DGFT Draft SOP for NBFC Factor Inward Remittance Reporting: What Factors Should Prepare
By Ravi Sisodia · Reviewed by CA Divyanshu Sengar · Updated 5 October 2026
Current-source controlled update for finance, legal, compliance and operating teams.
2-minute summary
- Trade Notice 20/2026-27 remains a draft consultation at the cut-off, so readiness work should not be represented as a final legal obligation.
- Gap-assess current factoring remittance messages against the draft text, including the proposed AD-AD(P0092) EXP FACTORING PROCEED identifier.
- The 2026 draft proposes a specialised message treatment for NBFC factoring proceeds; it should be tested in UAT rather than represented as final production law.
Current position
Trade Notice 20/2026-27 remains a draft consultation in the official DGFT/APEDA notice register through the 5 October 2026 cut-off. Existing eBRC/FEMA rules continue to govern live transactions.
Control and action map
| # | Control / action |
|---|---|
| 1 | Gap-assess current factoring remittance messages against the draft text, including the proposed AD-AD(P0092) EXP FACTORING PROCEED identifier. |
| 2 | Document which party sends the foreign-currency remittance, which bank receives it, and who owns exporter-level invoice/shipping-bill mapping. |
| 3 | Prepare exception handling for missing or duplicated IRMs without changing production logic until a final DGFT instrument is issued. |
| 4 | Keep a change log so any final SOP can be compared line-by-line against the draft before deployment. |
Evidence pack
- factoring agreement and assigned receivable schedule
- bank/SWIFT or remittance-message record
- export invoice / shipping bill / SOFTEX evidence
- DGFT eBRC / IRM reconciliation
- exception, rejection and correction log
Worked example
An NBFC factor can configure a test message template and bank coordination checklist now, but keeps the production switch disabled because the consultation text is not the final operative SOP.
Common mistakes
- Treating a dated policy, report, draft or portal metric as if it were the final company-specific legal conclusion.
- Acting before the key identifier, document, approval or counterparty record has been reconciled to the same transaction population.
- Failing to preserve the version and date of the evidence used, making later correction or audit review difficult.
Is the 12 August 2026 NBFC-factor SOP final?
No. The official notice register still describes Trade Notice 20/2026-27 as inviting comments on a draft SOP at this cut-off.
Can a factor wait for the final SOP before doing anything?
It can prepare data maps, bank coordination and UAT controls now, while keeping live production aligned to current DGFT eBRC and FEMA rules.
Official sources
- DGFT / Department of Commerce via APEDA - Trade Notice 20/2026-27 - Draft SOP for IRMs pertaining to NBFC Factors (Trade Notice 20/2026-27; 12 Aug 2026)
- Directorate General of Foreign Trade - Pilot Launch of upgraded eBRC system for self-certification (Trade Notice 33/2023-24; 10 Nov 2023)
- Directorate General of Foreign Trade - Self-Certified eBRC Generation Guidelines (Version 1.0; 10 Nov 2023)
- Reserve Bank of India - FEMA notifications - Export and Import of Goods and Services Regulations, 2026 (FEMA notification index; 2026)
Disclaimer
Educational and professional reference only; confirm the current law, rates and the facts of your case before relying on this page.