EPCG e-BRC: Export Obligation, Realisation and EODC in 2026

Paras Nagpal, Business Consultant, GetMyCA | Last updated: 21 October 2026

Quick Answer

e-BRC is important for EPCG export-realisation and EODC verification, but it is not the only export-realisation evidence recognised under DGFT Appendix 5C. For goods exports, the certificate also recognises export realisation from RBI's EDPMS and a Bank Certificate of Export and Realization. The current DGFT closure process uses BRC repository data, and the revised e-BRC format has applied since 13 January 2026.

If your EPCG exports are complete but BRC data is missing or mismatched in DGFT, closure can become confusing. Exporters often assume that e-BRC is the only proof required. In practice, export documents establish the transaction, while e-BRC or other accepted evidence supports the export-proceeds realisation side of the review.

This article explains how e-BRC, EDPMS, export realisation and EODC connect under the current EPCG process, and what to check before filing for closure.

Key Takeaways

• Appendix 5C recognises e-BRC, RBI EDPMS export realisation and a Bank Certificate as export-realisation evidence for goods.
• HBP 2023 Para 5.20 requires ANF 5B with prescribed documents as proof of export-obligation fulfilment.
• Trade Notice 01/2023-24 permits EPCG closure applications to be submitted online without validation. This does not remove the need for applicable supporting evidence.
• From 1 May 2025, services e-BRCs include a Mode of Export of Services field. From 13 January 2026, the e-BRC format includes GSTIN and GST invoice fields.
• From 20 August 2026, DGFT Notification 30/2026-27 amended FTP Paras 2.52 and 2.53, allowing qualifying INR export realisations to receive FTP benefits and count towards export obligations.
• In the current system, banks report Inward Remittance Messages (IRMs) to DGFT and the exporter generates the e-BRC. IRMs before the applicable bank cut-off date may follow the legacy bank-issued e-BRC process.

What Export-Realisation Evidence Does Appendix 5C Recognise?

Appendix 5C lists the following forms of evidence for export of goods:

For goods, Appendix 5C also refers to the export order or contract, Shipping Bills or third-party Shipping Bills, Bills of Export, Airways Bills or PP Receipts, Bills of Lading, Customs or bank-attested invoices, GR declaration and connected books of accounts. The certificate requires verification of relevant Shipping Bills for specific export obligation.

For services exports, Appendix 5C refers to e-BRC, RBI EDPMS realisation, a Bank Certificate of direct foreign-exchange earning, FIRCs, credit-card certificates, CA certificates for indirect sources and connected books of accounts. The exact evidence depends on the export category.

Important: “e-BRC or nothing” is not the correct way to read Appendix 5C. An exporter without an available e-BRC may still have other accepted realisation evidence, subject to the specific EPCG documentation requirements.

What Is e-BRC and Why Does It Matter?

e-BRC, or Electronic Bank Realisation Certificate, is an electronic record of export-proceeds realisation. For EPCG holders, it supports the realisation side of export-obligation review. It does not replace Shipping Bills, export records or other prescribed evidence.

FTP 2023 describes e-BRC as a mechanism through which DGFT captures export-proceeds realisation details from banks through a secured electronic mode. RBI's EDPMS is a parallel IT-based system for monitoring exports and bank reporting.

In the current process, banks transmit IRMs to the DGFT e-BRC system. The exporter reviews the IRM and matches it with the relevant invoice or Shipping Bill to self-generate the e-BRC on the DGFT portal. For IRMs dated before the applicable bank cut-off date, the bank may issue the e-BRC under the legacy process.

For an EPCG holder, export documents establish the export transaction; realisation records support the payment side. Both aspects are relevant when export obligation is reviewed for closure.

How Is EPCG e-BRC Connected with Export Obligation?

In EPCG, e-BRC connects export transactions with export-proceeds realisation. The information helps DGFT and the reviewing authority assess the realisation side of EO fulfilment. It does not replace Shipping Bills or become the complete calculation of export obligation.

