DGFT Introduces Inventory-Based E-Commerce Export Framework 2026: New EOR Registration, Seller Payment and Compliance Rules
DGFT's inventory-based e-commerce export framework sets out rules for EOR registration, seller payment, inventory, returns, and annual audit from 5 August 2026.
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Introduction
The Directorate General of Foreign Trade (DGFT) introduced India's inventory-based e-commerce export framework on 5 August 2026. The framework allows a registered Exporter-on-Record (EOR) to hold Indian-origin goods exclusively for export through e-commerce, but only after receiving a confirmed order from a buyer outside India.
The regulatory framework amends the Foreign Trade Policy (FTP) 2023, includes operating procedures in the Handbook of Procedures (HBP) 2023, and introduces Aayaat Niryaat Form 9A (ANF-9A).
This framework applies to e-commerce marketplaces that offer an export-only inventory model, registered EORs, Indian manufacturers, and other GST-registered SORs. It lays down elaborate guidelines on registration, inventory tracking, seller payments, export benefits, destination-country compliance, returns, certification, and documentation.
A separate legal caution applies to foreign-invested e-commerce structures. DPIIT's Press Note No. 3 (2026 Series) says the related foreign direct investment policy decision will take effect from the date of the relevant Foreign Exchange Management Act notification. The DGFT documents reviewed do not identify that FEMA notification or its effective date.
Notification at a Glance
| Particular | Verified Details |
| Issuing authority | Directorate General of Foreign Trade, Department of Commerce, Ministry of Commerce and Industry |
| Document type | FTP amendment notification and HBP public notice with an application form |
| Date of issue | 5 August 2026 |
| Effective date | Immediate effect from 5 August 2026 for the FTP and HBP provisions |
| Related FDI instrument | DPIIT Press Note No. 3 (2026 Series), dated 23 July 2026 |
| FDI-policy effective date | The date of the FEMA notification is not identified in the three instruments reviewed. |
| Governing framework | Foreign Trade (Development and Regulation) Act, 1992; FTP 2023; HBP 2023; Consolidated FDI Policy; other applicable customs, GST and FEMA provisions |
| Sector/activity covered | Inventory-based cross-border e-commerce exports of eligible Indian-origin goods |
| Main stakeholders | E-commerce entities, EORs, SORs, Indian manufacturers, MSMEs, exporters, warehouses, logistics providers and compliance teams |
| Core development | Registered EORs may procure and hold goods exclusively for e-commerce exports against confirmed overseas orders. |
| Registration form | ANF-9A |
| One-time compliance deadline | Not expressly specified |
| Recurring deadlines | Seven-day, 30-day and 90-day requirements, depending on the obligation |
| Record-retention period | Five years from the end of the relevant financial year |
| Registration fee, validity and renewal | Not expressly specified |
| Nature of requirement | Mandatory for entities operating under the new EOR framework |
The Regulatory Framework
DGFT's legal authority
It was issued under Section 5 of the Foreign Trade (Development and Regulation) Act, 1992, read with paragraph 1.02 of FTP 2023. It inserts paragraphs 9.13-9.19 into FTP 2023.
It was issued under paragraphs 1.03 and 2.04 of FTP 2023. It inserts paragraphs 9.03 to 9.07 into Chapter 9 of HBP 2023 and notifies ANF-9A.
The FTP lays down the substantive policy. The HBP explains how regulated parties must implement it. The Foreign Trade (Development and Regulation) Act, 1992 provides the statutory basis for India's foreign trade policy and its administration.
Earlier FDI position
Under the Consolidated FDI Policy Circular of 2020, foreign direct investment was permitted in business-to-business e-commerce and the marketplace model, subject to applicable conditions. FDI was not permitted under an inventory-based model in which the e-commerce entity owned the inventory and sold directly to consumers.
DPIIT proposes an export-only exception for goods manufactured or produced in India. It preserves the existing restrictions for domestic B2C and inventory-based e-commerce.
