The DGFT’s amendment to the Electronic Bank Realisation Certificate (eBRC) format, effective 13 January 2026, transforms eBRC from a mere forex realisation proof into a central control point for GST, FEMA and export-incentive compliance. By mandating GSTIN, GST Invoice Number and GST Invoice Date in every eBRC, the government has effectively created a real‑time digital loop between DGFT systems, banks and the GST Network (GSTN), significantly tightening monitoring of export realisation timelines and zero‑rated benefits.
Background: eBRC and Policy Change
The eBRC is an electronic certificate issued by authorised dealer banks through DGFT’s online system, evidencing realisation of export proceeds and acting as the primary document for export incentives, verification and statistics. Appendix 2U of the Handbook of Procedures, 2023 prescribes the standard eBRC format for all banks and is the legal backbone for uniform reporting of export realisations.
Through Public Notice No. 42/2025‑26 dated 09 January 2026, DGFT has amended Appendix 2U to strengthen the eBRC framework by adding new GST‑linked fields and restructuring existing fields. The revised Appendix 2U is to be operationalised for all eBRCs generated on or after 13 January 2026, meaning every post‑implementation export realisation will carry invoice‑level GST data.
Key Changes in the eBRC Format
The revised format introduces three mandatory GST‑related fields in every eBRC: GSTIN of the exporter, GST Invoice Number and GST Invoice Date. This change breaks the earlier combined “Address/GSTIN” field into a pure address field and a separate, structured GST identification set, improving clarity and machine‑readability.
The new format is fully system‑generated through DGFT and is designed for online validation, including QR‑code based verification and cross‑checking via the DGFT portal by authorities and stakeholders. Because GST invoice particulars now sit inside the eBRC, authorities can match export realisation, shipping documentation, and GST returns on a one‑to‑one basis at the invoice level, closing the loop from invoice to foreign currency inflow.
Creation of a Digital Compliance “Tripwire”
By embedding GSTIN, invoice number and date in eBRC data, DGFT systems can feed enriched realisation information to the GST Network (GSTN) and other back‑end analytics platforms. This enables automated data triangulation between GSTR‑1, shipping bills, ICEGATE records and eBRCs, allowing authorities to detect mismatches in value, tax treatment or timing far more quickly than manual scrutiny.
The system can compute the time elapsed from the GST invoice date or export date to the date of realisation recorded in the eBRC and flag invoices breaching FEMA or GST time limits. With this level of automation, it becomes feasible for GST authorities to generate system‑triggered alerts, risk scores or even notices when export proceeds are not realised within the prescribed period or when realisation amounts diverge from declared zero‑rated supplies.
Statutory Time Limits and Legal Consequences
Under the GST framework, exports are treated as zero‑rated supplies, but this benefit rests on the condition that sale proceeds are realised within specified timelines and that the exports are either under Letter of Undertaking (LUT) without payment of tax or on payment of IGST with refund mechanism. Non‑realisation within the permissible period can trigger reversal of zero‑rating, refund clawback and exposure to interest under Section 50 of the CGST Act.
Under Rule 96A of the CGST Rules, exports made under LUT without payment of IGST must have consideration realised within one year from the date of invoice, or within an extended period allowed by the Commissioner; failing this, the exporter becomes liable to pay IGST plus interest from the date of invoice. Rule 96B provides that if export proceeds against supplies for which refund of IGST or accumulated ITC has been granted are not realised within the period permitted under FEMA, such refunds can be recovered along with applicable interest.
FEMA / RBI Realisation Window and Extension
Under the Foreign Exchange Management (Export of Goods & Services) Regulations, exporters are generally required to realise and repatriate export proceeds within a prescribed period from the date of export. Historically this period was nine months for most exports, forming the base for many GST‑FEMA linkages and refund validation checks.
The Reserve Bank of India, through the Foreign Exchange Management (Export of Goods and Services) (Second Amendment) Regulations, 2025 and related press communication dated 14 November 2025, has temporarily extended the maximum period for realisation and repatriation from nine months to fifteen months from the export date. While this provides breathing space to exporters, the extended 15‑month window still remains a hard outer limit for retaining zero‑rated benefits and for avoiding refund clawbacks where export proceeds remain unrealised.
How the New eBRC Framework Enables Automated GST Monitoring
The revised eBRC format aligns practical banking realisation records with statutory GST data, enabling end‑to‑end digital surveillance of export transactions. Authorities can now algorithmically tie each GST export invoice to its corresponding forex inflow and measure timeliness and completeness of realisation.
Key features of this emerging monitoring framework include:
- Real‑time data integration: Banks upload eBRCs to DGFT; the enriched data set with GST fields can then be shared or accessed by GSTN and analytics engines for automated risk scoring and reconciliation.
