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Finin2minBatch 08 · Source checked 14 Aug 2026
DGFT & Export FinanceUpdated 5 October 2026

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

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
1Draw the money flow from overseas debtor/import factor to NBFC factor to exporter/AD bank, with each message and ledger posting identified.
2Separate recourse and non-recourse commercial terms from regulatory reporting; both can require precise remittance evidence.
3Reconcile the factoring agreement, invoice assignment and bank remittance instruction to the same exporter and receivable population.
4Use a sandbox/UAT file for the draft DGFT process and require compliance sign-off before any live rule change.

Evidence pack

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

  1. Treating a dated policy, report, draft or portal metric as if it were the final company-specific legal conclusion.
  2. Acting before the key identifier, document, approval or counterparty record has been reconciled to the same transaction population.
  3. 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

Disclaimer: Educational and informational content only. Verify live legal, regulatory, contractual and project facts before acting.

Disclaimer

Educational and professional reference only; confirm the current law, rates and the facts of your case before relying on this page.

Educational and professional reference only — not financial, tax or legal advice. Verify the current official position from the primary source before relying on any figure, rate, provision or deadline.