The IEC annual update, and what deactivation actually blocks
The IEC has permanent validity, which is exactly why the annual update gets forgotten. It runs in a fixed three month window whether or not anything has changed, and the penalty for missing it is not a fee but a de-activated code. Here is the rule, the consequence, and the way back.
Paragraph 2.10(a) of the Handbook of Procedures 2023 provides that an IEC allotted to an applicant shall have permanent validity unless suspended or cancelled by the competent authority. That sentence is true and it is also why the annual obligation goes unread. Paragraph 2.05(d) of the Foreign Trade Policy 2023 provides that an IEC holder has to ensure that the details in its IEC are updated electronically every year, during the April to June period, and that where there are no changes in the IEC details the same also needs to be confirmed online.
What is the annual IEC update, and who has to do it?
Every IEC holder, every year, in the April to June window, whether or not anything about the entity has changed. Paragraph 2.05(d) of the Foreign Trade Policy 2023 is explicit that a nil change position still has to be confirmed online, which is the part most exporters get wrong: silence is not confirmation. Paragraph 2.05(c) records that the application process for an IEC and the updation of an IEC are completely online, and paragraph 2.10(b) of the Handbook of Procedures 2023 points back at the policy for the circumstances in which an IEC can be de-activated.
What actually happens if the update is missed?
Paragraph 2.05(e) of the Foreign Trade Policy 2023 states the consequence in one sentence: an IEC shall be de-activated if it is not updated within the prescribed period. It adds two things worth reading closely. An IEC so de-activated may be activated on its successful updation, so the route back is the same act that was missed. And the de-activation is without prejudice to any other action taken for violation of any other provision of the policy, so it is not a substitute for whatever else may be owed.
Is there a second way an IEC gets de-activated?
Yes, and it does not run on the calendar at all. Paragraph 2.05(f) of the Foreign Trade Policy 2023 provides that an IEC may also be flagged for scrutiny, that IEC holders are required to ensure that any risks flagged by the system are timely addressed, and that failing this the IEC shall be de-activated. So an exporter who diarises only the April to June window is watching one of the two triggers. The other arrives when the system decides it has a question, and the clock on it is whatever answering it takes.
How is the update actually run?
Through the DGFT portal, since paragraph 2.05(c) of the Foreign Trade Policy 2023 provides that updation is completely online, and paragraph 2.14(a) of the Handbook of Procedures 2023 provides that modifications and updations in an IEC can be done online only, with applicable fees and requisite documents. The steps below follow those paragraphs. We give no fee figure, because the scale of fee is set out in Appendix 2K referred to at paragraph 2.06 of the Handbook of Procedures 2023 and we have not verified the current schedule against it.
1. Open the window in April, not in June
Paragraph 2.05(d) of the Foreign Trade Policy 2023 puts the obligation in the April to June period. Running it at the start of the window leaves room for a document or a bank detail that turns out to be stale, which is the usual reason an update stalls.
2. Reconcile the details before you open the form
Check the entity name, address, constitution and bank details against what is actually true today, because paragraph 2.14(b) of the Handbook of Procedures 2023 requires those to have been updated online within 30 days of any change in any case.
3. Update online, or confirm the nil change
Paragraph 2.05(c) of the Foreign Trade Policy 2023 makes updation completely online, and paragraph 2.05(d) requires that where there are no changes in IEC details the same also needs to be confirmed online. A nil change is an action, not an omission.
4. Keep the profile in step
Paragraph 2.15(a) of the Handbook of Procedures 2023 provides that ANF-1 contains the profile of the importer or exporter, and that the IEC holder is responsible for updating it as and when a change takes place, immediately, or in any case at least once in a year.
5. Verify the record afterwards
Paragraph 2.09 of the Handbook of Procedures 2023 records that an electronic copy of the IEC may be downloaded from the DGFT dashboard, and that the details of any IEC may be verified on the DGFT website under Services, View IEC Related Details.
What else has to be updated, and on what clock?
Two obligations run alongside the annual one and neither waits for April. Paragraph 2.14(b) of the Handbook of Procedures 2023 requires that on any change in the constitution of the firm, the address, the bank details or any other primary details, the IEC holder ensures the IEC details are suitably updated online within 30 days of effecting the change. Paragraph 2.14(e) deals with a change of PAN through merger, acquisition, liquidation, inheritance or business transfer, requiring an IEC against the new PAN within 30 days, since paragraph 2.12 permits only one IEC against a single PAN.
What does a de-activated IEC actually block?
The whole export leg, because everything downstream keys to the code. Paragraph 2.05(a) of the Foreign Trade Policy 2023 provides that no export or import of goods shall be made by any person without obtaining an IEC unless specifically exempted, so a de-activated code is not an administrative inconvenience, it is a stoppage. It also reaches the registrations built on top of it: an AD code registration is tied to the PAN linked to the IEC, which is why AD code registration is worth checking in the same session as the update rather than separately.
When is the right time to run it?
April, alongside the other annual checks that fall in the same quarter, and not in the last week of June alongside everyone else. The update is cheap when it is a confirmation and expensive when it turns out a bank account or a registered address changed nine months ago and nobody told DGFT. Purser Outbound holds those registration artefacts and their dates against the shipment record so the annual window is a review rather than an archaeology exercise. Purser never submits to a government portal, and it never sends an outbound message without a recorded human approval event: the filing on the DGFT portal is yours.
Where to go from here
The IEC sits underneath everything else in the export file, so its failure mode is the one that stops the most.
- The registration that sits next to it. AD code registration ties the same PAN to a port and to the account refunds are credited into.
- Everything the IEC is read by. Documents required to export from India maps the registrations and the per-shipment documents in one chain.
- Where the code appears on the shipment. The shipping bill, field by field traces the declarations downstream.
- The clock that runs after the goods leave. The realisation clock changes on 01-10-2026, and it is judged per shipment rather than per year.
Frequently asked questions
When does the IEC annual update have to be done?
Every year during the April to June period. Paragraph 2.05(d) of the Foreign Trade Policy 2023 provides that an IEC holder has to ensure that the details in its IEC are updated electronically every year during that window, and that where there are no changes in the IEC details, the same also needs to be confirmed online.
What happens if the IEC is not updated?
Paragraph 2.05(e) of the Foreign Trade Policy 2023 provides that an IEC shall be de-activated if it is not updated within the prescribed period, that an IEC so de-activated may be activated on its successful updation, and that this is without prejudice to any other action taken for violation of any other provision of the policy. Since paragraph 2.05(a) bars export or import without an IEC unless exempted, de-activation is a stoppage rather than a fee.
Do I still have to file if nothing about my business changed?
Yes. Paragraph 2.05(d) of the Foreign Trade Policy 2023 requires that where there are no changes in IEC details, the same also needs to be confirmed online during the April to June window. A nil change position is a positive confirmation, not an omission, and failing to make it exposes the IEC to de-activation under paragraph 2.05(e).
How is a de-activated IEC reactivated?
By completing the update that was missed. Paragraph 2.05(e) of the Foreign Trade Policy 2023 provides that an IEC de-activated for non-updation may be activated on its successful updation. Paragraph 2.14(a) of the Handbook of Procedures 2023 provides that modifications and updations in an IEC can be done online only, with applicable fees and requisite documents.
Can an IEC be de-activated for a reason other than a missed update?
Yes. Paragraph 2.05(f) of the Foreign Trade Policy 2023 provides that an IEC may also be flagged for scrutiny, that IEC holders are required to ensure any risks flagged by the system are timely addressed, and that failing this the IEC shall be de-activated. That trigger does not run on the April to June calendar and arrives whenever the system raises the flag.