eBRC Generation on DGFT Portal – Detailed Process, Advisory References, Service Exports Clarification & Professional Guide
Regulatory Background and Advisory Framework
The Electronic Bank Realisation Certificate (eBRC) is a key compliance document evidencing foreign exchange realisation against exports. It is relied upon for:
- Benefits under the Foreign Trade Policy (FTP)
- GST refunds (IGST refunds, LUT exports)
- FEMA compliance and post-export audits
With the introduction of self-certification of eBRCs and further enhancements vide Trade Notice No. 12/2024-25 dated 14 August 2024, DGFT has significantly re-engineered the eBRC ecosystem by:
- Integrating banks through APIs
- Enabling exporters to self-generate eBRCs
- Introducing bulk upload functionality for large exporters
Under the revised framework, banks upload Inward Remittance Messages (IRMs), while exporters bear the responsibility of accurate mapping, declaration, and compliance.
IRM – The Starting Point of eBRC
An IRM (Inward Remittance Message) is generated by the Authorised Dealer bank upon receipt of foreign exchange. These IRMs are automatically transmitted to the DGFT system and made available to exporters in the IRM / ORM Repository.
Key points emerging from DGFT advisories and user manuals:
- IRMs are bank-originated and system-controlled
- Exporters cannot modify IRM particulars
- eBRCs can be generated only up to the available IRM balance
- Partial utilisation of IRMs is permitted
Modes of eBRC Generation on DGFT Portal
DGFT currently provides two methods for generation of eBRCs. Both operate under identical validation rules.
a) Single eBRC Generation (Manual Mode)
This mode involves selection of one or more IRMs and mapping them individually with:
- Shipping Bills (for goods)
- Invoices / Softex (for services)
It is typically preferred where:
- Export volumes are limited
- Adjustments like commission, freight, or discounts require careful review
b) Bulk eBRC Generation (Spreadsheet Upload)
Introduced to improve efficiency, this mode allows exporters to generate multiple eBRCs simultaneously by uploading a DGFT-prescribed Excel template.
DGFT has clarified that: Bulk upload is a facilitation measure only. All business rules applicable to manual eBRC generation apply equally to bulk uploads.
IRM–eBRC Mapping: Key Legal and Practical Clarifications
- Multiple IRMs can be clubbed into a single eBRC, provided:
- Same currency
- Same bank and same bank account
- One IRM can be split across multiple eBRCs
- Multiple shipping bills can be mapped to one eBRC
- One shipping bill can be used across multiple eBRCs of different banks (common in tranche-based realisations)
Purpose Codes and Clubbing Rules – High-Risk Compliance Area
DGFT user manuals repeatedly caution exporters on purpose code validation:
- P0103 (Advance Payment) enjoys special treatment and can be clubbed with eligible purpose codes
- No two purpose codes can be clubbed except where P0103 is involved
- eBRC generation is not permitted for P0101 and P0108
- Service exports are subject to purpose code–SAC code alignment
eBRC for Export of Services – Clarification on Softex and Non-IT Services
The revamped eBRC framework expressly covers export of services, including:
- IT / ITeS services
- Non-IT services
DGFT has consciously designed separate workflows for goods and services. For services, exporters must select:
- Export Type → Services
- Category → IT or Non-IT
While Softex is required in certain IT/software cases under RBI/STPI regulations, DGFT does not mandate Softex for all service exports.
FAQ: eBRC for Export of Services (Including Non-IT Services Without Softex)
To address persistent doubts in practice, the following clarifications are summarised below.
A. Can eBRC be generated for export of services?
Yes. eBRC can be generated for export of services, including both IT / ITeS and Non-IT services, under the DGFT self-certification framework.
B. Is Softex mandatory for generation of eBRC for services?
No. Softex is required only where mandated under RBI / STPI / SEZ regulations. DGFT does not prescribe Softex as a universal requirement for service exports.
C. Can eBRC be generated for Non-IT services where Softex number is not generated?
Yes. For Non-IT services, eBRC can be generated by mapping IRMs with service invoices and correct purpose codes and SAC codes. The DGFT portal does not require Softex details in such cases.
D. What details are required for Non-IT service eBRC generation?
- IRM uploaded by the bank
- Invoice number and date
- SAC code aligned with service description
- Purpose code reflecting service export
- Port code (as per system requirement)
E. Do IRM clubbing rules differ for service exports?
No. The same IRM clubbing rules apply to goods and services, including currency, bank, and account consistency.
F. Can one IRM be used to generate multiple eBRCs for services?
Yes. Partial utilisation of IRMs is permitted, and multiple eBRCs can be generated until the IRM balance is fully utilised.
G. What are common reasons for failure of eBRC generation for services?
Incorrect purpose codes, SAC mismatches, invoice date inconsistencies, and incorrect assumption that Softex is mandatory for Non-IT services.
H. Is eBRC for services relevant for GST and FEMA compliance?
Yes. eBRC is frequently relied upon during GST refund scrutiny, FEMA audits, and FTP benefit verification.
Post-Generation, Utilisation and Cancellation
Once generated, eBRCs:
- Are stored in the DGFT repository
- Are accessible to banks and authorities
- Can be downloaded by exporters
Cancellation is permitted only for:
- Self-generated eBRCs
- eBRCs not utilised for any incentive, refund, or benefit
Practical Checklist
a. Before eBRC Generation
- Reconcile IRMs with bank statements
- Verify purpose codes at remittance stage
- Check invoice / shipping bill dates
b. During eBRC Generation
- Ensure correct IRM clubbing
- Validate deductions (commission, freight, insurance)
- Avoid excess utilisation of IRMs
c. For Service Exports
- Confirm whether Softex is applicable
- Validate SAC–purpose code alignment
- Preserve service agreements and invoices
d. After eBRC Generation
- Download and archive eBRCs
- Track IRM utilisation reports
- Cross-check with GST refund claims
Conclusion
The shift to self-certified eBRCs improves efficiency but significantly increases compliance responsibility for exporters and their advisors. For professionals and taxpayers, disciplined IRM reconciliation and documentation is now indispensable to mitigate future disputes under GST, FTP, and FEMA regimes.
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Author’s Note: The views expressed are based on the current DGFT portal functionality and system disclosures. Field-level implementation may vary. For any query related to above article, or if you face any issue in Income Tax, GST, SEZ, STPI, MCA compliances etc., especially in cases involving legal proceedings, notices, litigation, or demand matters. Please feel free to contact us at the details mentioned below:
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