It states that its decision takes effect from the date of the FEMA notification. Foreign-invested applicants should therefore verify the relevant FEMA instrument before commencing operations in reliance on the FDI relaxation.
Interaction with other laws
ANF-9A requires the applicant to undertake compliance with the following, among other applicable laws:
- Foreign Trade (Development and Regulation) Act, 1992,
- Foreign Trade Policy 2023,
- Handbook of Procedures 2023,
- Customs Act, 1962,
- Foreign Exchange Management Act, 1999, and
- Central Goods and Services Tax Act, 2017.
EOR registration does not replace product-specific, customs, GST, foreign-exchange or destination-country approvals. It also does not automatically grant eligibility for export incentives. Each benefit remains subject to its governing scheme and notification.
Why This Was Implemented
Paragraph 9.14 of the amended FTP states that the framework is intended to enable e-commerce exports through an inventory model. Under this model, the EOR holds export inventory, handles export processes, and helps Sellers-on-Record access overseas markets.
DPIIT's Press Note gives a related policy reason: improving Indian sellers' access to global markets and facilitating greater exports. The framework seeks to achieve this while preventing an export-only inventory operation from becoming an indirect domestic retail channel.
Its main controls are therefore built around:
- confirmed overseas orders rather than speculative stock accumulation,
- strict separation of export and domestic inventory,
- a complete digital trail between seller, inventory and export documents,
- timely payment and visibility for Indian sellers,
- prohibition on domestic diversion, including for returned goods, and
- annual independent compliance certification.
What Has Changed
The two DGFT instruments create a new, source-specific operating model rather than a general relaxation across all forms of e-commerce.
| Compliance Area | Earlier Verified Position | New Position | Effective Date | Business Meaning |
| Inventory-based exports | No dedicated EOR framework existed in FTP 2023 | FTP paragraphs 9.13–9.19 create an export-only inventory framework | 5 August 2026 | Eligible entities can apply to operate through a registered EOR |
| FDI in inventory e-commerce | Restricted under the Consolidated FDI Policy | Press Note No. 3 proposes an exception for export-only operations involving Indian-made or produced goods. | Date of FEMA notification | Foreign-invested entities must verify FEMA effectiveness separately |
| Transfer of title | No source-specific rule under this framework | Title may pass to the EOR only against a confirmed overseas order | 5 August 2026 | Speculative inventory accumulation is prohibited |
| Seller payment | No framework-specific period | Payment is due within seven days of acceptance or deemed acceptance | 5 August 2026 | Buyer payment or overseas returns cannot delay payment to the SOR |
| Export benefits | No EOR-SOR sharing method under this framework | Relevant rebates and refunds must be apportioned by FOB value | 5 August 2026 | Participating sellers receive a defined share when the EOR claims the benefit. |
| Returned goods | No framework-specific disposal rule | Returned goods cannot enter domestic sales and must be resolved within 30 days of receipt in India | 5 August 2026 | Reverse logistics becomes the EOR’s responsibility and cost |
| Compliance assurance | No framework-specific annual certificate | Independent annual compliance certification is required | 5 August 2026 | EORs need audit-ready records throughout the year |
The change does not allow an EOR to acquire Indian goods in anticipation of possible future demand. The commercial order must come first, followed by the transfer of title and creation of export-designated inventory.
Scope and Applicability
| Stakeholder or Product | Covered? | Relevant Condition | Main Responsibility |
| Registered Exporter-on-Record | Yes | Must hold a valid IEC and GSTIN and be registered with DGFT | Export, inventory, payment, benefits, destination compliance and returns |
| Seller-on-Record | Yes | Must be registered in India under the applicable GST law | Supply Indian-produced goods against a confirmed export order and correctly declare origin |
| Foreign-invested e-commerce structure | Conditionally | Separate legal EOR entity is required; FEMA effectiveness must be verified. | Disclose shareholding and ownership or control relationship. |
| Marketplace e-commerce entity | Not for holding inventory under this framework | Paragraph 9.15 refers to an e-commerce entity other than a marketplace entity | May continue under its separately applicable marketplace rules |
| Indian-origin goods | Yes | Goods must meet the applicable origin criteria | SOR must ensure and declare correct origin |
| Imported goods | No | Only goods of Indian origin are eligible | Not covered by this framework |
| Service exports | No | The framework concerns goods and export inventory | Not covered |
| Domestic sales by the EOR | No | Export inventory and returned goods cannot be diverted to domestic sales | Strict prohibition |
| Speculative inventory | No | Title may pass only against a confirmed overseas order | Stock cannot be accumulated in anticipation of orders |
| Goods later notified as ineligible. | No | DGFT may publish an ineligible-goods list | Businesses must monitor later notifications |
No product-wise exclusion list appears. DGFT has reserved the power to notify ineligible goods later.
