Published: 1 Jul 2026
Regulatory UpdateDGFT Trade Notice No. 09/2026–27 — Dated 1 July 2026
DGFT Overhauls TRACE Reimbursement Under Export Promotion Mission — MSME-Tiered Support Up to 95%
The Directorate General of Foreign Trade has amended the Guidelines for Trade Regulations, Accreditation and Compliance Enablement (TRACE) under the Export Promotion Mission (EPM) — Niryat Disha. The flat, uniform reimbursement of ₹25 lakh per IEC is replaced with MSME-tiered support of up to 95%, disbursed in two linked instalments, against a consolidated, dynamic list of 462 eligible international certifications.
The Trade Notice
What Has Been Amended
Through Trade Notice No. 09/2026–27 dated 1 July 2026 — in continuation of Trade Notice No. 26/2025–26 dated 20 February 2026 — the DGFT has issued amendments and insertions to the Guidelines for Trade Regulations, Accreditation and Compliance Enablement (TRACE) under the Export Promotion Mission (EPM) – Niryat Disha, for operational clarity and certainty. TRACE reimburses exporters for the cost of obtaining foreign testing, inspection, and certification approvals needed to access overseas markets. All other provisions of Trade Notice No. 26/2025–26 remain unchanged.
Biggest Change
From a Flat Rate to MSME-Tiered Support
Earlier (Para 2(b))
Uniform assistance, ₹25 lakh cap
The level of assistance was uniform across all MSMEs, irrespective of classification as Micro, Small, or Medium. Maximum cumulative reimbursement was ₹25 lakh per IEC per financial year.
Revised (Para 2(b))
Tiered by MSME classification, ₹50 lakh cap
Financial assistance is now differentiated: Micro and Small Enterprises get up to 95% of actual cost (net of taxes, duties, and cess) or the notified ceiling, whichever is lower; Medium Enterprises get up to 80%. Maximum cumulative reimbursement is now ₹50 lakh per IEC per financial year, with cases above ₹50 lakh considered case-by-case by the Sub-Committee.
Reimbursement Structure
One Rate Table Replaced by a Two-Instalment Process
Previously, reimbursement rates depended on whether the certification was on the Positive List (up to 60%) or the Priority Positive List (up to 75%) — each disbursed as a single payment. Under the revised Para 2(c), support is now disbursed in two instalments, tied to milestones rather than list category.
The Reimbursement Claim (RC) filing process mirrors this two-stage structure under revised Para 3(c): RC-1 (First Claim) is filed after obtaining certifications, test reports, and compliance documents, enclosing the certificate/inspection report, invoice and proof of payment, and evidence of the mandatory or market-driven requirement. RC-2 (Second Claim) is filed after demonstrating exports linked to the certification, enclosing evidence of exports and proof of realisation. Disbursements continue to be made directly to the bank account specified in the IEC (Para 4(b)).
Lapse & Recovery Rule
A New Two-Year Clock on the Second Instalment
Revised Para 5(a) retains the existing rule that a reimbursement application lapses, and the applicant becomes ineligible for the next financial year, if not filed within 2 years of the Intent-to-Claim. It adds a new condition: where the first instalment has already been disbursed, the applicant must submit evidence of exports linked to the certification within 2 years of that disbursement. Failing this, the second instalment lapses — and the first instalment may be subject to recovery.
Eligible Certifications
Positive & Priority Lists Merged Into One Dynamic List of 462
The separate Positive List (Annexure-V) and Priority Positive List (Annexure-VI) of eligible testing, inspections, and certifications have been consolidated into a single List of Eligible Testing, Inspections, and Certifications, now running to 462 entries (Annexure-I to this Trade Notice), spanning dozens of countries and sectors. The list remains dynamic and subject to periodic review for inclusion or exclusion based on stakeholder consultations, international standards notifications, and trade facilitation considerations. A representative cross-section from the annexure:
Governance
Sub-Committee’s Recommending Role Simplified
Under revised Governance Structure Para 1(e), the Sub-Committee continues to recommend the level and applicable ceilings of financial assistance under TRACE, and the list of tariff lines eligible for support to Merchant Exporters (Annexure-VII). Its mandate over “inclusion, revision, or deletion of entries” now refers to the single consolidated list of eligible testing, inspections, and certifications, rather than separately to the erstwhile Positive List and Priority Positive List.
What It Means for Exporters
Regulatory
A single 462-entry eligible-certification list replaces two overlapping lists, simplifying which certifications qualify for TRACE support.
Commercial
Micro and Small Enterprises can now recover up to 95% of certification cost, and the annual cap doubles to ₹50 lakh per IEC — a significant increase in support available.
Operational
Claims must now be filed and tracked in two linked stages (RC-1, RC-2), with a hard 2-year deadline to prove exports after the first instalment or risk recovery.
How Omega QMS Can Help
Support for Exporters Claiming TRACE Reimbursement
Key Insight
By tying half the reimbursement to proven exports rather than certification alone, DGFT has sharpened TRACE into an outcome-linked scheme — exporters that treat the second claim and its 2-year export-evidence deadline as seriously as the certification itself stand to capture significantly more support than before.
Reference
Trade Notice No. 09/2026–27, dated 1 July 2026, issued by the Directorate General of Foreign Trade, Ministry of Commerce & Industry, Government of India (File No. 01/02/33/AM-26/EPM), signed by A G Subramanian, Deputy Director General of Foreign Trade. Issued in continuation of Trade Notice No. 26/2025–26 dated 20 February 2026.
Exporting products that need international certification?
Omega QMS helps exporters identify TRACE-eligible certifications, manage the testing and certification process, and file Reimbursement Claims correctly — so you capture the full MSME-tiered support you’re entitled to. Talk to our regulatory team.
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