The EximLabh Brief

Can Your Interest Subvention Claim Still Use the Old Credit Period After DGFT's Clarification?

Trade Notice No. 13/2026-27 resets the eligibility window for claims filed after 14 July 2026, and your bank certificate must now map to a fresh EPM-format UIN.

The question Can an exporter whose pre-shipment or post-shipment credit was disbursed under the old credit-period norms still rely on those norms when filing an interest subvention claim after DGFT's clarification of 14 July 2026? The short answer is no, not automatically. Trade Notice No. 13/2026-27 resets the eligibility window for claims filed after that date, and the bank certificate must now map to a fresh EPM-format UIN, not an IES-era one. ## What changed DGFT issued Trade Notice No. 13/2026-27 on 14 July 2026, clarifying operational aspects of Interest Subvention Support for Pre- and Post-Shipment Export Credit under the Export Promotion Mission (EPM) , Niryat Protsahan sub-scheme. It follows Trade Notice No. 03/2026-27 dated 13 May 2026, which amended the interest subvention guidelines. The clarification addresses three things: how exporters calculate eligible credit periods, how they generate and map Unique Identification Numbers (UINs), and how banks submit certificates for claims. The core compliance risk sits with exporters whose loans straddle the transition date. A loan disbursed before 14 July 2026 but maturing after it cannot simply carry forward the old credit-period calculation into a new claim. The claim must be filed under the revised norms, with a UIN generated in the EPM format (EPMIESxxxxxxxxxxxx) against the notified Positive List of HS Codes. ## The UIN trap A UIN obtained under the erstwhile Interest Equalisation Scheme (IES) is not eligible to pass subvention benefits under EPM. Exporters must generate a fresh EPM-format UIN. One question remains unresolved in the materials available: whether a UIN that was valid at the time of disbursal but expired on 31 March 2026 remains valid for loans outstanding beyond that date. The illustrative example is a loan disbursed on 20 February 2026, maturing on 30 June 2026, with a UIN expiring on 31 March 2026. Practitioners should not assume continuity. Confirm against the primary instrument whether a fresh UIN is required for the post-31 March 2026 portion of the credit period. Portability of UIN is not permitted. A change in lending bank requires a new UIN reflecting the revised bank details. ## Past-period claims: file separately Past-period claims carry their own trap. Additional claims for January 2026 to May 2026 must be submitted separately through the online DGFT module. They must not be clubbed with the regular monthly claim for June 2026. An exporter who files a consolidated claim covering both the old and new periods risks rejection of the entire claim, not merely the ineligible portion. This is a hard separation rule, not a formatting preference. ## Bank certification The entity must furnish the applicable UIN to the lending bank, and the bank must report interest subvention claims mapped to that UIN. If the bank's certificate references the old credit period or an IES-era UIN, the claim will fail even if the underlying export is eligible. Exporters with outstanding pre-shipment or post-shipment credit disbursed before 14 July 2026 should obtain written confirmation from their lending bank on the UIN mapped to that facility and the credit period the bank will certify in its claim. Do not wait for the claim filing deadline to discover a mismatch between the bank's certificate and the DGFT module's UIN validation. ## Open confirmations Practitioners should confirm the following against Trade Notice No. 13/2026-27 and the scheme guidelines as amended: - Whether the revised credit period applies prospectively only, or retrospectively to disbursements made before the clarification date.