DGFT Seeks Comments on Draft SOP for NBFC Factor Inward Remittances and eBRC Reporting
The Directorate General of Foreign Trade (DGFT) has invited stakeholder comments on a draft Standard Operating Procedure (SOP) for reporting Inward Remittance Messages (IRMs) connected with export transactions financed by NBFC Factors. The consultation was issued through DGFT Trade Notice No. 20/2026-27 dated 12 August 2026, titled "Draft Standard Operating Procedure (SOP) for reporting of Inward Remittance Messages pertaining to NBFC Factors". It is relevant to exporters, AD Category I banks, NBFC Factors, Export Promotion Councils and professionals who handle export-realisation compliance.
The problem the draft addresses
Export receivables are often financed or purchased by an NBFC Factor before the overseas buyer's payment is finally received through the banking channel. When the remittance data does not show that a factoring arrangement is involved, the IRM available for electronic Bank Realisation Certificate (eBRC) self-certification becomes hard to match with the underlying export invoice or shipping bill. That leads to incorrect or duplicate IRMs and avoidable reconciliation work.
The draft builds on the online eBRC self-certification framework that DGFT introduced through Trade Notice No. 33/2023-24 dated 10 November 2023 and enhanced through Trade Notice No. 12/2024-25 dated 14 August 2024.
What the draft SOP proposes
Foreign-currency proceeds remitted by a Factor
When an authorised NBFC Factor remits factoring proceeds in foreign currency to an AD Category I (AD-I) bank, the draft requires the Factor to use this exact narration in the SWIFT message:
AD-AD(P0092) EXP FACTORING PROCEED
The fixed narration lets the bank and the DGFT system identify the remittance as an NBFC Factor transaction instead of treating it as an ordinary exporter-level inward remittance.
Rupee funding against export bills
Where a Factor discounts an export bill and releases funds to the AD-I bank in Indian rupees, no SWIFT message is generated. If an exporter asks the AD-I bank for an IRM against such rupee funds, the bank is to direct the customer to approach the Factor concerned.
Exporter self-certification
Under the enhanced system, remittance data relating to NBFC Factors will be visible to exporters on the DGFT portal. Exporters can then self-certify eBRCs by matching those IRMs with the corresponding invoices or shipping bills. The proposal does not create a new levy or a separate return; it changes how factoring-linked remittance data is tagged and reconciled.
AD Category II entities
The draft also refers to the RBI's Foreign Exchange Management (Authorised Persons) Regulations, 2026 dated 30 April 2026. These regulations widen the permitted activities of AD Category II entities, including non-bank entities, to cover foreign trade transactions of up to Rs 25 lakh per transaction. Once licensed, such entities will carry out the related reconciliation activities in the DGFT system.
Who should act and how
| Stakeholder | What to check |
|---|---|
| Exporters using factoring | Whether records link the Factor, the AD-I bank, the invoice, the shipping bill and the final realisation |
| NBFC Factors | Ability to carry the prescribed SWIFT narration on every foreign-currency remittance of factoring proceeds |
| AD-I banks | Handling of IRM requests where the Factor funded the exporter in rupees |
| Advisers and auditors | Clients with factoring or bill-discounting arrangements whose eBRC records do not reconcile |
Finance teams should check whether internal records can connect the amount first received from the Factor with the later foreign-currency realisation that enters the banking system. This matters most where the party providing working capital is different from the bank through which the overseas proceeds are finally received, and where realisations arrive in parts.
Stakeholders sending comments can usefully cover clear identification of Factor transactions, treatment of rupee funding, prevention of duplicate IRMs, the matching logic for eBRC self-certification and partial realisations. DGFT's user manuals on the eBRC system are available in the Learn section of its website, and eBRC feedback can be sent to ebrc-dgft@gov.in.
The SOP is still a draft. Businesses should not treat it as a final mandatory rule until DGFT issues the final procedure. The notice and other DGFT trade notices for August 2026 are listed on the APEDA page of DGFT trade notices.
Updated on 28 September 2026: added the official Trade Notice No. 20/2026-27 link, the exact SWIFT narration, the earlier eBRC trade notices and the AD Category II provision, and dropped a 30-day comment period that could not be confirmed from the notice text.