Export transaction → Shipping Bill → Export proceeds realised → e-BRC / EDPMS / other accepted evidence → EO fulfilment review → EODC

Export obligation and export realisation are related but not identical. A Shipping Bill records the export transaction; e-BRC or other accepted evidence addresses receipt of proceeds. The closure review considers the relevant records together.

For a broader explanation of EPCG eligibility, export obligation and scheme mechanics, see GetMyCA's EPCG Scheme in India guide.

How Can Exporters Reconcile e-BRC, EDPMS and EPCG Records?

Before filing EODC, compare Shipping Bills, invoices, IRMs and export-realisation records against DGFT BRC repository data. Where figures differ, identify the specific scenario and apply the applicable EPCG procedure.

How Does e-BRC Appear in the EPCG Closure Process?

During online EPCG closure, the DGFT exporter manual instructs applicants to open Realisation Details, search the BRC repository, select the required BRCs, add them and verify the export-obligation fulfilment summary.

1. Open the EPCG closure application on the DGFT portal.
2. Complete utilisation details; Shipping Bills and export records are reviewed before the realisation stage.
3. Open Realisation Details and use “Search BRC detail in Repository” to select applicable BRCs.
4. Review the export-obligation fulfilment summary and verify the figures.
5. Submit ANF 5B with prescribed documents as proof of EO fulfilment.
6. The Regional Authority examines the application before issuing EODC.

The “without validation” route permits online submission without validation. It does not remove the need for evidence; the Regional Authority still examines supporting documents through the applicable process.

What If EPCG e-BRC Data Is Missing or Mismatched?

First compare the Shipping Bill, invoice details, bank-reported IRM and DGFT BRC repository. Do not assume that a mismatch automatically means the export cannot be considered. Treatment depends on the records and the applicable EPCG procedure.

If e-BRC data does not appear

Check whether the bank has reported the IRM and whether the exporter has completed the self-generation step. If the IRM is before the bank's applicable cut-off date, check whether the legacy bank-issued e-BRC process applies.

If the data does not match

Compare the Shipping Bill number, export value, invoice details, realised amount and bank-reported IRM information. If the issue remains, review the specific reconciliation scenario before filing.

If online validation fails

Trade Notice 01/2023-24 permits submission without validation. The Regional Authority examines the supporting documents during closure.

What if the export was made through a third party?

Under HBP 2023 Para 5.10, the Shipping Bill or Bill of Export, GST invoice and e-BRC or RBI EDPMS export-realisation evidence should be in the name of the third-party exporter. The export documents should indicate the authorisation holder and supporting manufacturer, where applicable, along with the EPCG authorisation number. The goods must be manufactured as required under the applicable conditions, and proceeds must be transferred through normal banking channels from the third-party exporter's account to the authorisation holder's account.

What Changed in e-BRC and EODC Processing in 2025 and 2026?

May 2025: Mode of Export of Services

DGFT Trade Notice 02/2025-26 introduced a Mode of Export of Services field in the e-BRC format for the Services Export category. It applies to relevant e-BRCs generated on or after 1 May 2025 and identifies the applicable GATS mode: Cross-Border Supply, Consumption Abroad, Commercial Presence or Presence of Natural Persons.

January 2026: GST details added to e-BRC

DGFT Public Notice 42/2025-26 amended Appendix 2U to add GSTIN, GST Invoice Number and GST Invoice Date to the e-BRC format. The change was operationalised from 13 January 2026.

August 2026: INR export-realisation rules expanded

DGFT Notification No. 30/2026-27 dated 20 August 2026 amended FTP Paras 2.52 and 2.53. Subject to the revised conditions, qualifying INR export realisations through prescribed banking channels can receive FTP benefits and count toward export obligations. ACU and Nepal/Bhutan transactions remain subject to their specific provisions, and exports to Iran remain subject to FTP Para 2.19. EPCG holders with INR-denominated contracts should check whether their transactions qualify.

