IEC
Your first international order landed. What must exist before you ship?
IEC, AD Code, LUT, RCMC and the payment rail block each other in a fixed order. Which registration gates which, and what breaks if you go out of sequence.
By Aaryan Kakani · · 17 min read
Which registration gates which?
Here is the short answer, before the explanation. Your PAN and a current account gate the IEC. The IEC gates everything else, because it is the identifier that DGFT, Customs, your AD bank and EDPMS all key off. The AD Code registration gates the shipping bill at one specific port. The LUT gates whether you ship without paying integrated tax or ship having paid it and claim it back. The RCMC gates Foreign Trade Policy benefits rather than the shipment. And the payment rail gates whether the money that eventually arrives can be evidenced as export proceeds at all.
That chain is worth reading twice, because the failures are not distributed evenly along it. Nobody gets stuck on the IEC; it is well documented and every consultant leads with it. People get stuck at the port, on the day of shipment, on an AD Code registered somewhere else. And they get stuck months later, on a bank query about a payment that arrived through a rail nobody thought about at the time of invoicing. The two failures sit at opposite ends of the timeline and both are decided in the first week.
| What it is | Who issues or accepts it | What it blocks if missing |
|---|---|---|
| IEC (Importer Exporter Code) | DGFT, on the DGFT portal, against your PAN | Everything. No shipping bill, no AD Code registration, no eBRC, no scheme benefit |
| AD Code registration | Your AD Category-I bank issues the letter; Customs registers it at one port | The shipping bill at that port. Registration elsewhere does not help you here |
| LUT (Letter of Undertaking) | Filed by you on the GST portal for the financial year | Export without payment of integrated tax. Not the shipment itself |
| RCMC | The Export Promotion Council or commodity board for your product | Foreign Trade Policy authorisations and scheme benefits. Not the shipment itself |
| Payment rail | Your AD bank, or a payment provider settling through one | Evidence that the receipt is export proceeds, and therefore EDPMS closure and the eBRC |
Two of these six (the AD Code gateway and the payment rail) are the ones that actually fail in practice. Everything else on the list is paperwork you will complete because someone told you to. These two you have to think about, because the answer depends on facts specific to
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Why does the IEC have to come first?
The Importer Exporter Code is not a licence in any meaningful sense. It is an identifier, issued by the Directorate General of Foreign Trade against your PAN, and its importance comes entirely from what resolves against it downstream. Your shipping bills carry it. Your AD bank reports realisation against it. The EDPMS record of every open shipment sits under it. The eBRC you will eventually generate is issued against it. It is, functionally, the primary key of your entire export compliance file.
Which is why the mistakes people make with it are almost never about obtaining it. They are about identity. A seller who trades informally under a personal PAN, then incorporates, then invoices from the company while the IEC still sits against the individual, has built a fault line into the file that will not surface until a bank or DGFT tries to reconcile a name. The same is true of a proprietorship that changes its bank account, its address or its constitution and never updates the DGFT record. The details on the IEC are the details Customs and your bank will match against. Where they diverge, the divergence is yours to explain. Our IEC registration guide covers the application and the update mechanics in detail.
There is a second, less obvious reason the IEC has to be genuinely first rather than nominally first: the AD Code letter your bank issues will quote it, and the port registration will be made against it. If the IEC is issued but the details on it are stale, you can end up with a bank letter that does not match the customs record, which produces exactly the same outcome as having no registration at all. A shipping bill that will not generate, discovered at the worst possible moment.
What does AD Code registration actually unlock?
This is the section to read carefully, because it contains the single dependency that most reliably breaks a first shipment.
An Authorised Dealer Code is a number identifying your bank branch. Registering it at a port is your bank telling Customs, in effect, that it is the channel through which the proceeds of shipping bills filed by your IEC at that port will flow. It is the bridge between the customs record and the banking record, and it is what makes it possible for a shipping bill filed at a port to later be matched against money arriving in a bank account.
