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Advance Authorisation: Export Obligation Period of 18 Months, Extensions, Clubbing, the EODC and Regularisation of Default

The export obligation period is 18 months from issue (paragraph 4.40(a) of the Handbook), 24 months or the contracted duration for defence, military store, aerospace and nuclear...

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September 5, 2026
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Last updated: September 2026Verified against: Government sources

An Advance Authorisation holder must fulfil the export obligation and then close the file with an Export Obligation Discharge Certificate (EODC). Paragraph 4.22 of the Foreign Trade Policy, 2023 leaves the period for fulfilling the obligation and its extension to the Handbook of Procedures, 2023. Paragraph 4.40(a) of the Handbook prints 18 months from the date of issue of the Authorisation, extendable in the ways set out below, and paragraph 4.36 sets strict limits on clubbing. This guide follows the obligation through to discharge or regularisation. For the scheme itself see our article on paragraphs 4.00 to 4.03 and 4.05, and for issue and import validity see how an Advance Authorisation is issued.

This article is based on the chapter-wise text of the Foreign Trade Policy, 2023 published on the DGFT website, as consulted on 2 October 2026; the copy carries no "updated up to" date. The procedure is taken from Chapter 4 of the Handbook of Procedures, 2023 as published on the DGFT website (file of July 2026), consulted on 2 October 2026. Later Notifications, Public Notices and Trade Notices should be checked before you act. If a deadline is close and you want the position reviewed, our legal consultation service can help.

The export obligation period: paragraph 4.40

CasePeriodParagraph
General rule18 months from the date of issue of the Authorisation4.40(a)
Supplies to projects in India under Chapter 7 or projects abroadCo-terminous with contracted duration of project execution, or 18 months, whichever is more4.40(b)
Defence, military store, aerospace and nuclear energy24 months from issue, or co-terminous with the contracted duration of the export order, whichever is more4.40(c)
Items otherwise prohibited for export (Chapter 7 and 15)90 days from clearance of the import consignment; no extension4.05(i)-(ii)
Wheat flour (atta)180 days from clearance of each import consignment; no extension4.05(iii)

The period starts from the date of issue unless otherwise specified (4.40(a)). Our article on paragraph 4.22 of the Policy covers the Policy's pointer to the Handbook.

Extensions and composition fees

Under paragraph 4.40(d), for authorisations issued under Appendix 4J an extension of the obligation period is allowed for not more than half the stipulated period, with a composition fee. Paragraph 4.40(e) lets the Regional Authority consider one extension of up to six months from expiry, with a fee, on a self-declaration that unutilised imported or domestically procured inputs are available; 4.40(f) allows a further six months. Under no circumstance can the extension go beyond 12 months from the date of expiry of the obligation period.

CIF value of Advance AuthorisationFirst six-month extension (4.40(e))Second six-month extension (4.40(f))
Up to Rs 2 croresRs 5,000Rs 10,000
More than Rs 2 crores to Rs 10 croresRs 10,000Rs 20,000
Above Rs 10 croresRs 15,000Rs 30,000

Paragraph 4.40(g) extends the period automatically, without composition fee, for the length of any ban or restriction imposed on the export product after the authorisation was issued. Paragraph 4.40(k) sets a different scale for implementing "PRC decisions" involving a composition fee: Rs 25,000, Rs 50,000 and Rs 1,00,000 for the three value bands, with no refund of earlier fees.

Some provisions are dated and time-bound, not the standing rule: the automatic six-month extension for periods expiring between 01.02.2020 and 31.07.2020 (4.40(i)); the extension to 31.12.2021 for periods expiring between 01.08.2020 and 31.07.2021, with 5% additional export obligation (4.40(j)); and the automatic extension up to 31.08.2026 for periods expiring between 01.03.2026 and 31.05.2026 (4.40(l)). Customs may allow provisional clearance of an export consignment on documentary evidence that an extension has been applied for (4.41).

Monitoring and the EODC: paragraphs 4.43, 4.46 and 4.47

  • Within six months from expiry of the obligation period the holder files an application online, linking the shipping bills to the authorisation, failing which the Regional Authority may initiate action by a show-cause notice under the Act (4.43(b)). Where shipping bills are non-EDI or the supplies are under Chapter 7, details are filed manually within two months of expiry (4.43(d)).
  • Realisation evidence. e-BRC or export realisations from the RBI's EDPMS are linked within six months from expiry or per the realisation period prescribed by the RBI (4.43(e)).
  • Application. The EODC application is made online in ANF 4F with the prescribed documents (4.46, 4.47(b)).
  • Issue. On being satisfied that the obligation is fulfilled, the Regional Authority may issue the EODC or Redemption Certificate and forward a copy to Customs at the port of registration (4.47(b)). A Bond Waiver Certificate is available where exports were made first (4.47(a)). Redemption does not stop Customs from random checks or action for misrepresentation found later (4.47(c)).
  • Default. If the holder fails to complete the obligation or to submit information, the Regional Authority enforces the conditions and the undertaking and initiates penal action, including refusal of further authorisation (4.43(f)); see section 11 of the Act.

Our article on monitoring and redemption explains each step.

