certification from a recognised institute 5 years FERA Crew Shift Crew Graduate with Sub Officer certification from a recognised institute 2 years These conditions matter whether the workforce is recruited directly or supplied through an outsourced professional firefighting agency. A workforce contract that supplies the right number of personnel but not the required qualifications and experience can therefore create an obvious compliance gap. Training Is Not a One-Time Exercise The regulations expect FERA personnel to be capable of actually using the emergency systems they are responsible for. Their competence should cover areas including: HVLR operation; operation of fire pumps; foam deployment; use of SCBA; emergency coordination; routine equipment checks; preventive maintenance; and participation in mock drills. The FERA crew should receive training once every year from a competent agency or person decided by the Governing Committee. The crew also has a wider training role. It is expected to provide regular hazard and emergency-handling training to officials, security personnel and contractor workforce. This matter because a real emergency will rarely involve only the FERA team. Security staff, operations staff and contractors may all be present when an incident begins. Who Owns and Operates the FERA Facility? The answer changes depending on whether the location is isolated or forms part of a cluster. Single Isolated Installation For a standalone isolated installation, the concerned entity has to establish the FERA facilities. Workforce may be provided by the entity itself or through professional firefighting agencies under authorised contracts. Cluster of Installations Where several installations form a cluster, the concerned entities have to jointly establish the FERA facility. The cost is to be shared in proportion to their respective total tank storage capacity. Workforce may again be provided internally or through professional firefighting agencies. The cluster model therefore requires companies that may otherwise operate independently to agree on shared emergency infrastructure and responsibility. How Does Cost Sharing Work? PNGRB sets out the principle of shared cost but does not prescribe one universal financial formula for every expense. The participating installations must jointly set up the cluster FERA facility on a cost-sharing basis linked to their respective total tank storage capacities. The Governing Committee then has to deal with matters including: capital expenditure; operating expenditure; funding; reimbursement; liability; indemnification; damage to FERA resources; and replenishment after those resources are used in an emergency. The regulation does not provide a fixed rupee cost for implementation. That means each cluster will need to understand its own infrastructure gap and develop commercial arrangements around the requirements actually applicable to the participating sites. Can FERA Firefighting Manpower Be Outsourced? Yes. The amendment expressly allows required workforce to be provided through professional firefighting agencies under authorised contracts in the situations described by Part L. Outsourcing may make sense where an operator does not want to build the entire firefighting workforce internally. But the contract needs to be treated as a safety-critical arrangement rather than an ordinary workforce supply agreement. Qualifications, experience, shift strength, training, emergency mobilisation and actual performance all matter. The amendment makes this even clearer through its vendor-selection rule. QCBS Is Required for Outsourced FERA Vendors Where the workforce arrangement is outsourced, vendor selection should take place through Quality and Cost Based Selection (QCBS). The regulation assigns 70% weightage to technical criteria. That tells businesses something important about PNGRB's approach: price should not dominate selection for a service that directly affects emergency response. The tender and contract terms are also expected to carry stringent penalty provisions where a vendor: fails to comply with applicable statutory rules or regulations; or performs inadequately during a mock drill or actual emergency. The notification does not prescribe the amount of those contractual penalties. It also does not give a standard tender value, turnover requirement, or bid-security amount. Those details should therefore be developed through the actual procurement process rather than added as if they were part of the regulation. What Does the FERA Governing Committee Do? A cluster cannot function well if several installations share resources, but nobody has clear authority over them. Part L addresses this through a Governing Committee made up of members from installations within the cluster. Its responsibilities cover matters such as: where FERA assets will be located; who will own or hold them; who is responsible for maintenance; how FERA will be activated; how mobilisation will be authorised; communication during an incident; command and control; coordination with mutual-aid members; coordination with local and district crisis groups; coordination with external emergency agencies; cost sharing; funding and reimbursement; liability; indemnification; replenishment of used resources; readiness reviews; maintenance; drills; competency assurance; reporting; audits; and additional SOPs considered necessary. The regulations also allow arrangements under which another oil and gas installation may use FERA facilities on a cost-sharing basis. For cluster operators, these governance arrangements should be worked out early. Leaving them until equipment is ready could create uncertainty over ownership, liability and emergency authority. FERA Audit Requirements FERA is not something that can be commissioned once and then forgotten. Audit or Review Frequency / Stage Internal audit by FERA In-charge Monthly FERA system audit by Governing Committee Annually T4S audit Every 3 years ERDMP audit Every 5 years Cluster FERA audit and mock drill As part of applicable cluster-wide assessment PNGRB-empanelled TPIA audit At pre-commissioning for cluster-based FERA facility The FERA In-charge must conduct the monthly internal audit and send the report to the Governing Committee for review and necessary action. The Governing Committee must carry out the annual FERA system audit to check compliance with applicable statutory and regulatory requirements. T4S and ERDMP audits remain on their respective three-year and five-year cycles. Where the installation being audited forms part of a cluster housing FERA facilities, the FERA audit and mock drill become part of the cluster-wide assessment. A cluster-based FERA facility must also undergo an audit by a PNGRB-empanelled Third Party Inspection Agency at the pre-commissioning stage. Which IS and NFPA Standards Are Referred to? The notification identifies a number of Indian and NFPA standards. Standard Subject IS 15105 Design and installation of fixed automatic sprinkler fire-extinguishing systems IS 15811 Long-range water-cum-foam monitor for firefighting NFPA 11 Low-, medium- and high-expansion foam NFPA 13 Installation of sprinkler systems NFPA 14 Standpipe and hose systems NFPA 15 Water spray fixed systems NFPA 20 Stationary pumps for fire protection NFPA 22 Water tanks for private fire protection NFPA 24 Private fire-service mains and their appurtenances These references matter mainly to the engineering and fire-safety teams responsible for translating the regulation into an actual installation design. A regulatory review may establish that FERA applies, but detailed system design should still involve professionals competent in the relevant engineering standards. What Does FERA Mean for Existing Petroleum Installations? Existing sites are likely to face the