The critical property is that this registration is per port . It is not a company-level registration, it is not a bank-level registration, and it does not travel. An exporter who registered at a seaport for a container shipment and then sends a sample by courier is, from the courier terminal's point of view, an exporter with no AD Code registration. The shipping bill will not generate, the broker will call it an AD Code error, and nothing about the earlier registration helps.
| Scenario | Does the existing AD Code registration cover it? | What you have to do |
|---|---|---|
| Second shipment, same seaport, same bank | Yes | Nothing |
| Air cargo complex in the same city as the registered seaport | No | Fresh bank letter, fresh registration at that location |
| Courier terminal for a sample or an e-commerce parcel | No | Fresh bank letter, fresh registration at that terminal |
| Same port, but you switched to a new bank | No | New bank's AD Code registered at that port |
| Same port, same bank, but the account was closed and reopened | Confirm with the bank and the broker | Re-issue the letter if the account particulars on record no longer match |
The lead time is what makes this dangerous rather than merely annoying. Obtaining the letter from a bank branch takes as long as a bank branch takes. Registration at the port takes as long as the broker and the customs location take. Neither is under your control, and neither compresses because a buyer is waiting. Sequencing this the week the order lands, rather than the week the shipment moves, is the whole game.
Do you need an LUT before you ship?
Strictly, no. The LUT does not gate the shipment. It gates whether you ship without paying integrated tax or ship having paid it and then claim it back. Both routes are lawful. They differ in working capital and in the amount of subsequent paperwork, and the choice is genuinely yours. But it has to be made before the shipping bill is filed, because the shipping bill records which route you took.
A Letter of Undertaking is filed by you, online, on the GST portal, and it covers a financial year. That last point is the one people miss. An LUT is not a permanent status. It has to be filed again for the new financial year, and an exporter who shipped happily under an LUT through March and keeps shipping in April on the assumption that it rolls over has, for those April shipments, exported without payment of tax with nothing on record permitting it.
| Route | What you do at export | Working capital effect | What you must keep current |
|---|---|---|---|
| Export under LUT | Ship without payment of integrated tax, declaring the LUT | No tax outflow on the export itself | An LUT filed and accepted on the GST portal for the current financial year |
| Export on payment of IGST | Pay integrated tax on the export and claim refund of the tax paid | Cash out first, refunded later | Accurate shipping bill and GST return data, since the refund is driven by their match |
| Shipping under an LUT you never filed | Not a route. The declaration and the record disagree | Appears free, then is not | Regularise before volume compounds it across a year of shipments |
For a first-time exporter the practical advice is unglamorous: file the LUT, because it is free of cost to file and removes a recurring cash drag, but do not treat it as a blocker. If your first order is time-critical and the LUT is not yet accepted, the IGST-paid route exists precisely for that situation. What you must not do is declare an LUT route on the shipping bill when no LUT exists, because that mismatch surfaces later in the GST reconciliation rather than at the port, when it is far more expensive to unwind. The mechanics of both routes are covered in our GST guide for exporters .
Is RCMC mandatory for a first shipment?
For most first shipments, no. And this is where the sequencing advice diverges from the checklist advice you will read elsewhere. A Registration-cum-Membership Certificate is issued by an Export Promotion Council or a commodity board covering your product line, and its function is to establish, for Foreign Trade Policy purposes, that you are a registered exporter of that product. It gates scheme benefits and authorisations. It does not gate the physical act of exporting.
So why put it on a first-order checklist at all? Because the asymmetry is brutal. Skipping the RCMC costs you nothing on shipment one. It costs you a great deal on the shipment where you wanted a benefit, discovered you needed an RCMC, and found that a certificate obtained now may not reach back to cover a shipment already made. The item with no immediate consequence is exactly the item that gets deferred indefinitely, and it is the deferral rather than the requirement that hurts.
| What you are trying to do | RCMC needed? | Why |
|---|---|---|
| Physically export goods against a commercial order | Generally not, for a plain export | The shipping bill runs off the IEC and the port registration, not the council membership |
| Claim a Foreign Trade Policy scheme benefit | Yes | The benefit is granted to a registered exporter of that product line |
| Apply for an authorisation under the Foreign Trade Policy | Yes | Authorisation applications are made as a registered exporter with the relevant council |
| Access council support, buyer databases and trade fair participation | Yes, in practice | These are membership services of the council itself |
Which payment rail can receive the money?
