Source: Handbook of Procedures 2023, Chapter 10, DGFT, Ministry of Commerce and Industry, Government of India, updated 05 June 2025. Para 10.15.

The Problem This Blog Answers

Your Indian company regularly transfers SCOMET items, software, or technology to your foreign subsidiary or parent company as part of ongoing design, development, testing, or delivery work. Every transfer technically requires a SCOMET authorisation. Applying for a fresh licence each time is slowing down your operations and adding cost without reducing any real risk.

Is there a route that recognises the nature of intra-company transfers and removes the need for repeated individual applications?

Yes. It is called GAICT: Global Authorisation for Intra-Company Transfers.

What Is GAICT?

As per Para 10.15 of HBP 2023, the Global Authorisation for Intra-Company Transfers (GAICT) is a pre-export authorisation that allows eligible Indian companies to export and re-export SCOMET items including software and technology under SCOMET Category 8 to their related foreign entities without requiring a fresh individual authorisation for each transfer, subject to post-reporting obligations.

The key phrase is pre-export authorisation will not be required for each transfer once GAICT is granted. You apply once, get approved, and transfer multiple times during the validity period.

What Does GAICT Cover?

GAICT covers SCOMET items including software and technology under SCOMET Category 8, except items listed in Appendix 10M of HBP.

SCOMET Category 8 covers special materials and related equipment, material processing, electronics, computers, telecommunications, information security, sensors and lasers, navigation and avionics, marine, aerospace, and propulsion.

Critical exclusion: Items listed in Appendix 10M are excluded from GAICT. Before applying, verify whether your specific item appears in Appendix 10M. If it does, GAICT is not available and you must apply for an individual authorisation.

Who Is Eligible for GAICT?

As per Para 10.15(A)(i) of HBP 2023, GAICT is available only for intra-company transfers. Specifically:

Route 1: From an Indian parent company to its foreign subsidiary company.

Route 2: From an Indian subsidiary of a foreign company to its foreign parent company or another subsidiary of that foreign parent company.

There is no provision for GAICT between unrelated companies. If your buyer or recipient is not your subsidiary, parent, or a co-subsidiary under the same foreign parent, GAICT does not apply to your transaction.

Third party involvement: If there is a third party in the supply chain, the end user must be a foreign parent, another subsidiary of the foreign parent company, or a subsidiary company of the Indian company. Third parties who are entirely unrelated entities cannot be in the GAICT supply chain.

What Conditions Must Be Fulfilled?

As per Para 10.15(A)(ii) of HBP 2023, all of the following conditions must be met:

Condition 1: Master Service Agreement or Contract The items, software, or technology to be exported must be based on a Master Service Agreement or Contract between the Indian parent company or Indian subsidiary of the foreign company, and the foreign subsidiary or foreign parent company, for carrying out services including but not limited to design, encryption, research, development, delivery, validation, calibration, testing, and related services.

Note 1: The list of services is illustrative and not exhaustive. However, the final decision to approve a GAICT authorisation lies with the relevant authority.

Note 2: As a result of the service carried out by the Indian exporter in case of re-export, the items, software, or technology must not undergo a change in classification.

Condition 2: Approved Country List The items, software, and technology must be exported or re-exported only to countries listed in Table 1 of Para 10.15 of HBP 2023. The entire supply chain including any third party must be in the countries listed in Table 1.

The Table 1 country list as per HBP 2023 Chapter 10 is:

Argentina, Australia, Austria, Belgium, Bulgaria, Canada, Croatia, Czech Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Japan, Latvia, Lithuania, Luxembourg, Malta, Mexico, Netherlands, New Zealand, Norway, Poland, Portugal, Republic of Korea, Romania, Russian Federation, Slovakia, Slovenia, South Africa, Spain, Sweden, Switzerland, Turkey, Ukraine, United Kingdom, United States.

Compliance warning on Russian Federation and Ukraine: Although these countries appear in Table 1 of HBP 2023, Indian exporters must independently assess whether any proposed transfer to Russian Federation or Ukraine-linked entities is consistent with India’s obligations under catch-all controls in Para 10.05, UNSC resolutions, and India’s foreign policy considerations. The catch-all provision at Para 10.05 applies regardless of whether a country is on Table 1. IMWG retains the right to deny GAICT on national security and foreign policy grounds.

Note: IMWG may on a case-to-case basis allow countries other than those listed in Table 1, considering the description, end use, and end user of the item.

Condition 3: Declaration of Intended Use The applicant exporter must declare that the exported items will be used for the purposes for which they are intended by the foreign subsidiary, foreign parent, or another subsidiary of the foreign parent company.

Condition 4: Internal Compliance Programme The applicant exporter must furnish either a certified or approved Internal Compliance Programme (ICP), or demonstrate compliance to the ICP of the foreign parent company, or provide an ICP certified by the Compliance Manager of the company, or certification by a Government agency such as the Authorized Economic Operator (AEO) scheme.

Condition 5: Agreement to On-Site Inspection The exporter must agree to allow on-site inspection if required by DGFT or authorized representatives of the Government of India.

