What has changed in the Foreign Trade Policy 2023 for service exporters?
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Short answer
India's Foreign Trade Policy 2023 took effect on 1 April 2023 with no end date.1 Self-certified e-BRCs started as a pilot in November 2023.2 A mode-of-export field became mandatory on services e-BRCs from 1 May 2025.3 IEC details face online and NPCI checks from November 2025 and February 2026.45 In August 2026, DGFT eased One Star Export House status.7
| Change | Applies to | Governed by | Deadline | Penalty | Last verified |
|---|---|---|---|---|---|
| Self-certified e-BRC | Exporters who generate e-BRCs | DGFT Trade Notice 33/2023-24, 10 November 20232 | Pilot from 15 November 20232 | Not applicable | 28 October 2026 |
| Mode of export of services field | Services e-BRCs | DGFT Trade Notice 02/2025-26, 21 April 20253 | e-BRCs generated on or after 1 May 20253 | Not applicable | 28 October 2026 |
| NPCI bank validation for IEC | New IEC applications and modifications | DGFT Trade Notice 23/2025-26, 6 February 20265 | From February 20265 | Failed validation blocks submission5 | 28 October 2026 |
| Rupee and foreign currency receipts | Exporters claiming FTP benefits | DGFT Notification 30/2026-27, 20 August 20266 | Immediate effect6 | Benefits returned if proceeds not realised in RBI time (para 2.54)8 | 28 October 2026 |
| One Star Export House on two of three years | Status holder applicants | DGFT Notification 33/2026-27, 21 August 20267 | Immediate effect7 | Not applicable | 28 October 2026 |
India's Foreign Trade Policy (FTP) 2023 is the Directorate General of Foreign Trade's (DGFT) rulebook for exports and imports of goods and services. It came into force on 1 April 2023 and continues until amended.1 DGFT changes it through notifications (the policy), public notices (the Handbook of Procedures) and trade notices (systems and processes).
This page lists changes since April 2023 that matter to service exporters, newest first, each with the document and date.267 Changes that only affect goods (customs, input-output norms, quotas, commodity export policy) are left out. For RBI changes alongside DGFT's, see RBI and DGFT changes for exporters.
What is the Foreign Trade Policy 2023?
The Foreign Trade Policy 2023 is DGFT's policy for exports and imports of goods and services, in force from 1 April 2023 with no end date, with exports up to 31 March 2023 governed by the earlier policy.1 It is amended in three ways:
- Notifications: change the policy text itself, such as paras 1.25, 2.52 and 2.53.67
- Public notices: change the Handbook of Procedures, such as para 2.08 on IEC applications.4
- Trade notices: change systems and processes, such as the e-BRC system.23
Who does the Foreign Trade Policy 2023 apply to among service exporters?
The Foreign Trade Policy 2023 applies to service exporters mainly when they claim FTP benefits or status, while e-BRC rules matter to anyone using e-BRCs for GST refunds.82
| Entity type | Applicable | Why | Best for |
|---|---|---|---|
| Freelancer not claiming FTP benefits | Mostly no | Para 2.05(a): IEC for services is needed only to avail FTP benefits8 | Individuals paid by foreign clients without incentives |
| Exporter using e-BRCs for GST refunds | e-BRC rules only | Self-certified e-BRCs and the mode-of-export field apply23 | Registered exporters claiming refunds |
| Exporter claiming FTP benefits | Yes | Needs an IEC and an RCMC (paras 2.05 and 2.57)8 | Firms registered with an export promotion council |
| Services company seeking status | Yes | Paras 1.25 and 1.26 cover goods, services and technology exporters1 | IT firms and agencies near the $3 million threshold |
How does a service exporter keep up with FTP 2023 changes?
A service exporter keeps up with FTP 2023 changes by first deciding whether it claims FTP benefits, then keeping its IEC, bank details and RCMC current.81
- Decide on benefits: if you do not claim benefits, most FTP changes do not affect you directly, but e-BRC rules matter if you use e-BRCs for GST refunds.
- Update your IEC: every April to June, as para 2.05(d) requires.8
- Keep bank details consistent: across PAN, IEC and bank records, since IEC bank accounts are validated through NPCI.5
- Hold a current RCMC: required to apply for FTP benefits under para 2.57.8
- Track yearly export performance: status depends on performance in the preceding financial years.7
What changed in the Foreign Trade Policy 2023, and when?