This is the decision nobody makes deliberately on a first order. The buyer offers to pay by whatever is convenient, the money arrives, and only months later does anyone ask whether that arrival can be evidenced as export proceeds against a specific shipping bill. By then the invoicing decision has been made many times over.
The distinction that matters is not brand but mechanism: does the money reach you as a foreign inward remittance your own AD bank can see and report, or does it reach you as a domestic rupee credit from a payment provider's partner bank, with the foreign origin evidenced only by a certificate that provider issues? Both are workable. They demand completely different paperwork habits, and the second one demands habits most first-time exporters do not know they need.
| Rail | Realisation document | Cadence | Cost of the document |
|---|---|---|---|
| Bank wire to your AD bank | Your AD bank's own inward remittance advice and subsequent eBRC | Per remittance, as received | Per your bank's schedule. Confirm with the branch |
| PayPal (India) | Foreign Inward Remittance Advise (FIRA), downloaded from the Business account under Reports | Weekly digital FIRA clubbing all withdrawals in that week into one document | Weekly digital FIRA free; a per-transaction Custom FIRA is priced at INR 100 + 18% GST per transaction for requests up to 20 transactions |
| Payoneer | Digital FIRA per transaction, delivered into the Payoneer account. Expressly not the regulatory e-FIRA | One per transaction, automatically, typically within 1 to 3 business days | Free of charge |
| Marketplace payout through a provider | Whatever the underlying provider issues, plus the marketplace settlement statement | Set by the marketplace's payout calendar, not by your export dates | Provider dependent |
Two mechanics are worth stating plainly because they surprise people. First, PayPal India credits your local Indian bank account automatically every day and manual transfer is not available, so one weekly FIRA routinely spans several daily credits and many underlying orders. Second, Payoneer is explicit that its digital FIRA is not the regulatory e-FIRA: its own guidance states that your bank must report to EDPMS, generate the IRM, issue the e-FIRA and provide the e-BRC after export bill realisation. In both cases, the document the provider gives you is an input to your AD bank, not a substitute for it.
There is one more thing to settle before you invoice: the purpose code. On both PayPal and Payoneer the purpose code is set on the account and stamped onto the certificate, and correcting it after issue is a bank-mediated exercise rather than a self-service one. Set it correctly at the outset for the kind of export you actually make, using our guide to purpose codes on marketplace receipts . If you sell through a marketplace where one payout will cover many shipping bills, read one payout, many shipping bills before your first settlement rather than after your fiftieth.
A first-time exporter with an IEC in the company name receives an order from a buyer abroad. The parcel will go by courier from a courier terminal. The exporter's AD Code was registered at the city seaport last year for a container shipment that never happened. Payment will come through a payment provider that settles in rupees. </> } result= >
| Link in the chain | State on the day the order arrived | Action |
|---|---|---|
| IEC | Held in the company name that will invoice | None |
| AD Code at courier terminal | Not registered. Seaport registration does not carry | Fresh bank letter, register at the terminal, confirm completion with the broker |
| LUT | Filed last financial year, not renewed | File for the current year, or ship on payment of IGST and declare that route |
| RCMC | None; no scheme benefit claimed on this shipment | Start the council application now, before it is needed |
| Purpose code | Provider default, never reviewed | Set correctly before the first withdrawal. It is stamped on the certificate |
| Realisation evidence | Provider certificate only, no bank-side entry | Present certificate plus export documents to the AD bank for IRM lodgement |
Note what the trail does not contain: any step that could have been taken after the money arrived. Every fix on the right-hand column is cheapest at the point the order lands and dearest at the point the file is queried.
When does the realisation clock start, and how long is it?
