Executive Summary

The Directorate General of Foreign Trade (DGFT) issued Notification No. 27/2026-27, establishing a formal regulatory framework under the Foreign Trade Policy (FTP) 2023 for inventory-based cross-border e-commerce exports. The notification enables Exporters-on-Record (EoRs) to procure and manage export-only inventory on behalf of underlying Sellers-on-Record (SoRs), while establishing payout timelines and governing export incentive distribution.

Regulatory Background

Cross-border e-commerce exports previously faced operational hurdles because small manufacturers and artisans (Sellers-on-Record) often lacked the infrastructure to handle customs clearances, foreign exchange realisation, and international logistics. The updated framework clarifies how inventory fulfillment entities (Exporters-on-Record) can legally clear goods while preserving export benefits for the underlying seller.

What Has Changed?

The framework formally recognises the dual EoR–SoR operating model. EoRs can aggregate, store, and export inventory from centralized hubs against confirmed export orders. The framework mandates that payments from the EoR to the SoR must be settled within 7 days of goods acceptance, supporting liquidity for underlying sellers.

Key Changes Comparison

Who Will Be Affected?

• E-Commerce Aggregators and Global Export Platforms
• Exporters-on-Record (EoRs) and Logistics Hub Operators
• Sellers-on-Record (SoRs), MSMEs, and Artisans
• Customs Brokers and Foreign Trade Compliance Teams

Effective Date & Applicability

• Date of Issue: 05 August 2026
• Effective Date: 05 August 2026
• Applicability: All entities operating inventory-backed cross-border e-commerce export models under FTP 2023.

Compliance Impact

• Contractual Alignment: Agreements between EoRs and SoRs must incorporate the statutory 7-day payout clause and explicit incentive-sharing terms.
• Customs Documentation: EoR entities must align shipping bill filings to link SoR GSTIN and exporter credentials for complete traceability.
• Inventory Segregation: Fulfillment hubs must maintain dedicated physical and digital segregation of export-only inventory.

KGS Practical Takeaway: This update facilitates global market access for MSMEs. Logistics operators and aggregators acting as EoRs must establish robust ERP and inventory reconciliation systems to maintain complete audit trails and satisfy statutory settlement schedules.

Source / Reference

• Authority: Directorate General of Foreign Trade (DGFT), Ministry of Commerce and Industry
• Document: Notification
• Reference No.: Notification No. 27/2026-27
• Date: 05 August 2026
• Official Source: DGFT Official Portal — Notifications Section