most detailed gap-assessment exercise. A practical review may need to answer questions such as: Is existing fire-water storage sufficient? Is foam inventory adequate? Can present pumps achieve the required flow and pressure? Can water and foam be shared across the cluster? Are pipelines properly interconnected? Is suitable HVLR equipment already available? Does the current ECC arrangement support the proposed IECC? Does the available firefighting team meet the new qualification criteria? Are emergency drills and audits already aligned with the new structure? Not every facility will need the same level of modification. An installation that already has strong firefighting infrastructure may need fewer physical upgrades than a site whose present arrangements were designed for a lower level of emergency support. The only reliable way to know is to compare current systems with the provisions that actually apply. What Does It Mean for New Petroleum Projects? Upcoming installations have a different advantage: they can consider FERA during project design. Where Part L applies, the project team may need to include FERA requirements while deciding: fire-water storage; pumping systems; foam capacity; network layout; monitor placement; emergency-control infrastructure; location of the FERA station; cluster connections; workforce planning; and commissioning activities. This can reduce the risk of designing a project first and then discovering that large modifications are needed before FERA readiness can be demonstrated. For cluster-based FERA facilities, the pre-commissioning TPIA requirement should also be built into the project schedule. What Will FERA Cost? There is no single answer because PNGRB has not fixed a standard implementation cost. The amount will depend heavily on what already exists at the installation. Capital Costs May Arise From additional water or foam storage; pumping upgrades; pipelines and interconnections; FERA station construction; HVLR monitors; hoses; PPE and SCBA; emergency communication equipment; CCTV and alarm systems; IECC modifications; and other supporting infrastructure. Recurring Costs May Include specialist firefighting workforce; outsourced agency charges; equipment maintenance; annual training; mock drills; audits; replacement or replenishment of foam and other resources; and administration of cluster arrangements. A site with a mature fire-safety setup may already have many of these elements. Another installation could face substantial augmentation. For that reason, a compliance gap assessment is generally more useful at the beginning than trying to estimate the project cost from storage capacity alone. Is FERA Good for Safety or Just Another Compliance Cost? It would be too simple to describe FERA as either purely beneficial or purely burdensome. There is a clear safety case behind the requirements. Large petroleum storage sites can face incidents where the first hour matters enormously. More water, more equipment or more people are useful only if they can be mobilised quickly and operate together. FERA directly addresses that problem through response times, specialist crews, common command arrangements and resource-sharing rules. At the same time, the business cost can be real. Area Safety Benefit Business Impact Faster response Earlier control of a serious incident More readiness planning Larger emergency resources Greater firefighting capacity Capital expenditure Qualified crew Better specialist response Recruitment or outsourcing cost Shared cluster resources Access to a larger combined pool Recruitment or outsourcing cost Regular audits Readiness is checked repeatedly Continuing compliance workload Training Better practical capability Recurring training time and cost Common control Clearer mobilisation structure Governance and documentation effort The burden is unlikely to be equal for every installation. An operator with relatively modern systems may be able to build on what it already has. An older terminal requiring new pumps, storage, pipelines, control facilities and specialist workforce could face a much larger implementation project. What Business Opportunities Could Come From the FERA Rules? The amendment may also increase demand for specialised services and equipment connected with petroleum fire safety. Areas likely to see more activity include: professional firefighting agencies; fire engineering; fire-water system design; foam systems; pump and pipeline upgrades; HVLR equipment; SCBA and PPE; emergency communication systems; fire-safety training; TPIA and audit-related services; ERDMP support; technical documentation; and petroleum regulatory compliance services. This does not mean PNGRB has endorsed any supplier, consultant or technology provider. The commercial opportunity arises because covered installations may need people, systems and technical support to meet the new requirements. Practical FERA Compliance Roadmap A covered operator can make the work more manageable by dealing with it in a sensible order. 1. Establish Whether FERA Applies Start with installation type, petroleum class, and actual storage capacity. For nearby installations, examine whether the 10 km cluster condition and cumulative capacity bring the group within scope. For affected crude oil terminals, deal with the Hindi-English threshold difference before reaching a final view. 2. Identify the Correct Timeline Once applicability is established, place the site in the relevant storage band: 150–200 TKL, 200–300 TKL, or 300 TKL and above. 3. Decide the Operating Model Establish whether the site will: operate independently; be part of a cluster; or serve as the Host Installation. 4. Carry Out a Technical Gap Review Compare present fire and emergency facilities with Part L. The review should cover water, foam, pumps, pipelines, monitors, protective equipment, control facilities, communications, and workforce. 5. Prepare the Engineering Plan Once the gap is known, decide which systems require augmentation, replacement, or interconnection. 6. Review Manpower Check the number of people required per shift and confirm that qualification and hazardous-industry experience criteria can be met. 7. Set Up Cluster Governance Where several installations participate, agree on ownership, cost sharing, maintenance, activation, mobilisation, reimbursement and liability. 8. Review Procurement If a professional firefighting agency will be used, make sure the selection process reflects the QCBS requirement and 70% technical weightage. 9. Plan Training and Mock Drills Create a practical programme that keeps the FERA crew and other site personnel prepared. 10. Build an Audit Calendar Monthly, annual, T4S, ERDMP and pre-commissioning requirements should be mapped in one compliance calendar. FERA Compliance Checklist for Operators Area to Review What Needs Attention Applicability Installation category and storage capacity Petroleum class Class A, B and Class C where relevant Cluster position Nearby facilities within 10 km Cumulative storage Combined cluster capacity where applicable Deadline Applicable 2-, 3- or 5-year period Host Installation Identification for cluster arrangement Fire-water Storage, supply, flow and sharing Foam Type, capacity and availability Pumps Capacity and delivery capability Pipelines Interconnection and distribution HVLR Capacity, specification and approval/listing PPE / SCBA Availability for firefighting crew FERA station Location, equipment and workforce IECC Control, alarms, communication and monitoring Manpower Four-person shift structure plus required officer Qualification Role-specific education and experience Training Annual and continuing competency Governing Committee Constitution and responsibilities Cost sharing Constitution and responsibilities Outsourcing QCBS and technical evaluation