Export Obligation (EO) for EPCG Licenses reduced proportionately for FY 24-25



Quick Summary
A new policy circular (No. 10/2025-26) allows for a proportionate reduction in the Export Obligation (EO) for EPCG licenses for FY 2024-25. This applies if your sector's exports declined by more than 5% compared to FY 2023-24. The DGFT will notify eligible sectors, and Regional Authorities will re-fix the EO, which must be endorsed on your license. Exporters are responsible for ensuring this reduction is reflected before applying for Export Obligation Discharge.

Under Customs, Policy Circular No. 10/2025-26 dated 26.02.2026 is a significant compliance update for EPCG license holders.

Let's break it down into a structured, operational checklist for quick application in practice:

EPCG EO Reduced for FY 24-25: New Policy Circular

Compliance Checklist: EO Reduction under Para 5.17 (FTP 2023)

1. Eligibility

  • Check if your sector/product group exports declined >5% in FY 2024-25 compared to FY 2023-24.
  • If decline is continuous over consecutive years, use the year after which decline began as the base year.

2. DGFT Communication

  • DGFT will notify Regional Authorities (RAs) of eligible sectors/product groups within 7 months of FY close.
  • Refer to Policy Circular No. 10/2025-26 (26.02.2026) for the official list of product groups with decline percentages.

3. Action by Regional Authorities

  1. RAs will re-fix annual average EO proportionately for FY 2024-25.
  2. Reduction must be endorsed in:
  • License file
  • Amendment sheet issued to EPCG Authorisation holder
 

4. Exporter’s Responsibility

  1. Ensure EO reduction endorsement is reflected in your license records.
  2. While applying for EO discharge (EODC):
  • Reference Para 5.11.2 (HBP 2009-14), Para 5.19 (HBP FTP 2015-20), and Para 5.17 (FTP 2023).
  • Confirm RA considers these before issuing demand notice/EODC.
 

5. Risk Mitigation

  • Maintain documentation of sector decline (DGFT circular + export data).
  • Keep a check-sheet for EODC applications to ensure Para 5.17 relief is applied.
  • If EO shortfall exists, rely on cumulative relief provisions across past FTPs.

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About the Author

DESIGNATED PARTNER

Mr. Vivek Jalan is a FCA, Qualified LL.M (Constitutional Law) and LL.B. He is the Chairman of The Fiscal Affairs and Taxation Committee of The Bengal Chamber of Commerce and Industry. He is the Convenor on Indirect Taxes of the CII- Economic Affairs and Taxation Committee (ER); He is also a visiting faculty for Indirec ... Read more

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