Detailed Provision-Wise Analysis
1. Exporter-on-Record and separate legal entity
An EOR must:
- hold a valid Importer-Exporter Code (IEC),
- hold a valid Goods and Services Tax Identification Number (GSTIN),
- register with DGFT under the framework,
- procure goods from one or more SORs,
- export and sell those goods in its own capacity to buyers outside India, and
- maintain the required operational and compliance controls.
Where an e-commerce entity proposes operations under the FDI-policy provision introduced through Press Note No. 3, those operations must be conducted through a separate legal entity incorporated for that purpose. The entity must disclose its shareholding and ownership or control relationship with the associated e-commerce entity.
2. Confirmed orders and Indian origin
Only items of Indian origin will be considered. It is the duty of the SOR to correctly identify and declare the origin of the item as per the law and origin criteria.
Title can be transferred from SOR to EOR only after EOR receives a confirmed export order from a foreign buyer. A mere interest of buying, forecast, projection of demand, or internal sales target will not be considered as a confirmed order.
3. Inventory identification and digital traceability
The EOR must distinctly identify and segregate Export Inventory. It must maintain a digital repository that can identify, track and trace the inventory.
The repository must:
- cover all locations where Export Inventory is held,
- remain operational even where multiple warehouses are used,
- record procurement from each SOR,
- show current inventory status,
- link the inventory with export documentation,
- connect procurement records, GST invoices and export documents to the relevant SOR, and
- remain accessible to DGFT and other authorities authorised under applicable law.
The EOR must also ensure that the goods match the descriptions, specifications and quality parameters declared by the SOR.
4. Destination-country product compliance
Before export, the EOR is solely responsible for ensuring compliance with the destination country's applicable requirements. Depending on the product and market, these may include:
- testing and inspection,
- certification and accreditation,
- registration, licensing and approvals,
- conformity assessment,
- packaging and labelling,
- product marking,
- product information,
- safety warnings, and
- other market-access requirements.
The framework does not make every listed approval compulsory for every product. Each becomes relevant only where the destination country or applicable product law requires it.
5. Payment to the Seller-on-Record
The EOR must pay the SOR immediately on accepting the cargo or upon such acceptance being presumed. The payment must not be delayed beyond seven days from the date of such acceptance or presumed acceptance.
Payment cannot be delayed because:
- the overseas customer has not yet paid the EOR,
- the customer later returns the goods, or
- another event outside the SOR's control occurs.
This places overseas payment and customer-return risk on the EOR rather than the Indian seller.
6. Export rebates, refunds and seller benefits
"Export Rebates and Refunds" include cash or cash-equivalent incentives, rebates, refunds or remissions received by the EOR after export. The definition includes:
- Duty Drawback,
- Remission of Duties and Taxes on Exported Products (RoDTEP),
- Rebate of State and Central Taxes and Levies (RoSCTL), and
- another notified scheme giving a direct monetary or transferable financial benefit.
The definition excludes non-transferable duty-remission instruments such as Advance Authorisation and Export Promotion Capital Goods Authorisation. GST refunds belonging to the EOR are also excluded from seller-attributable rebates and refunds.