Internal audit Monthly Governing Committee audit Annual T4S audit Every 3 years ERDMP audit Every 5 years Pre-commissioning audit Cluster-based facility where applicable The checklist is useful for organising a review, but the actual obligation should always be read from the applicable regulation and site conditions. Practical Risks Operators Should Avoid The first risk is assuming that FERA does not apply because an individual installation appears to be below the threshold. A nearby cluster may change the position. Another risk is using the crude oil terminal threshold without checking the difference between the Hindi and English texts. Infrastructure planning also deserves early attention. Pumps, pipelines, and additional storage are not normally changes that can be completed at the last moment. Workforce is another area where operators may underestimate the work. FERA specifies qualifications and hazardous-industry firefighting experience, so simply increasing headcount may not solve the requirement. For clusters, governance can become a bottleneck. Companies need to settle who owns the assets, who maintains them, who pays what share, and who has authority to act during an emergency. Finally, audit planning should begin when FERA is being set up, not after commissioning. Records, drills, training and internal checks form part of the operating arrangement. What Should Petroleum Installation Operators Do Now? For most businesses, the best first move is not immediate procurement. It is clarity. Operators should first confirm whether the site falls under Part L and which implementation period applies. After that: Verify storage capacity and petroleum classes from technical records. Check whether nearby installations create a qualifying cluster. Identify whether a Host Installation arrangement is possible. Review current fire-water, foam, and pumping capacity. Check existing HVLR, SCBA, PPE and emergency-control facilities. Compare present workforce with the new qualification criteria. Estimate which requirements involve capital expenditure. Begin discussions with cluster partners where joint facilities are required. Review outsourcing strategy if specialist workforce will come from an external agency. Put training, mock drills and audits into the implementation plan from the start. The aim should be to understand the gap before money is committed. How Corpseed Can Help With PNGRB FERA Compliance FERA is unusual because the compliance question is not confined to one filing or one approval. It connects legal interpretation, petroleum storage data, technical systems, emergency planning, workforce, contracts, documentation, and audit readiness. That is where structured petroleum regulatory compliance services can be useful. Corpseed can support petroleum businesses in the following areas: FERA Applicability Assessment Corpseed can review the installation profile, storage capacity, petroleum classes, and cluster configuration to help businesses understand whether Part L may apply. This is particularly relevant where cumulative storage or the crude oil threshold issue makes the position less straightforward. PNGRB Compliance Interpretation The 2026 amendment contains several technical conditions that need to be read together. Corpseed can assist management and compliance teams in understanding the relevant FERA provisions, implementation periods, and regulatory responsibilities without turning the requirement into a generic checklist. Compliance Gap Assessment Existing installations may already have strong firefighting systems. A compliance gap assessment can help identify which FERA requirements are already addressed and which areas still need technical, operational or documentary attention. Fire-Safety and Technical Documentation Review Corpseed can assist in organising and reviewing regulatory and technical documentation connected with emergency-response arrangements. Where specialist engineering judgement is required, the work can be coordinated with the appropriate technical professionals. Infrastructure Compliance Coordination FERA may involve water and foam systems, pumps, pipelines, HVLR equipment, IECC arrangements and related emergency infrastructure. Corpseed can support the regulatory coordination side of these requirements and help businesses maintain a clear link between technical work and the applicable PNGRB provisions. Workforce and Training Compliance Review The regulations prescribe role-specific qualifications, experience, and staffing expectations. Corpseed can help businesses review workforce documents, training arrangements and contractor records against the applicable provisions. Cluster Governance Support Cluster-based FERA creates several non-engineering issues that can be just as important as equipment. Corpseed can assist with documentation relating to: Host Installation arrangements; Governing Committee responsibilities; cost-sharing structures; activation protocols; maintenance responsibility; role allocation; audit documentation; and record control. Outsourcing and Vendor Compliance Review Where the professional firefighting workforce is outsourced, Corpseed can assist businesses in reviewing regulatory requirements around QCBS selection, technical evaluation and contract documentation. Audit Readiness Support The FERA framework includes several audit cycles. Corpseed can help organise records, internal compliance calendars and supporting documentation for monthly internal reviews, annual audits, T4S and ERDMP assessments and applicable pre-commissioning requirements. Ongoing Petroleum Installation Compliance Support Petroleum installations often deal with more than one PNGRB requirement at a time. Through PNGRB compliance consulting and petroleum installation compliance support, businesses can maintain a structured view of applicable requirements, pending actions, and supporting documentation instead of treating every compliance event separately. Corpseed does not issue PNGRB approvals, replace competent engineering professionals, or guarantee the outcome of any audit or regulatory review. The role of professional support is to help an operator understand the applicable requirements, identify gaps and organise the work needed to address them. For petroleum operators assessing the 2026 FERA amendment, early petroleum regulatory compliance services can be useful in deciding what applies before technical procurement or infrastructure spending begins. Key Takeaways The 2026 PNGRB amendment introduces a much more defined emergency-response arrangement for specified high-risk petroleum installations. The points businesses should remember are: Part L introduces Fire & Emergency Response Augmentation (FERA). The framework covers specified existing and upcoming Priority Locations. Applicability depends on installation type, petroleum class, storage and cluster conditions. Clusters can be assessed using cumulative storage within the stated 10 km radius. Implementation periods are 5 years, 3 years, or 2 years depending on storage capacity. Emergency response must begin immediately and no later than 30 minutes. Fire should be controlled or extinguished within 65 minutes from initiation of firefighting. Specialised firefighting workforce, infrastructure, equipment, training and audits form part of the framework. Cluster arrangements bring additional responsibility around shared assets, cost, mobilisation and governance. The difference between the Hindi and English crude oil threshold deserves regulatory clarification where it affects applicability. For covered operators, the main task now is to establish applicability and understand the gap between existing facilities and Part L. Once that position is clear, infrastructure, workforce, procurement and audit planning become much easier to organise.