The changes to the Foreign Trade Policy 2023 that matter to service exporters are mostly procedural, from self-certified e-BRCs in November 2023 to rupee receipts and easier status in August 2026.267
| Date | Document | Change |
|---|---|---|
| 21 August 2026 | Notification 33/2026-277 | One Star Export House on two of three years |
| 20 August 2026 | Notification 30/2026-276 | Contracts and receipts in rupees or any foreign currency |
| 6 February 2026 | Trade Notice 23/2025-265 | NPCI validation of IEC bank accounts |
| 20 November 2025 | Public Notice 32/2025-264 | Online validation of IEC applications |
| 21 April 2025 (effective 1 May 2025) | Trade Notice 02/2025-263 | Mode of export of services on e-BRCs |
| 14 August 2024 (effective 20 August 2024) | Trade Notice 12/2024-259 | Bulk and API e-BRCs |
| 10 November 2023 (pilot from 15 November 2023) | Trade Notice 33/2023-242 | Self-certified e-BRCs |
| 1 April 2023 | FTP 2023, para 1.011 | FTP 2023 in force |
What did DGFT change in August 2026 for service exporters?
DGFT changed status holder rules and currency rules in August 2026.67
- One Star Export House: DGFT Notification No. 33/2026-27 amended para 1.25(d) with immediate effect. Status still needs export performance in all three preceding financial years, except that for One Star Export House (other than gems and jewellery), performance in any two of the three is enough.7 A small IT firm or agency with one weak year can now qualify, subject to the rest of para 1.25. See DGFT status holder.
- Currency of contracts: DGFT Notification No. 30/2026-27 rewrote paras 2.52 and 2.53 with immediate effect. Export contracts and invoices, other than those involving Asian Clearing Union (ACU) members, may be denominated in foreign currency or Indian rupees, and proceeds may be realised in any foreign currency or rupees.6
- ACU members: contracts with ACU members other than Nepal and Bhutan are denominated in a currency the ACU determines, or as RBI directs.6
- Rupee realisations: exports to any country other than Nepal and Bhutan whose proceeds are realised in rupees, by credit to rupee accounts of persons resident outside India under the FEMA (Deposit) Regulations, qualify for FTP benefits on par with foreign currency realisations.6
DGFT says the change aligns the FTP with the FEMA (Manner of Receipt and Payment) Regulations, 2023.6 The earlier text required realisation in "freely convertible currency" with narrow rupee exceptions.8 See export invoicing in INR.
What did DGFT change for IEC applications in 2025 and 2026?
DGFT added online validation of IEC applications in November 2025 and NPCI bank validation in February 2026.45
- 20 November 2025: DGFT Public Notice 32/2025-26 merged ANF-1A into a revised ANF-2A and amended para 2.08(c) and (d) of the Handbook of Procedures so that IEC application details are validated through online integration with records of ministries, departments and banks, with post-verification guidelines issued by DGFT headquarters.4 See how to apply for an IEC.
- 6 February 2026: DGFT Trade Notice 23/2025-26 says bank account details in new IEC applications and IEC modifications are validated in real time through NPCI from February 2026. Applicants must declare all active bank accounts linked to their PAN.5
What did DGFT change for e-BRCs between 2023 and 2025?
DGFT moved e-BRCs to self-certification in 2023, added bulk and API generation in 2024, and added a mode-of-export field in 2025.239
- Self-certification: DGFT Trade Notice 33/2023-24, citing para 1.07 of FTP 2023, launched the upgraded e-BRC system: banks send Inward Remittance Messages to DGFT and exporters self-certify e-BRCs against invoices.2 See e-BRC on DGFT.
- Bulk and API: DGFT Trade Notice 12/2024-25 introduced bulk upload by spreadsheet and API integration with exporters' ERP or accounting systems for e-BRC self-certification.9
- Mode of export: DGFT Trade Notice 02/2025-26 added a mandatory "Mode of Export of Services" field for services e-BRCs generated on or after 1 May 2025, using the four GATS modes: cross-border supply, consumption abroad, commercial presence and presence of natural persons.3
What happens if a service exporter gets FTP 2023 compliance wrong?
If a service exporter fails to realise proceeds within the time RBI specifies, para 2.54(a) requires it to return all benefits availed against those exports, without prejudice to other penalties.8
- Unrealised proceeds: benefits are returned under para 2.54(a).8
- Failed NPCI validation: a failed validation blocks submission of a new IEC application, and on modification it marks the application deficient.5
- No RCMC: an application for an FTP benefit needs an RCMC unless specifically exempted.8
Which FTP 2023 paras matter most to service exporters?
Four provisions of FTP 2023 matter most to service exporters: paras 2.05, 1.25 and 1.26, 2.54 and 2.57.18
| Para | Rule | Why it matters for services | Best for |
|---|---|---|---|
| 2.05(a) | IEC needed for goods; for services only to avail FTP benefits | A freelancer not claiming benefits needs no IEC under FTP | Freelancers deciding whether to get an IEC |
| 1.25 and 1.26 | Status holder recognition for goods, services and technology exporters | One Star Export House at $3 million | Larger IT firms and agencies |
| 2.54 | Benefits must be returned if proceeds are not realised in RBI's time limit | Links FTP benefits to the FEMA realisation period | Exporters claiming benefits |
| 2.57 | RCMC needed to apply for FTP benefits | Service exporters register with the relevant export promotion council | Exporters applying for schemes |
The table summarises the chapters as published on DGFT's website.18 FTP 2023 also asks each district to identify "products and services" with export potential under its District Export Action Plan.10
What are the common mistakes service exporters make with FTP 2023?