- Timeline tracking: Systems can count days between GST invoice/export date and realisation date recorded in the eBRC, instantly identifying invoices crossing one‑year LUT limits or the 15‑month FEMA window.
- Targeted enforcement: Mismatches or delays can be used to generate system‑based notices for recovery of IGST, ITC refunds or to initiate deeper investigations into alleged trade‑based tax evasion or round‑tripping.
Practical Risks and Challenges for Exporters
While the policy intent is improved compliance and data integrity, exporters face heightened operational and financial exposure under this tightly linked digital ecosystem. The risk profile shifts from post‑facto, inspection‑driven scrutiny to continuous, system‑driven surveillance.
Key challenges include:
- Automated demand exposure: Once systems are configured, notices or alerts may appear swiftly upon expiry of LUT or FEMA timelines, with limited initial consideration for commercial disputes, quality issues or macro‑events delaying remittances.
- Working capital strain: Exporters facing delayed payments must potentially fund IGST plus interest liabilities while receivables remain unpaid, creating a double burden on cash flows.
- Risk to incentives and ratings: Mismatch between eBRC data and GST declarations can result in denial or delay of export incentives like RoDTEP, duty drawback or other DGFT benefits, and may also impact internal risk ratings used by tax authorities.
- Regulatory consequences: Persistent non‑realisation or repeated data mismatches may lead to stricter actions such as suspension of Importer Exporter Code (IEC), restriction or withdrawal of LUT facility, or increased frequency of audits.
Essential Risk‑Mitigation Strategies
In this environment, exporters must treat GST‑linked realisation tracking as a core part of export operations rather than a periodic compliance add‑on. Strengthening systems, processes and coordination with banks becomes critical to avoid avoidable demands and interest costs.
Key strategies include:
- Robust monthly reconciliation
- Reconcile GSTR‑1 export invoices with shipping bills and the DGFT eBRC repository each month to ensure that every reported export invoice is backed by a corresponding eBRC entry with correct GSTIN, invoice number and date.
- Identify and resolve discrepancies in values, currencies, invoice dates or buyer details promptly to avoid systemic flags or refund delays.
- Disciplined credit and buyer management
- Design export credit terms to comfortably sit within the 15‑month FEMA window and, in practice, substantially earlier (for example, 150–180 days) to leave room for dispute resolution or extension processes where required.
- Use structured follow‑up systems, reminder tools and contractual clauses to encourage buyers to remit on time, especially for high‑value or high‑risk jurisdictions.
- Close coordination with banks
- Ensure authorised dealer banks capture GSTIN, GST Invoice Number and GST Invoice Date correctly at the time of eBRC generation, as incorrect mapping can lead to mismatched records even when funds have been realised.
- Obtain copies or downloads of eBRCs soon after issue and incorporate them into internal reconciliation workflows and document management systems.
- Use of statutory extensions and condonation
- Where delays are anticipated, apply proactively for extension of LUT realisation period under Rule 96A with the jurisdictional GST Commissioner, and for FEMA realisation extension with RBI (through the bank) before expiry of the standard period.
- Maintain detailed documentation demonstrating genuine commercial reasons, disputes, or force majeure to support requests and defend cases if proceedings are initiated.
- Technology‑enabled monitoring
- Upgrade ERP and compliance software to carry GST invoice‑wise flags, expected realisation dates and automated alerts at pre‑defined milestones (for example, 6, 9, 12 and 15 months).
- Where possible, integrate ERP with GST filing tools, bank statement feeds and eBRC download utilities to minimise manual data entry and reduce reconciliation errors.
Re‑imagining Export Compliance in the Digital Era
The alignment of DGFT, banking and GST data through the revised eBRC format signals a broader shift toward holistic, data‑driven oversight of India’s export ecosystem. Authorities are moving to a paradigm where every export invoice is expected to map seamlessly from GST returns to shipping documents and finally to actual forex realisation within statutory timelines.
Exporters that adapt by investing in stronger internal controls, digital tools and disciplined receivables management will be better positioned to retain zero‑rated benefits and avoid sudden tax and interest shocks. Those who continue with fragmented, manual or ad‑hoc approaches to export documentation and follow‑up may face increased scrutiny, denial of incentives and working capital stress that can erode margins and competitiveness in global markets.
Disclaimer :- Only for Educational Purpose.
FCA, CWM (AAFM-US), CBV, CIFRS, R-ID, B.COM (H), RV* (IBBI)
Practising Chartered Accountant in Delhi NCR Since 2011. He can be contacted at ankitgulgulia@gmail.com or +91-9811653975.