Where an EOR claims a covered benefit:
- the amount must be apportioned among relevant SORs according to the Free-on-Board value of their goods declared in the Shipping Bill,
- the EOR may retain an administrative charge not exceeding 10% of the gross rebates and refunds,
- the remaining seller-attributable amount must be paid to the SOR within 30 days after the EOR receives the benefit, and
- the pass-through duty arises only when the EOR has claimed the relevant benefit.
- An export rebate cannot be made mandatory. The eligibility conditions remain tied to the applicable scheme.
7. Visibility of seller and product
The SORs need access to digital information regarding their products. The bare minimum required is that the information needs to include:
- final sale price to the buyer outside India,
- order status,
- shipment-tracking details, and
- destination country.
The product listing or another applicable method must disclose the manufacturer or brand owner. Where the SOR is different from the manufacturer or brand owner, the SOR's identity must also be disclosed to the buyer.
8. Non-conforming and returned goods
Goods supplied by an SOR that fail to meet the required description, specification or quality parameters must be returned by the EOR within seven days of acceptance or deemed acceptance.
A consignment returned or rejected by an overseas buyer must be dealt with within 30 days from its receipt in India. It must be:
- re-exported,
- returned to the SOR,
- destroyed, or
- dealt with through another agreed method permitted by applicable law.
The EOR cannot sell or supply a returned or rejected consignment in India, directly or through another person. The EOR must bear the reverse-logistics cost.
The EOR-SOR agreement must clearly address cancellation, rejection, repair, re-export, destruction, disposal and related return conditions. These terms must be fair, transparent and verifiable.
9. Annual certification and record retention
An independent Chartered Accountant, Cost Accountant or another professional later specified by DGFT must certify compliance with:
- Export Inventory maintenance and segregation,
- prohibition on domestic diversion,
- handling of returned and rejected goods,
- seller visibility and brand disclosure,
- seller-payment periods,
- export-benefit payment periods,
- accuracy of benefit-apportionment calculations, and
- disposal or other treatment of returned goods.
The EOR must provide the professional with all reasonably required books, records and assistance. The certificate must be submitted to DGFT within 90 days of the end of each financial year, unless DGFT prescribes a different interval.
Records must be retained for five years from the end of the financial year in which the relevant inventory is finally exported, re-exported, returned, rejected, destroyed or otherwise disposed of. This duty survives suspension, cancellation or voluntary surrender of EOR registration.
10. Dispute resolution
An EOR-SOR dispute may be referred to the DGFT Regional Authority having jurisdiction over the SOR's place of business from which the disputed supply was made.
The Regional Authority must give both parties a reasonable opportunity to be heard and endeavour to facilitate resolution within 30 days of receiving the complaint. This is an endeavour, not an absolute adjudication deadline.
An unresolved matter may be referred to DGFT Headquarters with written reasons. DGFT Headquarters may request records, information, and comments before issuing appropriate administrative directions or recommendations.
A micro or small enterprise retains its right to approach the Micro and Small Enterprises Facilitation Council under Section 18 of the Micro, Small and Medium Enterprises Development Act, 2006.
11. E-Commerce Export Hubs
The EOR must use notified E-Commerce Export Hub infrastructure "to the extent practicable." This is subject to the facility being operationally ready and having sufficient capacity.
The wording does not create an unconditional requirement to use an ECEH where the facility is unavailable or unsuitable.
Exporter-on-Record Registration and ANF-9A
ANF-9A is the prescribed application for EOR registration. Scanned copies of the completed form and supporting documents must be sent to the government.
The form asks for:
- IEC, PAN, GSTIN and legal name,
- constitution of the applicant,
- CIN or LLPIN, where applicable,
- incorporation or registration date,
- registered-office address,
- authorised signatory and contact information,
- foreign-investment percentage on a fully diluted basis,
- names and countries of foreign investors,
- relationship with the associated e-commerce entity,
- total and export turnover for the previous three financial years,
- proposed export countries,
- e-commerce platforms and the relationship with each platform, and
- details of every warehouse or inventory location.
- Newly incorporated entities may leave the three-year turnover section blank.
The applicant shall provide, for each inventory location, the location address, GST registration (if any), whether the location is an ECEH, approximate inventory capacity, ownership or lease, and operator information.