The common mistakes service exporters make with FTP 2023 are getting an IEC they do not need, letting the IEC go stale, and holding bank accounts that do not match across records.85
- Unneeded IEC: for services, an IEC is needed only to avail FTP benefits.8
- Stale IEC: para 2.05(d) requires an update every April to June.8
- Mismatched bank details: applicants must declare all active bank accounts linked to their PAN.5
- Missing the mode-of-export field: services e-BRCs from 1 May 2025 need it.3
For example, say an agency had export performance in two of the last three financial years and one weak year: from 21 August 2026 it can apply for One Star Export House, subject to the rest of para 1.25.17
Which benefits you can claim depends on your service, council membership and records, so confirm with your export promotion council or a chartered accountant. See export promotion schemes for services and SEPC membership.
How did we verify this?
We checked this page against the sources below on 30 October 2026. Read our methodology or report an error.
- [1]DGFT: Foreign Trade Policy 2023, Chapter 1 (paras 1.01, 1.25 to 1.29)
- [2]DGFT: Trade Notice No. 33/2023-24 dated 10 November 2023, Pilot launch of the upgraded eBRC system for self-certification by exporters
- [3]DGFT: Trade Notice No. 02/2025-26 dated 21 April 2025, Mode of Export of Services field in eBRC from 1 May 2025
- [4]DGFT: Public Notice No. 32/2025-26 dated 20 November 2025, Amendment to Para 2.08 of the Handbook of Procedures
- [5]DGFT: Trade Notice No. 23/2025-26 dated 6 February 2026, NPCI-based bank account validation in IEC applications and modifications
- [6]DGFT: Notification No. 30/2026-27 dated 20 August 2026, Amendment in Paras 2.52 and 2.53 of the Foreign Trade Policy 2023
- [7]DGFT: Notification No. 33/2026-27 dated 21 August 2026, Amendment in Para 1.25 of the Foreign Trade Policy, 2023
- [8]DGFT: Foreign Trade Policy 2023, Chapter 2 (paras 2.05, 2.52 to 2.54, 2.57)
- [9]DGFT: Trade Notice No. 12/2024-25 dated 14 August 2024, API integration and bulk upload facility for self-certification of eBRC
- [10]DGFT: Foreign Trade Policy 2023, Chapter 3 (Developing Districts as Export Hubs)
Frequently asked questions
When does the Foreign Trade Policy 2023 expire?+
The Foreign Trade Policy 2023 has no fixed end date. Para 1.01 says FTP 2023 came into force on 1 April 2023 and continues in operation unless otherwise specified or amended.1 Earlier policies ran for five years, so DGFT now changes FTP 2023 through notifications, public notices and trade notices instead of a new policy.
Do service exporters need an IEC under FTP 2023?+
Service exporters need an IEC under FTP 2023 only to claim FTP benefits. Para 2.05(a) makes an Importer Exporter Code mandatory for exports of goods, but for services or technology it is necessary on the date of rendering services only for availing benefits under the FTP.8 A freelancer not claiming benefits needs no IEC under FTP.
Can a services company become a status holder?+
A services company can become a status holder. Para 1.25(b) of FTP 2023 makes exporters of goods, services and technology with an IEC eligible, and the One Star Export House threshold in para 1.26 is $3 million of export performance.1 From 21 August 2026, performance in two of the three preceding years can be enough.7
Does a service exporter need an RCMC?+
A service exporter needs a Registration-cum-Membership Certificate only when applying for an authorisation or any other benefit or concession under the FTP. Para 2.57(a) requires the RCMC from the competent authority in those cases, unless specifically exempted.8 Service exporters register with the relevant export promotion council to get one.
What happens to FTP benefits if a client never pays?+
Para 2.54(a) of FTP 2023 says an exporter who fails to realise proceeds within the time RBI specifies must return all benefits availed against those exports, without prejudice to other penalties.8 This links FTP benefits directly to the FEMA realisation period, so unpaid invoices can claw back benefits already claimed.
Can e-BRCs be generated in bulk under FTP 2023?+
E-BRCs can be generated in bulk. DGFT Trade Notice 12/2024-25 of 14 August 2024, effective 20 August 2024, introduced bulk upload by spreadsheet and API integration with exporters' ERP or accounting systems for e-BRC self-certification.9 This helps service exporters with many invoices each month.
Do district export plans under FTP 2023 cover services?+
District export plans under FTP 2023 can cover services. FTP 2023 asks each district to identify products and services with export potential under its District Export Action Plan, as set out in Chapter 3 on developing districts as export hubs.10 Whether a district lists your service depends on its own published plan.
This page is general information for Indian service exporters, not tax or legal advice. Rules change and outcomes depend on your facts, so confirm with a chartered accountant before acting.
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