Condition 6: No UNSC Sanctioned Destinations No GAICT will be granted for UNSC sanctioned destinations or countries.

Condition 7: No Adverse Notice No GAICT will be granted to an exporter who has previously come to adverse notice.

Condition 8: Military End Use Trigger If after issue of GAICT the exporter is notified in writing by DGFT, or knows or has reason to believe that an item may be intended for military end use, the exporter is not eligible to use GAICT for that item and must apply separately for a fresh individual authorisation under regular SCOMET policy as per Para 10.05 of HBP.

What Documents Are Required?

As per Para 10.15(B) of HBP 2023, the application for GAICT must be submitted through the online SCOMET portal using proforma ANF 10C, along with the following supporting documents:

1. Corporate relationship proof Documentary proof of the corporate relationship between the Indian parent company and its foreign subsidiary, or between the Indian subsidiary of the foreign company and its foreign parent or another subsidiary of the foreign parent company.

2. SCOMET classification Classification of the item including software and technology in SCOMET, indicating the SCOMET category and sub-category.

3. License exception proof (optional) Documentary proof of license exception or temporary license from the country of the parent company abroad or from subsidiaries of the parent company abroad, if available. This is optional.

4. Detailed item description Detailed description of the item intended to be exported with relevant technical details and specifications such as model, part number, etc. For software or technology, relevant details including encryption algorithm, key length, encryption functionality, and eligibility under the cryptography note must be provided if applicable.

5. Third party contract (if applicable) If there is third party involvement in the supply chain, a clear contract, service agreement, or purchase order specifying the SCOMET item description must be furnished.

6. Internal Compliance Programme Certified or approved ICP of the Indian parent company, or self-certified copy of the ICP of the foreign parent company being adopted by the Indian subsidiary of the foreign company, along with an undertaking.

7. Undertaking on company letterhead A signed and stamped undertaking by the authorised signatory covering agreement to allow on-site inspection, declaration that exported items will be used for intended purposes, and declaration that if military end use is suspected the exporter will not use GAICT and will apply separately under regular policy.

8. End User Certificate Original EUC in the prescribed format within 30 days of filing the application. For subsequent exports after GAICT is issued, EUC must be submitted within 30 days of delivery at the destination point.

9. Agreement or purchase order An agreement, purchase order, or excerpt of contract from the receiving entity stating that the export is for a permitted use.

10. Contact details of EUC signatory Documents must include the name, contact number, and email ID of the authority signing the EUC.

11. Third party supply chain contract (if applicable) A precise and clear contract, service agreement, or purchase order indicating item description in case of third party involvement in the supply chain.

Post-Reporting Obligations

As per Para 10.15(C) of HBP 2023, after GAICT is granted and transfers are made, the Indian exporter must submit post-shipment details of each transfer or consignment to the SCOMET Division of DGFT Headquarters, New Delhi, through the online system on the DGFT website.

Frequency: Quarterly, covering March, June, September, and December.

Deadline: By the end of the subsequent month of each quarter, in respect of exports made in the previous quarter.

Format: ANF 10D, along with a copy of EUC in Appendix 10J(iv) from the foreign subsidiary company or foreign parent company or another subsidiary of the foreign parent company.

Consequence of non-compliance: Failure to submit post-shipment details may result in imposition of penalty or suspension or revocation of GAICT.

Record Keeping

As per Para 10.15(D) of HBP 2023, the exporter must keep records of all export documents in manual or electronic form for a period of 5 years from the date GAICT is issued by DGFT.

Validity

As per Para 10.17 of HBP 2023, GAICT is valid for a period of 3 years from the date of issue, subject to whichever of the following comes first:

• Till the validity of the license exception of the foreign parent company
• Till the validity of the license exception of the foreign parent company for subsidiaries of the parent company abroad
• Till the validity of the Master Service Agreement or Contract with the foreign parent company and the Indian subsidiary

Can GAICT Be Revalidated?

No. As per Para 10.20 of HBP 2023, GAICT cannot be revalidated. Once it expires, a fresh application must be filed.

When Can GAICT Be Suspended or Revoked?

As per Para 10.15(H) of HBP 2023, GAICT will be suspended by DGFT on receipt of intimation about initiation of any inquiry from the country concerned or from any domestic agency. GAICT will be revoked on receipt of an adverse report on proliferation concern, or for non-submission of mandatory reports or documents within the prescribed timelines, or for non-compliance with any condition of this policy.

Re-Exports by the Foreign Receiving Entity

As per Para 10.15(F) of HBP 2023, further re-exports or re-transfers of items including software and technology, whether processed or incorporated, from the foreign subsidiary or foreign parent or another subsidiary of the foreign parent to end users in other countries, are subject to the export control regulations of the country of that foreign entity. India’s GAICT does not govern what the foreign entity does with the items after receipt.

Changes After GAICT Is Granted

As per Para 10.15(E)(c) of HBP 2023, if there is any inclusion or amendment of items including software and technology, or inclusion of new companies or amendment in existing companies in the supply chain, the applicant exporter must obtain prior permission from DGFT with relevant details before making those changes.

GAICT at a Glance