Draft DGFT SOP for Factoring Remittances: Export-Factor, Import-Factor and AD-Bank Workflow
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
- Export factor, import factor and AD-bank roles need a transaction map; labels alone do not determine the reporting outcome.
- Draw the money flow from overseas debtor/import factor to NBFC factor to exporter/AD bank, with each message and ledger posting identified.
- The practical control is to separate the dated policy/source statement from the company-specific legal, contractual and operational conclusion.
Current position
Control and action map
| # | Control / action |
|---|---|
| 1 | Draw the money flow from overseas debtor/import factor to NBFC factor to exporter/AD bank, with each message and ledger posting identified. |
| 2 | Separate recourse and non-recourse commercial terms from regulatory reporting; both can require precise remittance evidence. |
| 3 | Reconcile the factoring agreement, invoice assignment and bank remittance instruction to the same exporter and receivable population. |
| 4 | Use a sandbox/UAT file for the draft DGFT process and require compliance sign-off before any live rule change. |
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
Where an import factor remits a pooled amount, the Indian factor prepares a receivable-allocation schedule before the bank message is sent rather than trying to reconstruct the split after an eBRC exception.
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.