Subject

Summary: Indian businesses dealing in wheat exports have a very different policy position as of 24 August 2026. The Directorate General of Foreign Trade ( DGFT ), through Notification No. 35/2026-27, has changed the export policy of two specified wheat tariff lines from “Prohibited” to “Free.” The change covers ITC HS 10011900 – Durum Wheat: Other and ITC HS 10019910 – Wheat. DGFT has also made the change effective immediately. For exporters, this is more than a change in terminology. Businesses dealing in the covered goods no longer start from an export-policy position that prohibits an ordinary commercial shipment. They can now consider overseas orders under a free export policy status. There is, however, one point that deserves care. “Free” under DGFT policy does not mean that an exporter can forget about classification, IEC, shipping documents, customs procedures, buyer specifications, or requirements imposed by another country. The policy barrier has been removed for the two listed codes; the normal work involved in carrying out a lawful export transaction remains. Notification at a Glance Particular Verified Position Issuing authority Directorate General of Foreign Trade Ministry Ministry of Commerce & Industry Department Department of Commerce Notification number 35/2026-27 Date 24 August 2026 Subject Amendment in the Export Policy of Wheat Governing legislation referred to Foreign Trade (Development & Regulation) Act, 1992 FTP provisions referred to Paragraphs 1.02 and 2.01 of Foreign Trade Policy 2023 Relevant export schedule Schedule 2 of ITC (HS) Export Policy First ITC HS code 10011900 Product description Durum Wheat: Other Second ITC HS code 10019910 Product description Wheat Previous export policy Prohibited Revised export policy Free Effective date With immediate effect Separate transition period Not expressly specified New quota under this notification Not specified New minimum export price Not specified New export licence introduced No such requirement is stated New fee introduced Not specified Main businesses affected Exporters dealing in the covered wheat categories The notification is only one page long, but there is little ambiguity about its central effect. The two tariff lines shown in its table move from Prohibited to Free, and the change takes effect immediately. What Has Changed in the DGFT Wheat Export Policy? The amendment is quite direct. Before the latest notification, the two specified wheat tariff lines carried a prohibited export-policy status. DGFT has now substituted that position with Free. The change is: ITC HS 10011900 - Durum Wheat: Other Earlier: Prohibited Now: Free ITC HS 10019910 - Wheat Earlier: Prohibited Now: Free No future implementation date has been given. There is no separate waiting period in the notification. There is also no new quota or special export window mentioned in Notification No. 35/2026-27. That last point matters because earlier wheat export relaxations did not necessarily remove the underlying prohibition. Businesses could be allowed to export a specified quantity or export under particular conditions while wheat continued to carry a prohibited policy status. The August 2026 notification goes further for the two identified tariff lines. It changes the policy classification itself. Old vs New Wheat Export Policy ITC HS Code Product Earlier Position Position from Notification No. 35/2026-27 What It Means for an Exporter 10011900 Durum Wheat: Other Prohibited Free The earlier DGFT prohibition attached to this tariff line is removed 10019910 Wheat Prohibited Free Commercial export can now be considered under a free export policy status The important words here are “under a free export policy status.” That does not mean an exporter can load wheat onto a vessel without any further checks. It means the DGFT export classification itself is no longer stopping the covered goods from being exported. This distinction keeps the legal interpretation clear. How did India's wheat export policy reach this point? The latest change makes more sense when looked at against what happened before it. India had moved wheat from a Free export policy to a prohibited one in May 2022. DGFT's trade notice no. 09/2022-2023 records that notification no. 06/2015-2020, dated 13 May 2022, amended the wheat export policy from Free to prohibited with immediate effect. That did not mean that wheat could never leave India under any circumstances. Specific arrangements and exceptions existed. For instance, government-approved exports could take place in certain circumstances to meet the food-security requirements of other countries. DGFT also issued procedures dealing with such exports. The policy began opening further in 2026. April 2026: Additional 25 LMT Permitted, but Policy Still Prohibited On 27 April 2026, DGFT issued Notification No. 13/2026-27. That notification permitted the export of an additional 25 Lakh Metric Tonnes (LMT) of wheat, with detailed modalities to be notified separately. Importantly, however, it expressly said that the export policy for ITC HS 10011900 and 10019910 continued to remain “Prohibited.” Government-approved exports for food-security needs also continued over and above that additional permitted amount. This created a position where exports could take place within a permitted framework, but the underlying policy classification had not yet become Free. August 2026: The Policy Classification Itself Changes Notification No. 35/2026-27 changes that position. Rather than permitting another quantity while leaving the basic classification as Prohibited, DGFT has moved the two specified tariff lines to Free. For exporters, that is a much cleaner policy position. The commercial question is no longer centred on whether a shipment fits within a particular wheat export relaxation or quota mentioned in the April notification. For the two tariff lines now listed as Free, the prohibition itself has been removed. The Regulatory Framework Behind the Change DGFT has not issued this notification in isolation. It sits within the legal structure created by the Foreign Trade (Development & Regulation) Act, 1992, the Foreign Trade Policy 2023, and the ITC (HS) export classification. Understanding that structure is useful because it explains exactly what a word such as “Free” does, and does not, mean. Foreign Trade (Development & Regulation) Act, 1992 Notification No. 35/2026-27 refers to Section 5 read with Section 3 of the Foreign Trade (Development & Regulation) Act, 1992. Section 3 gives the Central Government powers relating to the development and regulation of foreign trade, including the power to prohibit, restrict or otherwise regulate imports or exports. Section 5 deals with the Foreign Trade Policy and allows the Central Government to formulate and amend that policy by notification in the Official Gazette. In practical terms, this is part of the legal foundation that allows the Government to move a product between policy categories such as Free, Restricted or Prohibited. Foreign Trade Policy 2023 The notification also refers to paragraphs 1.02 and 2.01 of the Foreign Trade Policy 2023. FTP 2023 provides the wider policy framework within which India's imports and exports operate. Goods are not regulated simply by their common names. They are linked to tariff classifications, and the ITC (HS) schedules tell businesses what policy applies to those classifications. Schedule 2 of ITC (HS) Schedule 2 is concerned with export policy. DGFT's official guidance on reading the Export Policy explains that an item shown as Free can be exported without a licence from DGFT. However, procedural conditions may still be notified, and other laws can continue to apply. That is perhaps the simplest way to understand the August wheat notification. The two identified wheat tariff lines no longer require an export licence merely because their DGFT export-policy category is Prohibited or Restricted. But other requirements that apply independently to the exporter, product, customs transaction, or destination market do not disappear merely because the export-policy column says Free. Which Wheat Categories Are Actually Covered? This is an area where businesses should avoid broad assumptions. The notification names two exact ITC HS codes. ITC HS 10011900 - Durum Wheat: Other The