Documents expressly required
| Document or Record | Status | Purpose | Submission Stage |
| Board resolution or authorisation letter | Mandatory | Establish authority of the signatory | With ANF-9A |
| Evidence of relationship with the e-commerce entity | Mandatory where such relationship exists | Show shareholding, group structure, board composition or similar connection. | With ANF-9A |
| Warehouse and inventory-location documents | Mandatory | Verify locations and ownership or lease arrangements | With ANF-9A |
| Other documents required by DGFT | Conditional | Address further verification requirements | When requested |
ANF-9A does not expressly provide for an application fee, processing period, registration expiry, renewal, or process for appeal to rejection. Applicants should not make assumptions regarding these items.
Changes after registration
A revised ANF-9A must be submitted within 30 days of a relevant change. The form specifically covers:
- constitution or legal name,
- registered-office address,
- authorised signatory,
- shareholding or FDI structure,
- relationship with the e-commerce entity,
- warehouse or Export Inventory locations,
- addition or deletion of e-commerce platforms,
- contact details,
- voluntary surrender, and
- another material change.
After receiving the update, DGFT may confirm, modify, suspend or cancel the registration after examining whether the EOR continues to satisfy the eligibility conditions.
Implementation Timeline and Compliance Norms
| Event or Requirement | Relevant Date or Period | Affected Entity | Required Action |
| DPIIT Press Note No. 3 issued | 23 July 2026 | Foreign-invested e-commerce entities | Review export-only FDI proposal and FEMA dependency |
| DGFT framework introduced | 5 August 2026 | Foreign-invested e-commerce entities | Apply through ANF-9A before operating under the framework |
| DGFT framework introduced | Immediate from 5 August 2026 | EORs and SORs using the model | Implement all applicable controls |
| Seller payment | Within seven days of acceptance or deemed acceptance | EOR | Pay the SOR without waiting for overseas payment |
| Return of non-conforming seller goods | Within seven days of acceptance or deemed acceptance | EOR | Return goods that fail the declared requirements |
| Change in registration particulars | Within 30 days of the change | EOR | Submit revised ANF-9A |
| Seller-attributable export benefits | Within 30 days of receipt by EOR | EOR | Pay the SOR’s apportioned amount |
| Overseas return or rejected consignment | Within 30 days of receipt in India | EOR | Re-export, return, destroy or lawfully dispose |
| Regional Authority dispute process | Endeavour within 30 days of complaint | DGFT Regional Authority | Facilitate resolution after hearing both parties |
| Annual compliance certificate | Within 90 days after financial-year end | EOR | Submit independent certificate to DGFT |
| Record retention | Five years from the end of the relevant financial year | EOR | Preserve complete records despite cancellation or surrender |
There is no stated transition period. The obligations apply immediately to operations conducted under the framework.
Risks and Consequences of Non-Compliance
The declaration in ANF-9A lists the consequences that may follow after due process. These are not stated as automatic outcomes.
Possible consequences include:
- Suspension/cancellation of EOR registration,
- Suspension/cancellation of IEC,
- Entry into the list of "Denied Entity" pursuant to para. 2.14 of FTP 2023,
- Recovery of export rebates and refunds, along with interest,
- Penal or prosecution proceedings under the Foreign Trade (Development and Regulation) Act, its rules and orders, or another applicable law, and
- Other action warranted under applicable law.
The declaration identifies domestic diversion, delayed or contingent seller payments, incorrect benefit apportionment, false origin claims, record failures, false information, and misuse of seller information as relevant breaches. Furnishing false, incorrect, or misleading information is independently stated to be grounds for the listed action.
ANF-9A also refers to receipt of a complaint from an SOR within the same clause. Because the form retains the words "after due process," a complaint should not be described as an automatic violation or automatic ground for punishment.
No fixed monetary penalty is prescribed. Any monetary or prosecution consequence must be determined under the applicable governing law and facts.
