Impact of Revised eBRC Format on GST Refund Claims

J's Position paper for today. Traditionally a foreign exchange realisation document under FEMA with only peripheral relevance to GST, the eBRC has been fundamentally recast by DGFT Public Notice No. 42/2025–26 dated 9 January 2026. The mandatory capture of GSTIN and invoice-level GST particulars in the revised Appendix 2U transforms the eBRC into a GST-integrated compliance document, directly linking export, realisation, and refund entitlement. While aimed at systemic harmonisation across GST, customs, and forex regimes, this recalibration significantly tightens the evidentiary threshold for zero-rated refund claims, foreshadowing a more exacting, data driven scrutiny that may render GST refund filings substantially more complex and contentious for exporters.