first code is 10011900. The notification describes the product as Durum Wheat: Other and changes its export policy from Prohibited to Free. Durum wheat is a particular class of wheat, but exporters should not classify a product based only on a casual commercial description. Tariff classification needs to match the actual product. ITC HS 10019910 - Wheat The second code is 10019910, described in the notification as Wheat. This entry has also moved from prohibited to Free. Why the Exact Code Matters The notification does not say that every wheat-related item, wheat preparation, or processed product has automatically become Free. Wheat flour, processed wheat foods, wheat-based preparations, seeds, and other products may sit under different tariff entries. For that reason, the question is not simply: “Does this product contain wheat?” The better question is: “What is the correct ITC HS classification of the product being exported?” Businesses unsure of that answer may need ITC HS code classification support before they sign an export contract or represent a product to an overseas buyer. What Does “Free” mean under the DGFT export policy? The word sounds simple, but its regulatory meaning needs to be understood correctly. DGFT's own guidance for Schedule 2 describes Free goods as goods that may be exported without a licence from DGFT. The same guidance also makes two qualifications: DGFT can notify procedural conditions, and free exportability remains subject to other laws in force. So, in the case of wheat: What Has Become Free? The DGFT export-policy status of: ITC HS 10011900, and ITC HS 10019910. What Has Gone Away? The prohibited status that previously applied to those two tariff lines. What Has Not Automatically Gone Away? Normal legal and transaction-level requirements that come from elsewhere. For example, Foreign Trade Policy 2023 separately provides for the Importer-Exporter Code (IEC). It states that no export or import of goods is to be made without an IEC unless the person falls within a specific exemption. The FTP also sets out basic documents for export of goods, including the transport document, commercial invoice-cum-packing list, and Shipping Bill/Bill of Export or Postal Bill of Export. These requirements are not introduced by Notification No. 35/2026-27. They arise from the wider export framework. That distinction is useful for businesses because it prevents two opposite mistakes. The first mistake would be to continue treating the covered wheat as prohibited even after the notification. The second would be to assume that “Free” means nothing else needs to be checked. Neither interpretation is correct. Does the Notification Create a New Wheat Export Licence? No new wheat export licence is created in the attached notification. In fact, the change runs in the opposite direction: the relevant tariff lines have moved from prohibited to Free. DGFT describes the Free category as allowing export without a DGFT licence for that export-policy category, while still recognising that other laws and notified procedural conditions may apply. This is useful from a lead-generation and compliance perspective because businesses should not be encouraged to purchase an unnecessary “wheat export licence” service simply because the policy changed. Where professional assistance may genuinely be required is in areas such as: confirming ITC HS classification, reviewing the current DGFT policy, obtaining or maintaining an IEC where applicable, checking basic export documentation, understanding later DGFT notifications, reviewing other product- or destination-specific requirements. That is where DGFT export compliance consulting has a legitimate role. When Does the Revised Policy Become Effective? The notification is dated 24 August 2026 and states that the export policy of the specified products will be Free with immediate effect. There is no separate future commencement date. The notification also does not give a transition period or phased schedule. One drafting detail should be handled carefully in any published article. The scanned notification says “To be published in the Gazette of India Extraordinary.” The copy itself does not separately state a Gazette publication date. It is therefore safer to describe 24 August 2026 as the notification date and separately say that DGFT has stated that the change takes effect immediately. Who Will Feel the Change Most Directly? The policy affects more than one business function, although not every stakeholder is affected in the same way. Existing Wheat Exporters Businesses that already understand international wheat trade are likely to see the most immediate practical benefit. Instead of first dealing with a prohibited export-policy classification, they can examine overseas enquiries on normal commercial terms, subject to the other requirements applicable to the shipment. Existing exporters may revisit: older buyer enquiries, markets previously placed on hold, supply arrangements, vessel and freight availability, pricing decisions, and longer-term buyer relationships. Merchant Exporters Merchant exporters do not necessarily grow or manufacture the goods themselves. FTP 2023 defines a merchant exporter as a person engaged in trading activity who exports or intends to export goods. For this group, the policy change can be commercially useful. A merchant exporter can assess an overseas buyer's requirement, find domestic supply, and then determine whether the price, quality, and logistics make the deal workable. The ability to do that is easier when the tariff line itself is not prohibited. Agricultural Traders and Suppliers For traders supplying wheat to exporters, the effect is likely to be indirect rather than regulatory. Notification No. 35/2026-27 does not impose a new compliance obligation on an ordinary domestic supplier merely because an exporter may buy from that supplier. What can change is demand. If exporters receive more overseas enquiries, suppliers that can offer suitable quantity, quality and commercial terms may receive more export-linked orders. Whether that actually happens will depend on the market. Procurement Teams A procurement team may need to pay closer attention to specifications. An overseas buyer could require a particular variety, quality, quantity, or delivery schedule. Purchasing wheat that does not fit the buyer's requirements can create a problem even if the export itself is Free under DGFT policy. Procurement decisions therefore need to be made alongside the export contract rather than in isolation. Compliance, Legal and Documentation Teams For compliance teams, the work becomes less about dealing with a prohibition and more about making sure the transaction is correctly put together. That includes: classification, IEC status, export documentation, buyer requirements, contractual descriptions, applicable destination-country rules, and later regulatory changes. This is exactly the type of work where an export compliance consultant can add value without pretending that the consultant controls customs clearance or government decisions. What Changes for Wheat Exporters After 24 August 2026? The first difference is obvious: commercial possibilities become wider. A buyer enquiry that previously could not be handled as an ordinary Free export can now be looked at again if the product falls under one of the two liberalised tariff lines. That does not automatically mean the exporter should accept the order. The policy answers only one part of the commercial decision. A serious exporter will still ask: Can the required quantity be sourced? Is the quality acceptable? Does the overseas price cover procurement and freight? Is the buyer credible? What are the payment terms? Can the shipment reach the destination within the agreed period? The August notification gives businesses the regulatory space to ask those questions. It does not answer them. That is why the commercial impact may differ sharply from one exporter to another. A large exporter with established international buyers may be able to move quickly. A first-time wheat exporter may need much more groundwork before taking an order. What Exporters Should Check Before Shipping Wheat The notification itself does not create a new step-by-step application process, so businesses should not be given a made-up one. What it does create is a reason to review existing export readiness. 