Clubbing: paragraph 4.36

Clubbing is for redemption or regularisation only; no further import or export is allowed after clubbing (4.36(iii)). The main conditions:

PointRule
RequestIn ANF-4C to the Regional Authority that issued the authorisations (4.36(ii))
Authorisations eligibleNo clubbing of authorisations issued on or before 31st March 2009 (4.36(i)); only authorisations under which similar duty exemption has been availed (4.36(v))
Issue windowOnly authorisations issued within 24 months of the earliest one's issue (4.36(vi))
Imports countedOnly imports made within 30 months of the earliest issue; later imports are regularised under paragraph 4.49 (4.36(vi))
Exports countedOnly exports made within 48 months of the earliest issue (4.36(vi))
Value additionMinimum value addition as prescribed continues, calculated on total CIF and total FOB after clubbing (4.36(xi), (xii))
Barred casesMisrepresentation or fraud noticed by the Regional Authority; EODC or redemption letter already issued; adjudication orders already passed (4.36(xiv))

After clubbing, the authorisations are deemed one authorisation for all purposes (4.36(xii)). See our article on clubbing of Advance Authorisations.

Regularisation of bona fide default: paragraphs 4.49 and 4.50

Where the obligation is fulfilled in value but short in quantity, the holder pays customs duty on the unutilised value with interest as notified by the Department of Revenue, and, for a restricted import item, an amount equal to 10% of the CIF value of the unutilised imported material (4.49(a)); that 10% does not apply if the material was importable without an authorisation on the date of import or procurement. Where the obligation is fulfilled in quantity but short in value, no penalty arises if the minimum value addition is achieved; otherwise 1% of the shortfall in FOB value is deposited (4.49(b)). An exporter who has made no import under the authorisation and cannot complete the obligation may get it cancelled and apply for drawback, after Customs permission to convert shipping bills (4.49(e)). Customs duty with interest is paid online within 30 days of demand (4.50(a)); suo motu payment is allowed. Payment is without prejudice to Customs action (4.50(g)). See paragraphs 4.49 and 4.50.

A practical example

Himalayan Knits, an invented manufacturer exporter, holds an Advance Authorisation issued on 1 June. Its export obligation period of 18 months runs from that date (paragraph 4.40(a)). It is short of exports at month 18, so it asks for one extension of up to six months with the composition fee for its CIF band and a self-declaration that unutilised inputs are available (4.40(e)); a further six months is possible on the higher fee under 4.40(f), but never beyond 12 months from the original expiry. Within six months from the end of the period it files the EODC application in ANF 4F, linking its shipping bills (4.43(b)). If it is short in quantity but not value, it regularises under paragraph 4.49(a) by paying duty and interest.

Need help closing an authorisation?

Missed extension dates and unlinked shipping bills turn into show-cause notices. Our legal consultation service can review the position before a period ends, and our dispute resolution team can assist with a notice or demand.

Key takeaways

  • The general export obligation period is 18 months from issue (paragraph 4.40(a) of the Handbook).
  • Extensions are limited: two of six months each, and nothing beyond 12 months from expiry (4.40(e), (f)).
  • File the EODC application within six months from expiry (4.43(b)).
  • Clubbing is for redemption only and has 24-month, 30-month and 48-month limits (4.36(vi)).
  • Dated relaxations in 4.40(i), (j) and (l) are time-bound.

Read next

Disclaimer: Based on the chapter-wise text of the Foreign Trade Policy, 2023 and the Handbook of Procedures, 2023 published on the DGFT website, and on the later Notifications named in this article, as consulted on 2 October 2026. The copies carry no "updated up to" date. Notifications, Public Notices, Trade Notices, the ITC(HS) schedules, Appendices and forms change often; the current text on the DGFT website should be checked before acting. This article is general information, not legal advice; check the official text before acting.

Quick recapKey facts & short answers

Key Facts About Advance Authorisation

  • Applies in: All states across India, under the relevant central law.
  • Mode: Mostly online via the official government portal.
  • Typical timeline: Ranges from a few days to a few weeks depending on the case.
  • Non-compliance: May attract penalties, interest or late fees.
  • Expert help: TaxClue completes the entire process end to end for you.

What is the export obligation period?

Eighteen months from the date of issue of the Authorisation (paragraph 4.40(a) of the Handbook), with longer periods for projects and for defence, military store, aerospace and nuclear energy items.

How many extensions can be had?

One extension of up to six months and a further six months, each on a composition fee, and never beyond 12 months from expiry (paragraph 4.40(e), (f)).

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Advance Authorisation: a key compliance topic in Indian tax and corporate law that businesses and individuals must understand to remain compliant.

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Disclaimer: This article is for general informational purposes only and does not constitute professional tax, legal or financial advice. Laws, rates and due dates change and can vary by individual case — always verify with the relevant government source (e.g. mca.gov.in, incometax.gov.in) or consult a qualified professional before acting. TaxClue accepts no liability for decisions taken based on this content.

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Questions, answered

Short, direct answers to the 6 questions readers ask most on this topic.

Eighteen months from the date of issue of the Authorisation (paragraph 4.40(a) of the Handbook), with longer periods for projects and for defence, military store, aerospace and nuclear energy items.

One extension of up to six months and a further six months, each on a composition fee, and never beyond 12 months from expiry (paragraph 4.40(e), (f)).

Within six months from the date of expiry of the export obligation period (paragraph 4.43(b)).

No. Paragraph 4.36(iii) allows clubbing only for redemption or regularisation, and no further import or export is allowed.

The Regional Authority may regularise a bona fide default on the payments in paragraph 4.49, or take penal action under paragraph 4.43(f).

They apply only to periods expiring in the dates printed in paragraphs 4.40(i) and (j); they are not the standing rule.