By Sagar Bhangare March 25, 2026

AEO EMI Scheme 2026: Defer Customs Duty as a Manufacturer

AEO EMI SCHEME — COMPLETE BLOG POST NOTES

TOPIC: Eligible Manufacturer Importer (EMI) Scheme
PURPOSE: Blog post reference document
DATE: March 2026

1. BACKGROUND & ORIGIN

– Announced in Union Budget 2026-27
– Introduced by CBIC via Circular No. 08/2026-Customs dated 28th February 2026
– Governed by the Deferred Payment of Import Duty Rules, 2016 (as amended)
– Part of the Authorised Economic Operator (AEO) framework under the
World Customs Organization (WCO) trade facilitation programme

2. WHAT IS THE SCHEME?

– Allows approved Eligible Manufacturer Importers (EMIs) to clear
imported goods from ports, airports, or Inland Container Depots (ICDs)
WITHOUT immediate payment of customs duties
– Duties can instead be paid on a MONTHLY basis
– Goal: Improve cash flow and working capital for manufacturers
– Acts as a stepping stone toward full AEO T2/T3 accreditation

3. DURATION OF THE SCHEME

– START DATE : 1st April 2026
– END DATE : 31st March 2028
– Applications open from: 1st March 2026
– Duration : 2 years (temporary/interim facilitation)

4. ELIGIBILITY CRITERIA

An applicant must satisfy ALL of the following:

a) MANUFACTURER/IMPORTER STATUS
– Must be an importer under Section 2(26) of the Customs Act, 1962
– Must be a manufacturer under Section 2(72) of the CGST Act, 2017
– OR: Must send inputs/capital goods for job work without tax payment
under Section 143 of CGST Act to a qualified job worker/manufacturer

b) IMPORTER EXPORTER CODE (IEC)
– Valid IEC issued by DGFT is mandatory

c) CUSTOMS FOOTPRINT
– Minimum 25 EXIM documents (Bills of Entry / Shipping Bills)
filed in the previous financial year
– RELAXED to 10 documents for MSME applicants

d) GST REGISTRATION
– At least one active GST Registration Certificate
under CGST/SGST Act, 2017

e) MANUFACTURING DECLARATION IN GSTIN
– For manufacturers: At least one active GSTIN must declare
“factory/manufacturing” in Form REG-01 (Column 16(d) or 20(d))

f) ANNUAL TURNOVER
– Aggregate annual turnover exceeding Rs. 5 crore in the last FY

g) BUSINESS CONTINUITY
– Minimum two financial years of operations

h) GST COMPLIANCE
– All GSTR-3B returns must be filed
– No tax collected but unpaid
– No unpaid dues under Central Excise or Service Tax laws

i) FINANCIAL SOLVENCY
– Positive net worth
– Solvent for the preceding two financial years
– CA Certificate mandatory as proof

j) CLEAN LEGAL RECORD
– No arrests or convictions under Customs, Central Excise,
Finance Act, or GST laws

NOTE: Existing AEO-T1 entities (including MSMEs) that meet the
criteria are also eligible to apply.

5. PAYMENT SCHEDULE (Deferred Duty)

– Bills of Entry assessed from 1st to last day of any month
(EXCEPT March) → duty due by 1st of the following month
– Bills of Entry assessed from 1st to 31st March → due by 31st March
– EMIs can also pre-pay anytime before the due date (early payment option)

6. THE AEO PROGRESSION PATHWAY

AEO Programme Tiers:
AEO T1 → Basic level (currently open to MSMEs)
AEO T2 → Intermediate level
AEO T3 → Highest level for importers/exporters
AEO-LO → For logistics operators and supply chain entities

– EMI scheme is designed as a BRIDGE to AEO T2/T3
– AEO T2/T3 status offers:
> Assured facilitation
> Priority treatment at ports
> Expanded, permanent benefits beyond the EMI scheme
– Manufacturers are encouraged to use the 2-year window to
upgrade to AEO T2/T3 accreditation

7. HOW TO APPLY — STEP-BY-STEP PROCESS

STEP 1: Visit the AEO India Portal — aeoindia.gov.in

STEP 2: Click on “Registration” on the homepage
(A registration form will appear as a pop-up)

STEP 3: Select “EMI” in the “Register for” dropdown
(DIC Zone will be auto-filled)

STEP 4: Enter the following details —
– Entity Name
– IEC Number (10-digit)
– Mobile Number
– Email ID (as per IEC/DGFT profile)

STEP 5: Create a username and password
Enter the CAPTCHA and click “Submit”

STEP 6: Upload a merged PDF containing —
– IEC Certificate
– Screenshot of the DGFT “View IEC Profile” page

STEP 7: Confirm the OTP sent to your registered email ID

STEP 8: Application forwarded to concerned DIC officer for
verification and approval

STEP 9: Upon approval — confirmation email sent + access granted
to file full EMI application on the portal

APPROVING AUTHORITY: Directorate of International Customs (DIC), CBIC

8. OPERATIONAL PROCESS POST-APPROVAL

– Approved EMIs must authenticate deferred payment through ICEGATE
– Duty to be paid by the specified monthly due dates
– CBIC retains monitoring and suspension powers for non-compliance

9. KEY BENEFITS OF THE SCHEME

– No immediate customs duty payment at port = improved cash flow
– Faster clearance of goods at ports/airports/ICDs
– Reduced working capital blockage for manufacturers
– Encourages compliance culture and AEO programme participation
– Boosts domestic manufacturing
– Improves ease of doing business
– Sector-specific advantage for:
> Electronics
> Pharmaceuticals
> Automotive components
> Renewable energy

10. BROADER POLICY SIGNIFICANCE

– Represents a POLICY SHIFT toward trust-based governance in
Customs administration
– Moves from transactional oversight to risk-based facilitation
– Signals CBIC’s intent to reward compliant manufacturers
– Success will be measured by:
> Industry uptake
> Compliance progression to higher AEO tiers
> Impact on India’s trade facilitation rankings

11. QUICK REFERENCE SUMMARY TABLE

SUGGESTED BLOG POST STRUCTURE

1. Introduction — What is the EMI Scheme and why it matters
2. Background — Budget 2026-27 and CBIC circular
3. Who is Eligible? — Detailed criteria
4. How the Deferred Payment Works — Payment schedule
5. How to Apply — Step-by-step guide
6. Benefits for Manufacturers — Cash flow, clearance speed
7. The AEO Pathway — Why this is a stepping stone
8. Impact on Key Sectors — Electronics, Pharma, Auto, etc.
9. Conclusion — Policy significance, call to action