The moment the goods leave, an obligation attaches that has nothing to do with your buyer and everything to do with FEMA. RBI Master Direction No. 16/2015-16 on Export of Goods and Services states at paragraph A.2(i) that the period of realisation and repatriation of export proceeds is nine months from the date of export , and that this applies to all exporters including SEZ units, Status Holder Exporters, EOUs, EHTPs, STPs and BTPs . The statutory basis is Regulation 9(1) and 9(2)(a) of Notification No. FEMA 23(R)/2015-RB.
Read that carefully, because a persistent piece of internet folklore says SEZ units get longer. They do not. Regulation 9(2)(a) applies the same nine months to SEZ units, Status Holder exporters, EOUs, EHTPs, STPs and BTPs, notwithstanding sub-regulation (1). The only longer period in the current text attaches to a destination, not to an exporter category: goods exported to a warehouse established outside India must be realised within fifteen months from the date of shipment.
| Situation | Period | Reckoned from | Source |
|---|---|---|---|
| All exporters, including SEZ units, EOUs, EHTPs, STPs, BTPs and Status Holders | Nine months | Date of export | MD 16/2015-16 para A.2(i); FEMA 23(R) Reg. 9(1), 9(2)(a) |
| Goods exported to a warehouse established outside India | Fifteen months | Date of shipment | MD 16/2015-16 para A.2(iii); FEMA 23(R) Reg. 9(1)(a) |
| Goods exported to Bharat Mart | Nine months | Date of sale of the goods from the warehouse | MD 16/2015-16 para A.2(iv), inserted by A.P. (DIR Series) Circular No. 03 dated April 23, 2025 |
| Software exported in other than physical form | Nine months | Date of invoice covering the export | Explanation to FEMA 23(R) Reg. 9 |
Now the awkward part, which most first-order checklists omit because it is uncomfortable. For goods, "date of export" is not defined anywhere in FEMA 23(R) or in the Master Direction. The only Explanation to Regulation 9 defines the term for software alone. Where RBI has had to make the clock operational for goods it has used date of shipment: paragraph A.2(iii) reckons the warehouse period from the date of shipment, and paragraph C.28(2)(a)(ii) requires usance bills of caution-listed exporters to mature within the prescribed realisation period reckoned from date of shipment. The practical consequence for you is that the shipping bill filing date, the Let Export Order date and the bill of lading date can be days or weeks apart, and you should not build a due-date calculation on an assumption. Our guide on when the nine-month clock actually starts works through the divergence.
What happens if the window passes is worth knowing on day one rather than on day two hundred and seventy. Since A.P. (DIR Series) Circular No. 03 dated October 9, 2020, caution-listing is no longer automatic on overdue bills: an exporter is caution-listed by the Reserve Bank on the recommendation of the AD bank, where the exporter has come to the adverse notice of a law enforcement agency, is not traceable, or is not making sincere efforts to realise the proceeds. Overdue bills alone are not the trigger. But an exporter who never responds to the bank is indistinguishable, on the bank's record, from one making no sincere effort. Our guide to the RBI caution list for marketplace sellers covers the consequences and the de-caution route.
First-order sequencing checklist
Run it in this order. The grouping is the point: everything in the first block gates everything in the second, and everything in the second has a lead time you do not control.
Block one. Identity, before anything else
- PAN and a current account in the name of the entity that will actually raise the export invoice
- IEC obtained from DGFT against that PAN, with address, bank and constitution details current rather than historic
- GST registration in place, and the export route decided. Under LUT, or on payment of IGST with a refund claim
Block two. The items with lead times you do not control
- Exact port or terminal code for this shipment confirmed with the customs broker or courier, in writing
- AD Code letter obtained from the bank branch and registered at that exact location, with the broker confirming the registration completed rather than merely submitted
- LUT filed and accepted on the GST portal for the current financial year, with an April diary entry for the renewal
- RCMC application started with the Export Promotion Council or commodity board covering your product line, even if no benefit is claimed on this shipment
Block three. The money, decided before you invoice
- Payment rail chosen, and the mechanism understood. Foreign inward remittance your bank sees, or domestic rupee credit evidenced by a provider certificate
- Purpose code set correctly on the provider account before the first withdrawal, since it is stamped on the certificate and corrected only through the bank
- Realisation tracker opened with the first shipping bill: SB number, port, LEO date, bill of lading date, FOB value and the computed deadline
- Provider certificate and export documents presented to the AD bank for IRM lodgement, then the eBRC generated once realisation is reported. See our eBRC filing guide and our EDPMS reporting guide
Frequently asked questions
Which comes first for a first-time exporter. IEC, AD Code, LUT or RCMC?