1. Start With the ITC HS Code Before looking at the attractive part of the policy, free export status, check the classification. The product must genuinely fall under the tariff line being relied upon. A business should not select ITC HS 10019910 merely because the word “wheat” appears in its commercial description. The nature, form, and classification of the actual goods matter. 2. Check the Current DGFT Position Before the Contract Becomes Firm Export policies can change. The August notification tells businesses what DGFT changed on 24 August 2026. A shipment planned for a later date should still be checked against the policy in force when the transaction proceeds. This is particularly relevant for contracts involving future delivery. 3. Review IEC Status FTP 2023 states that an Importer-Exporter Code is required for the export or import of goods unless a specific exemption applies. It also provides for electronic application and IEC-related compliance. A company that has never exported before should therefore not confuse “wheat is Free for export” with “the business needs no exporter setup.” Where required, IEC registration services can help a new exporter organise this part of the process. 4. Prepare the Basic Export Documents Foreign Trade Policy 2023 identifies basic documents for the export of goods from India, including: Bill of Lading, Airway Bill, Lorry Receipt, Railway Receipt or Postal Receipt, depending on the mode of transport, Commercial Invoice-cum-Packing List, and Shipping Bill, Bill of Export or Postal Bill of Export, as applicable. Additional documents can be required where a product or transaction is subject to another law or regulatory condition. This basic export-document requirement comes from the wider FTP. It is not a new obligation created by the wheat notification. 5. Make Sure the Descriptions Match The goods described in the contract, invoice, packing documents, and customs declaration should tell the same story. If a business describes the product differently across records, questions can arise about what was actually sold and what tariff classification has been used. Clear documentation is especially useful where classification determines whether a liberalised policy applies. 6. Review the Importing Country's Requirements India's decision that the goods are Free for export does not bind the importing country. An overseas government may have its own requirements involving food safety, plant health, quality, import permission, inspection, labelling, treatment or other controls. The exact requirements depend on the country and product. They should therefore be checked for the actual destination rather than copied from a generic wheat export checklist. 7. Check the Commercial Contract Properly Export problems are not always regulatory problems. Price terms, freight, insurance, payment, quality tolerance, delivery period, and rejection clauses can have a major financial effect. A business may be legally allowed to export and still enter into a poor contract. For that reason, the regulatory review and the commercial review should happen together. Documents Exporters May Need to Review The table below separates documents expressly recognised under the wider FTP framework from records that may depend on the transaction. Document / Record General Position Why It Matters IEC details Generally required for export of goods unless exempt Identifies the exporter under the DGFT framework Shipping Bill / Bill of Export Basic export document Used for customs/export declaration Commercial Invoice-cum-Packing List Basic export document Records goods, value and packing information Bill of Lading / Airway Bill / relevant transport receipt Basic export document depending on transport mode Evidence of movement/shipment Export contract or purchase order Commercial document Records buyer, quantity, specifications and terms Product classification working Recommended internal control Helps support the ITC HS code selected Notification No. 35/2026-27 Recommended reference record Helps document the policy position being relied upon Buyer specification Transaction-specific Helps procurement and shipment match buyer requirements Destination-country documents Depends on destination/product May be required under importing-country rules Product-specific certificates Only where independently applicable Should not be assumed merely because the goods are wheat This distinction matters. A generic consultancy article should not tell every exporter to obtain every certificate used somewhere in the global wheat trade. The right document list depends on the actual shipment. Business Impact of the Wheat Export Policy Change The effect of the policy can be looked at in three layers: regulatory, operational, and commercial. Regulatory Impact The direct legal-policy effect is the simplest. The covered tariff lines no longer carry a prohibited export-policy status. That removes the central DGFT policy barrier that existed against ordinary exports of those goods. Operational Impact Businesses can now prepare for wheat export transactions in a more normal way. Export, procurement, logistics, finance and compliance teams may need to work together earlier because a commercial order can move from enquiry to shipment planning more quickly when a policy prohibition is not blocking the transaction. Commercial Impact The change gives exporters another market option. A seller is no longer confined to domestic commercial opportunities merely because these tariff lines are prohibited for export. That can strengthen commercial flexibility, but it should not be confused with guaranteed profitability. International wheat prices, domestic procurement costs, currency movement, freight, and buyer demand will still decide whether a particular shipment makes sense. Likely Impact on Different Stakeholders These are likely business effects, not promises about what the market will do. Stakeholder Immediate Impact Commercial Effect Main Point to Watch Existing wheat exporters Prohibited policy removed for covered codes More freedom to consider overseas orders Current DGFT position and classification Merchant exporters Can evaluate sourcing against foreign demand More trading possibilities Supplier reliability and contract terms Domestic wheat traders Possible increase in exporter enquiries Additional sales channels may emerge Market pricing Procurement teams More export-oriented sourcing may be needed Greater focus on buyer specifications Quality and availability Logistics providers More shipment enquiries may arise Possible additional transport/warehouse work Port and freight planning Compliance teams Less focus on prohibition Possible additional transport/warehouse work Classification and other laws First-time exporters Wheat becomes commercially more accessible New export opportunity IEC, documentation and destination requirements The Government notification does not tell businesses how many tonnes will actually be exported, what buyers will pay, or how domestic wheat prices will move. Benefits of Making the Covered Wheat Categories Free For an exporter, the strongest benefit is flexibility. Overseas Orders Can Be Considered on Their Commercial Merit Under a prohibition, many commercial discussions stop before price, logistics, or buyer terms are even considered. A Free policy lets an exporter look at the whole deal and decide whether it makes business sense. Existing Buyer Relationships Can Be Revisited Businesses that sold wheat internationally before the 2022 prohibition may still have relationships with old customers or trading partners. The revised policy gives them a reason to reopen those conversations. Merchant Exporters Get More Room to Trade A trader can respond to an international enquiry by looking for suitable domestic supply. That can create another route to market for both merchant exporters and suppliers. Procurement Can Become More Export-Oriented Where international demand develops, procurement teams can source with the export contract in mind rather than buying first and looking for a market later. More Businesses May Enter Agricultural Exports A business already active in commodities may decide that wheat is worth adding to its export portfolio. New