Unclear or Pending Points Businesses Should Track
Several points are not fully resolved in the instruments:
- FEMA effectiveness: Press Note No. 3 makes its FDI decision contingent on a FEMA notification, but the DGFT documents do not identify the notification or its date.
- Ineligible goods: DGFT may notify an exclusion list later, but no list is included in the present notification.
- Acceptance and deemed acceptance: The instruments do not define these terms, although they trigger both the seven-day payment period and the seven-day return period for non-conforming goods.
- Registration administration: No fee, disposal timeline, validity period, renewal requirement, or rejection-review procedure is stated.
- Pilot phase: DGFT may review the export rebate and refund process during the pilot phase, but the duration and review schedule are not specified.
- Digital repository standards: The minimum content and access requirements are specified, but detailed technical formats, security standards, and system specifications are not prescribed.
- Other documents: ANF-9A allows DGFT to seek another document as required, without providing a closed list.
- Disposal mechanics: Destruction and other agreed disposal methods remain subject to applicable customs, tax, environmental and product laws.
- Complaint language: The form includes receipt of an SOR complaint among events that may lead to action after due process, without separately defining the threshold for such action.
These considerations do not negate the duties mentioned above. They involve proper contract formulation, internal controls, and monitoring of later DGFT, customs, and FEMA guidelines.
Impact on Businesses
The system separates the operational advantages of Indian sellers from those of the EOR, which bear more responsibility.
| Stakeholder | Immediate Impact | Likely Operational or Cost Effect | Priority Concern |
| E-commerce entities and EORs | New registration route and export-only inventory model | Digital systems, working capital, annual certification and reverse-logistics costs | Preventing domestic diversion and meeting short deadlines |
| Indian manufacturers and SORs | Access to an order-backed export channel | Digital systems, working capital, annual certification and reverse-logistics costs | Accurate origin, specification and GST records |
| MSMEs and artisans | Potential access to overseas buyers without handling every export function | Contract review and product-readiness costs may remain | Fair return terms, timely payments and benefit sharing |
| Finance and tax teams | Seven-day payment and benefit-apportionment controls | Faster cash outflow and reconciliation work | Correct FOB allocation and scheme eligibility |
| Product and quality teams | Destination-country compliance moves to the EOR | Testing, certification, packaging or labelling cost where required | Market-specific product compliance |
| Warehouses and logistics providers | Export inventory must be separately tracked | System integration and physical segregation | Traceability across multiple locations |
| Chartered and Cost Accountants | New annual certification assignment | Detailed evidence testing will be required | Independence and adequate audit trail |
| DGFT authorities | Registration, monitoring and dispute-facilitation functions | Increased supervisory work during the pilot | Consistent interpretation and enforcement |
Impact on Exporters-on-Record
The EOR is given control over export operations but shoulders most of the commercial and regulatory responsibilities. The EOR has to pay the sellers independently of the payment from the foreign buyer and manage the reverse logistics.
Impact on Sellers-on-Record
SORs gain source-based protections:
- payment within seven days after acceptance or deemed acceptance,
- access to final price, order and shipment information,
- a proportionate share of claimed export benefits,
- product-listing identity disclosure, and
- access to the DGFT dispute-facilitation route.
SORs remain responsible for correct origin declarations and accurate descriptions, specifications and quality information.
Impact on MSMEs
This model might help reduce the effort required of the small seller to handle every export activity on his own. The EOR will be responsible for export documentation, logistics, and compliance with the destination country's requirements. However, MSMEs need to be careful about their contracts, particularly about returns, rejections, repairs, and disposals.
Micro and small enterprises retain their statutory right to approach the Micro and Small Enterprises Facilitation Council under Section 18 of the MSMED Act.
Policy Assessment: Export Facilitation With Strict Ring-Fencing
The framework can support Indian manufacturers by placing international fulfilment, market-access work and reverse logistics with a dedicated EOR. The seven-day seller-payment rule and access to overseas pricing and shipment data address several practical concerns faced by smaller suppliers.