HBP 2023 Para 5.11 permits EPCG export proceeds in freely convertible currency or Indian Rupees under FTP Para 2.53. The 2026 amendment is therefore relevant to qualifying INR realisations.

August 2026: physical duty challans removed for EODC

For voluntary duty payments made on or after 1 August 2026, DGFT uses authenticated Customs/ICEGATE payment data for AA and EPCG EODC processing, reducing the need for physical duty-payment challans. This is a separate EODC process update, not an e-BRC amendment.

What Should an EPCG Holder Check Before Applying for EODC?

Before filing EODC, reconcile export records, export realisation, EO fulfilment and prescribed supporting documents. Review the DGFT repository and EO fulfilment summary for material discrepancies.

• ? EPCG authorisation details confirmed
• ? Relevant Shipping Bills identified and export values reconciled
• ? e-BRC or other applicable realisation evidence checked against the DGFT BRC repository
• ? Specific EO fulfilment summary verified
• ? Average EO position checked separately where applicable under HBP 5.13
• ? Third-party export documentation checked under HBP 5.10, where applicable
• ? Appendix 5C evidence requirements reviewed
• ? ANF 5B and supporting documents ready
• ? INR exports checked against Notification 30/2026-27, where applicable
• ? Any data mismatch resolved or without-validation route identified

HBP 5.20 states that the Regional Authority should ordinarily process redemption applications within 30 days and identify shortcomings in one go, with EO discharged within 30 days of receiving complete documents.

What to Do Next If EPCG e-BRC Data Is Not Matching?

First reconcile the Shipping Bill, invoice, bank IRM and DGFT BRC repository records. If the discrepancy remains or involves third-party exports, INR realisation or an EO shortfall, review the applicable EPCG procedure before submitting the EODC application.

For professional support with EPCG documentation, EO tracking and EODC redemption, see GetMyCA's EPCG advisory support.

Frequently Asked Questions

Is e-BRC the only export-realisation evidence accepted for EPCG EODC?

No. For export of goods, Appendix 5C recognises e-BRC, export realisation from RBI's EDPMS and a Bank Certificate of Export and Realization. The applicable evidence depends on the transaction and EPCG documentation requirements.

Can EPCG closure be submitted without online validation?

Yes. Trade Notice 01/2023-24 permits EPCG closure applications to be submitted online without validation. Supporting documents are still required and may be examined by the Regional Authority.

What should I do if my BRC is not appearing in the DGFT repository?

Check whether the bank has reported the IRM and whether you have completed the e-BRC self-generation step by matching the IRM with the relevant invoice or Shipping Bill. If the issue remains, use the applicable DGFT support or without-validation closure route.

Does the May 2025 e-BRC update apply to all EPCG exports?

No. Trade Notice 02/2025-26 introduced a Mode of Export of Services field for the Services Export category only. It applies to relevant e-BRCs generated on or after 1 May 2025.

What changed in the e-BRC format from January 2026?

DGFT Public Notice 42/2025-26 added GSTIN, GST Invoice Number and GST Invoice Date to the e-BRC format, operationalised from 13 January 2026.

What did DGFT Notification 30/2026-27 change?

It amended FTP Paras 2.52 and 2.53, expanding the circumstances in which qualifying INR export realisations can receive FTP benefits and count toward export obligations, subject to the revised conditions.

Sources and References

• DGFT Appendix 5C: Certificate for Grant of EODC of EPCG Authorisation
• DGFT official portal for FTP 2023 and HBP 2023
• DGFT eBRC FAQs, Version 1.1
• PIB: Physical duty-payment challans removed for AA/EPCG EODC
• DGFT Trade Notice and Public Notice index for the latest e-BRC and EODC instruments

Disclaimer: This article is for educational and general informational purposes only. It does not constitute legal or tax advice. Foreign-trade and DGFT requirements can change. Consult a qualified Chartered Accountant or export-compliance professional for advice specific to your situation.

Reviewed by: GetMyCA Export & Compliance Advisory Team | Last reviewed: 5 October 2026