entrants, however, should not interpret an open policy as a substitute for preparation. This is where agricultural export compliance services and genuine trade advisory support may help businesses enter the market with fewer avoidable documentation or classification gaps. Challenges and Cost Considerations Opening the policy does not remove commercial difficulty. Correct Classification Still Takes Work Businesses that handle several wheat varieties or related products may need to check exactly where each product sits under ITC HS. That work may require internal technical input or professional ITC HS code classification support. International Prices Can Change Quickly A Free policy does not protect an exporter against a bad price. A contract may become unattractive if domestic procurement costs rise, freight moves sharply, or overseas prices fall. Freight Can Decide Whether a Deal Works Wheat is a bulk commodity. Transport and port costs can materially affect the final export price. An attractive buyer quote can look much less attractive once logistics are added. Quality Has to Match the Contract A buyer may want specifications that are different from what is easily available in the domestic market. An exporter needs to know that before accepting a quantity commitment. Working Capital May Increase Export transactions can involve procurement, storage, transport, and a gap between paying suppliers and receiving money from the overseas buyer. That is a commercial financing issue rather than a new DGFT requirement, but it can determine whether a transaction is viable. Policy Monitoring Still Matters Agricultural export policy can change. The 2022 prohibition, the 2026 quota relaxation and the August 2026 liberalisation show why businesses should not assume that today's policy will remain unchanged forever. Is This a Right Decision or an Additional Burden? For businesses dealing in the tariff lines that have been made Free, the notification is mainly a removal of a regulatory barrier, not the creation of another compliance burden. That does not mean there are no concerns. Liberalising an agricultural commodity can affect exporters, domestic suppliers, procurement teams and compliance functions in different ways. The policy may make international trade easier while also requiring businesses to make sharper decisions about classification, pricing and contracts. A fair assessment needs to look at both sides. Detailed Assessment: Benefit or Additional Burden? Assessment Area Why the Decision May Help Where a Burden or Risk May Still Arise Practical Assessment Export-policy access The two specified tariff lines no longer carry a prohibited status Exporters must still confirm that their goods fall under the liberalised codes Strong benefit for correctly classified goods DGFT licensing burden Free goods can generally be exported without a DGFT licence for that policy category Other approvals may apply if required by a separate law Reduces the earlier policy barrier Commercial flexibility Exporters can consider foreign buyers and markets more freely Not every export order will be financially attractive Benefit, but commercial assessment remains essential Merchant exporter participation Traders can source against international orders without the earlier basic prohibition Supplier reliability and contract risk become more important Useful opportunity for organised traders International market access Indian wheat can be considered for more ordinary commercial export transactions Destination-country rules still need to be met Useful opportunity for organised traders HS classification Clear tariff codes are identified in the notification Businesses can make mistakes if they assume every wheat product is covered Manageable burden if classification is checked early Documentation The notification does not add a special new documentation system Normal export documentation still has to be accurate No major new burden created by the notification Compliance cost No new fee, testing charge or licence fee is stated in Notification No. 35/2026-27 Businesses may still spend on classification, documentation, logistics or advisory support Mostly existing business costs rather than a new regulatory levy MSME participation Smaller trading businesses may have an additional export opportunity MSMEs may have less in-house trade expertise and working capital Opportunity exists, but preparation matters Procurement planning Export demand may provide another sales channel for suppliers Exporters can face loss if they commit before securing reliable supply Good for organised procurement, risky for speculative buying Contract management More export transactions can be negotiated on normal commercial terms Quality disputes, delivery failure or buyer defaults remain possible Contract discipline becomes more important Logistics sector Higher export activity, if it occurs, may generate freight and warehousing work Bulk cargo logistics can be costly and capacity-sensitive Potential business opportunity rather than guaranteed benefit Policy certainty A Free classification is simpler than managing a prohibited policy with limited relaxations Agricultural trade policy can still be amended later Easier current position, but monitoring remains necessary Domestic market considerations Exporters and suppliers gain access to overseas demand The notification itself does not explain future domestic price or supply outcomes Wider economic effects should not be predicted without evidence Overall compliance load The policy removes the prohibition for the two listed codes Normal export rules continue Net effect is liberalisation rather than an additional compliance burden Why It Looks More Like a Benefit The strongest argument in favour of the decision is that it simplifies the starting point. In April 2026, exporters were dealing with a policy that remained prohibited even though an additional 25 LMT of exports had been permitted. That kind of arrangement can require exporters to understand both the prohibition and the exception. A Free classification is easier to interpret for an ordinary commercial transaction. If the product is correctly classified under one of the liberalised codes, the exporter can move directly to the usual questions: IEC, documents, buyer requirements, customs processing, price, and logistics. Where the Burden Still Exists Most of the remaining burden does not come from Notification No. 35/2026-27. It comes from running an export business properly. An exporter still needs to know what is being shipped, how it is classified, what the overseas buyer expects, and whether the commercial documents are correct. A first-time exporter may find that work demanding, especially if the business has no internal trade-compliance team. That can create a need for DGFT compliance services, documentation support, or an experienced export compliance consultant. But that should not be confused with the Government creating a new compliance layer. Final Assessment For exporters dealing in ITC HS 10011900 and 10019910, the decision is better described as a policy liberalisation with normal business-compliance responsibilities remaining in place. It removes a direct restriction. It does not remove the need for sensible export controls. On balance, therefore, it is more likely to be commercially helpful than an additional regulatory burden for businesses that are prepared to classify their goods correctly and manage the transaction properly. Business Opportunities Created by the Policy Change The new policy can create opportunities at several points in the trade chain. Existing Wheat Exporters Can Return to Normal Commercial Planning Exporters with established overseas contacts may be the quickest to respond. They already understand procurement, documentation, freight, and buyer negotiations. Removing the prohibited status can allow them to review markets they know rather than build an export model from the beginning. Merchant Exporters Can Develop New Supply Relationships A merchant exporter can connect domestic suppliers with overseas demand. Where international pricing works, that can create business for traders without requiring them to own agricultural production. The opportunity is strongest for businesses that can manage quality, volume, logistics, and payment