The order is forced by the dependencies, not by preference. A PAN and a current account come first because the IEC application is built on them. The IEC comes next because it is the identifier every downstream system keys off. The AD Code registration comes third and must be done at the specific port or courier terminal you are shipping from. The LUT is filed on the GST portal in parallel and only matters if you want to ship without paying IGST. RCMC comes last for most first shipments, because it gates Foreign Trade Policy scheme benefits rather than the shipment itself. The payment rail sits alongside all of it and must be chosen before you invoice, not after the money arrives.
My shipping bill is stuck and the agent says AD Code is not registered. What happened?
AD Code registration is per port, not per company. Registering at one port does nothing at any other port, and a courier terminal is a separate location from the seaport or the air cargo complex in the same city. If your first order ships out of a different gateway from the one you registered at, the shipping bill will not generate until the AD Code is registered at that gateway. The fix is a fresh AD Code letter from your bank branch addressed to the new port, registered there by your customs broker. This is the single most common reason a first export shipment stalls on the day it was meant to move.
Do I need an LUT before my first export shipment, or can I ship without one?
You can ship without an LUT, but not without consequence. An LUT filed on the GST portal lets you export without payment of integrated tax. Without one, the lawful route is to export on payment of IGST and then claim a refund of the tax paid. Both are legal; they differ in working capital. Shipping under an LUT that has not actually been filed and accepted for the current financial year is the failure mode to avoid, because the shipping bill and the GST return then tell two different stories, and it is the exemption or the refund that unravels later rather than the shipment.
Is RCMC mandatory before I can export for the first time?
For most first shipments, no. RCMC is a Registration-cum-Membership Certificate issued by an Export Promotion Council or commodity board, and its function is to establish that you are a registered exporter of a particular product line for Foreign Trade Policy purposes. It gates scheme benefits and authorisations rather than the physical act of exporting. The practical mistake is to treat it as optional forever: by the time you want an authorisation or a benefit on a shipment already made, a certificate obtained afterwards may not reach back to cover it. Register with the council that covers your product while nothing yet depends on it.
How long do I have to receive the money for my first export order?
Under RBI Master Direction No. 16/2015-16, the period of realisation and repatriation of export proceeds is nine months from the date of export, and that nine-month period applies to all exporters including SEZ units, Status Holder exporters, EOUs, EHTPs, STPs and BTPs. The only longer period in the current text is for goods exported to a warehouse established outside India, where proceeds must be realised within fifteen months from the date of shipment. Separately, the Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026 notified on January 13, 2026 come into force from October 1, 2026 and set the period at fifteen months from the date of shipment, so confirm with your AD bank which regime governs a shipment made close to the changeover.
Where to go next
- When does the nine-month clock actually start?
- One payout, many shipping bills
- My payout arrived in INR, not foreign currency
- The PayPal India weekly FIRA, explained
- Payoneer digital FIRA and e-FIRA eligibility
- The RBI caution list and the marketplace seller
- A DGFT show cause notice arrived. What now?
- Export documentation checklist
Sources
Seasaw for Exporters
Get the first order right, and every one after it
Seasaw tracks every shipping bill against its own realisation deadline, matches provider certificates to the bills they actually fund, and tells you which registration is about to block your next shipment. Before the container is at the gate.
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Update history
- First published.