The system also generates significant compliance costs. The EOR is responsible for ensuring a traceable record at the warehouse level, financing sellers before collecting payment from the foreign buyer, addressing destination-country compliance issues, and taking responsibility for returns. Independent yearly certification adds further to that.
The strict approach is connected to the policy's narrow purpose. It allows order-backed export inventory while preventing the arrangement from being used for domestic inventory-led retail. Since participation requires registration and is not imposed on all exporters, businesses can assess the commercial model before opting in.
What Businesses Should Do Next
| Priority | Action | Responsible Team | Relevant Date | Expected Outcome |
| 1 | Confirm that the proposed model involves eligible Indian-origin goods, confirmed overseas orders, and export-only inventory. | Legal and business teams | Before applying | Clear applicability decision |
| 2 | For a foreign-invested structure, verify compliance with FEMA notifications and establish the required separate legal entity. | Legal, FDI and corporate teams | Before commencing operations | Lawful entity structure |
| 3 | Confirm valid IEC, GSTIN, corporate details and authorised signatory | Secretarial and tax teams | Before ANF-9A filing | Registration readiness |
| 4 | Prepare ANF-9A and all supporting relationship and warehouse documents | Compliance team | Before operating as EOR | Complete registration application |
| 5 | Draft an EOR-SOR agreement covering acceptance, payment, rejection, repair, return, re-export and disposal. | Legal and procurement teams | Before procurement | Clear and verifiable commercial terms |
| 6 | Build inventory segregation and a DGFT-accessible digital repository | Operations and technology teams | Before receiving inventory | End-to-end traceability |
| 7 | Create seven-day payment and 30-day benefit-disbursement controls | Finance and tax teams | From the first transaction | Timely seller settlement |
| 8 | Prepare a destination-country product compliance matrix | Product, quality and legal teams | Before export | Market-access readiness |
| 9 | Establish returned-goods and no-domestic-diversion controls | Logistics and warehouse teams | Before the first export | Compliant reverse logistics |
| 10 | Maintain audit-ready records and appoint an independent professional for annual certification. | Finance and compliance teams | Throughout the financial year | Timely annual certificate and five-year evidence trail |
For a normal seller, before deciding to participate, they need to evaluate the contract involved, proof of the product's source, the terms for rejection, and the availability of information online. The seller needs to understand that just because the responsibility to register is the EOR's does not mean that his GST, product or source responsibilities have been taken care of.
How Can Corpseed Help?
Corpseed supports e-commerce entities, exporters and Indian sellers with DGFT registration services and related export compliance work under the new framework.
Relevant support may include:
- Assessing whether the proposed business model and goods fall within the EOR framework,
- Reviewing separate-entity, FDI-policy and FEMA considerations,
- Checking IEC, GSTIN and corporate-document readiness,
- Preparing and reviewing ANF-9A and its supporting documents,
- Drafting a compliance matrix for EOR and SOR responsibilities,
- Reviewing inventory segregation, digital repository and record-retention controls,
- Supporting destination-country testing, certification, packaging and labelling assessments,
- Reviewing EOR-SOR agreements for payments, returns and benefit sharing, and
- Preparing for annual professional certification and DGFT record checks.
Corpseed's work is carried out with due consideration of relevant legal documents and the applicant's practical business model. Registration, eligibility for export benefits, and regulations will continue to depend upon DGFT and other relevant authorities.
E-commerce entities and exporters planning to adopt this model can seek Corpseed's DGFT registration services for an applicability review, ANF-9A preparation and an operating-control assessment before accepting export inventory.
About the Author
Mahek Sancheti
Content WriterMahek Sancheti, BAJMC graduate with a deep passion for writing. As a content writer, video content creator, creative content creator, and scriptwriter, I bring stories to life through words and visuals. I honed my skills by working with a prominent news agency, where I excelled in crafting compelling narratives and engaging content. Coming from a journalism and mass communication background I have skills to craft engaging narratives that captivate audiences. With a keen interest in writing and creativity, I aim to deliver impactful and meaningful content that resonates with diverse audiences.
https://www.linkedin.com/in/mahek-sancheti-837196212