risk. Suppliers Can Reach Export Demand Indirectly Not every domestic trader needs to become an exporter. Some may benefit simply by supplying exporters. A business that can reliably supply wheat matching the buyer's requirements may find a new customer segment among exporters. Warehousing and Logistics Businesses May Benefit If actual wheat exports increase, the activity can also create demand for: storage, inland transport, cargo handling, freight forwarding, port-related services, and shipping coordination. Again, the notification does not guarantee an increase in volumes. It merely removes a policy barrier that may support additional trade. Compliance and Documentation Services Become More Relevant Liberalisation often brings new businesses into a market. Some may have no previous experience with agricultural exports. They can require help with: IEC, DGFT policy interpretation, tariff classification, export documentation, buyer-country requirements, and policy monitoring. For those businesses, DGFT export compliance consulting can be useful before a contract is signed, rather than after a documentation problem has already appeared. Risks Businesses Should Avoid The policy is easier, but some mistakes can still create avoidable trouble. Assuming Every Wheat Product Is Covered The notification identifies two codes. A processed product or a different wheat category should not automatically be placed under those entries. Using a Code Because It Is Free Classification should follow the goods, not the desired policy result. Choosing a Free tariff line simply because it is commercially convenient is a poor compliance approach. Accepting a Buyer Order Before Checking Supply An exporter can now legally explore the transaction, but that does not mean the required quantity will be available at an acceptable price. Procurement should be tested before a firm delivery promise is made. Ignoring the Destination Country The Indian export policy answers India's side of the policy question. The importing country still controls the admission of the goods into its own market. Relying on an Old Screenshot or News Article Businesses should check the current official DGFT position rather than relying only on information shared months earlier. Agricultural trade rules can move quickly. Treating “Free” as “Compliance-Free” This is probably the simplest mistake to avoid. The word Free removes the DGFT policy restriction for the listed tariff lines. It does not wipe away the entire export framework. What Should Wheat Exporters Do Next? Businesses that want to act on the new policy can keep the process practical. First, identify the exact product and determine the correct ITC HS classification. This should happen before finalising the overseas quotation. Next, check the latest DGFT export policy. If the shipment will take place later, confirm that no subsequent notification has altered the August position. The business should then check its IEC and general exporter readiness. Commercial documents should use clear and consistent descriptions. The overseas buyer's quality and destination-market requirements should also be reviewed. Only after those checks should the exporter commit firmly to quantity, price and delivery. For larger transactions, it is sensible to bring the procurement, finance, logistics and compliance teams into the discussion before the contract is signed. A problem discovered at that stage is usually easier to solve than one found after goods have been purchased or a vessel has been booked. How Corpseed Can Help Wheat Exporters The notification itself is easy to read. Applying it to a real transaction is where questions usually begin. A business may know that wheat exports are now Free under two tariff lines but still be unsure whether its own goods fall under those codes. A first-time exporter may also need help with IEC, documentation, or understanding the wider Foreign Trade Policy. Corpseed can support businesses with focused DGFT export compliance consulting rather than treating the notification as if it creates an unnecessary new licence. Relevant support can include: DGFT Export Policy Applicability Review Corpseed can assist businesses in reviewing whether Notification No. 35/2026-27 is relevant to the goods they intend to export and in understanding the difference between a Free policy and other independently applicable requirements. ITC HS Code Classification Support Correct classification sits at the centre of the notification. Corpseed can provide ITC HS code classification support to help businesses review the tariff entry applicable to their product before relying on the revised policy. DGFT Compliance Services Businesses may need help interpreting the Foreign Trade Policy, DGFT notifications, and later amendments. Corpseed's DGFT compliance services can support this regulatory review without suggesting that government approval is guaranteed. IEC Registration Services Businesses entering exports for the first time may require an Importer-Exporter Code unless they fall within an applicable exemption. Corpseed can assist with IEC registration services and related procedural support under the general DGFT framework. Export Documentation Support The wheat notification does not create a special document list, but normal export paperwork still matters. Corpseed can assist businesses with export documentation support, including review of product descriptions and consistency across relevant transaction records. Export Compliance Gap Assessment A company may already have an IEC but still lack internal controls for classification, documentation, or regulatory monitoring. A gap review can help identify those areas before the first shipment is committed. Foreign Trade Policy Consulting Businesses handling commodities may be affected by more than one DGFT notification over time. Foreign trade policy consulting can help management understand how current policy affects contracts, sourcing decisions, and planned exports. Ongoing Regulatory Monitoring The history of wheat policy itself shows why monitoring matters. The position changed from Free to Prohibited in 2022, moved through specific relaxations and quota permissions, and has now shifted to Free for the two identified codes. Businesses with ongoing export operations may therefore benefit from tracking later DGFT notifications instead of relying indefinitely on the August 2026 position. Professional support should help an exporter understand the rules and organise its transactions. It does not replace DGFT, Customs or any other authority, and it cannot guarantee customs clearance, buyer acceptance, export profitability or a particular regulatory result. Businesses planning wheat exports can use export compliance consulting when they need support with ITC HS classification, DGFT policy interpretation, IEC-related matters, and export-document readiness before committing to a shipment. Key Takeaways The DGFT wheat export policy has moved in a materially different direction for two tariff lines from 24 August 2026. The core points are straightforward: DGFT issued Notification No. 35/2026-27 dated 24 August 2026. The notification covers ITC HS 10011900 – Durum Wheat: Other and ITC HS 10019910 – Wheat. Both tariff lines move from Prohibited to Free. The revised policy applies with immediate effect. The notification does not state a separate transition period. It does not introduce a new quota, minimum export price, licence fee or testing requirement. “Free” means the products can be exported without a DGFT licence arising merely from that policy category, while other applicable laws and procedures can still apply. Exporters should verify the correct ITC HS code rather than assuming every wheat-related product is covered. General IEC and export-document requirements arise from the wider Foreign Trade Policy, not from this particular wheat notification. Businesses should check the latest official DGFT position before finalising future shipments. For exporters who need help with classification, documentation, or policy interpretation, DGFT export compliance consulting can provide transaction-specific support.

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.

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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.