IFSCA • Bullion Market • 15 October 2026
The International Financial Services Centres Authority has issued the final (Good Delivery) Guidelines, 2026 — a 46-page rulebook that decides which gold refiners, Indian or global, get to call their gold "Good Delivery" on the IFSC Bullion Exchange. It is in force with immediate effect.
If you refine gold anywhere in the world and want that gold to be deliverable on India’s IFSC Bullion Exchange (IIBX) or in its OTC market, there is now a single, binding standard you must meet. On 15 October 2026, IFSCA replaced its 2025 consultation draft with the final International Financial Services Centres Authority (Good Delivery) Guidelines, 2026 — and the message to the industry is unambiguous: technical quality alone is no longer enough. Responsible sourcing, audited to international assurance standards, is now part of what "Good Delivery" means.
This is a significant moment for the GIFT City bullion ecosystem. The Guidelines state their objective plainly: to build a transparent, credible and orderly bullion market and to advance India’s ambition of becoming a price influencer in the global bullion market — not just a price taker.
The essentials, at a glance
💡 What “Good Delivery” now means
The Guidelines define Good Delivery as the quality and technical standards of manufacturing of Gold as prescribed by BIS and NABL, plus responsible sourcing as specified in these Guidelines. Gold manufactured accordingly is eligible for delivery on IFSC exchanges or in the OTC market. In other words: a bar that is 99.5% pure but sourced through a conflict-tainted supply chain is not Good Delivery.
The 5-step framework every Accredited Refiner must follow
The heart of the Guidelines is a five-step compliance framework, closely modelled on the OECD Due Diligence Guidance for mineral supply chains. Every Accredited Refiner must adhere to all five steps, at all times.
1Build the compliance foundation (RFRC Framework)
Step 1 requires a Risk-Focused Regulatory Compliance (RFRC) Framework — essentially, the policy and governance spine of the whole system:
- A documented Gold Supply Chain Policy covering sourcing risks from conflict-affected and high-risk areas (CAHRAs), with risk-based procedures, an internal governance framework, traceability and chain-of-custody systems, supplier engagement written into contracts, and a formal grievance mechanism for internal and external stakeholders.
- Board-level oversight — the Board (or equivalent) must actively oversee the policy, build expertise, and allocate resources.
- A Compliance Officer with the seniority and authority to do the job — monitoring, policy improvement, training and regulatory engagement. The Bullion Exchange may prescribe the CO’s qualifications and experience.
- Mandatory training for compliance, risk, procurement and logistics staff, covering red-flag indicators and escalation.
- Group-level AML/CFT discipline: a refiner with branches or subsidiaries in FATF-countermeasure jurisdictions, or in countries with inadequate AML/CFT measures, must strictly observe its group-level AML-CFT and supply-chain policies there.
2Map risks across the supply chain (RBOE Framework)
Step 2 is the operational engine — the Risk Based Operational Excellence (RBOE) Framework. This is where the Guidelines get granular:
- Client due diligence: identify and verify every client/supplier and their beneficial owners, understand the business relationship, and run ongoing transaction scrutiny — aligned with the IFSCA AML/CFT/KYC Guidelines, 2022. Indian refiners must additionally follow the PMLA dealer guidelines for precious metals; overseas refiners follow their local law too, and where standards differ, the higher of the two applies.
- Environmental assessments: EIAs are recommended practice regardless of gold source, and refiners must honour the Minamata Convention (mercury), the International Cyanide Management Code and the Convention on Biological Diversity.
- Supply-chain and risk mapping across LSM mines, artisanal mines, aggregators, recycled material, mixed gold and industrial by-product — weighing geographical risks (CAHRA proximity, sanctions, cash-vs-formal payments), transaction risks (structuring, round-tripping, unexplained routing) and delivery-channel risks.
- Source-specific procedures: large/medium mines need GNSS mine coordinates, licences and ownership records, plus on-site visits for high-risk suppliers; artisanal and small-scale mines get a lighter registration-based regime but with added socio-economic mapping and strict child-labour monitoring; recycled gold needs origin documentation (enhanced due diligence only if it comes from or transits CAHRAs); mixed gold needs blending records and mass-balance checks.
- Record keeping for a minimum of 8 years, in physical or digital form.
- No cash: the Accredited Refiner’s own transactions with suppliers must go only through official banking channels, payment service providers or TPAPs. Cash transactions are not permitted for the Accredited Refiner.
- Red-flag catalogues (location, supplier, human-rights/security, financial-integrity based) that must be reviewed and updated regularly — plus Enhanced Due Diligence (on-site assessments, transaction sampling, beneficial-ownership verification) wherever red flags appear.
3Act on the risks — including cutting suppliers off
Step 3 turns assessment into action, and it has teeth:
- Suppliers with remediable deficiencies get a time-bound improvement window of six months (extendable by a further six months only with Bullion Exchange approval), monitored against quantitative and qualitative metrics.
- Where due diligence establishes direct or indirect support to non-state armed groups, money laundering, terrorist financing or serious human-rights abuses, the refiner must immediately suspend procurement — and where such involvement is confirmed, terminate the relationship immediately, whether the refiner is in India or overseas.
- A formal Risk Mitigation Plan follows: regular Compliance Officer reporting to the board, chain-of-custody traceability, reinforced physical security, and physical segregation of high-risk shipments (dedicated storage, restricted access) so CAHRA-linked material cannot contaminate clean stocks.
4Submit to independent third-party audit
Step 4 outsources verification to independent auditors empanelled by the Bullion Exchange — the refiner must check the auditor’s empanelment status and Letter of Empanelment before engagement. Audits must be independent, competent (OECD-guidance literate) and accountable, with a publicly accessible registry of empanelled auditors on the Exchange’s website.
Audit reports go to both the Bullion Exchange and the refiner within 90 calendar days of the audit period’s end, and the auditor must keep records for at least 8 years.
🚨 Zero-tolerance breaches
Four situations are treated as zero-tolerance breaches of the audit framework: denying the auditor access, trying to influence the audit outcome, misrepresentation or falsification of documents, and continuing to deal with suppliers confirmed to be involved in conflict gold, severe human-rights abuses, money laundering or terrorism financing. On occurrence or reasonable suspicion, the auditor must immediately and confidentially report to the Bullion Exchange with supporting evidence — and the Exchange decides the action at its sole discretion.
5Report publicly, every year
Step 5 closes the loop: each Accredited Refiner must publish a Comprehensive Management Report (CMR) annually, containing the latest third-party audit report, material changes since the audit, the status of corrective actions, and any other Exchange-specified disclosures. The refiner’s own Compliance Report — disclosing its overall rating and per-step ratings (low/medium/high) — forms part of the CMR.
The audit ladder: Limited Assurance first, Reasonable Assurance within 5 years
Annexure A lays down a detailed Audit Review Framework. The headline numbers auditors and refiners need to know:
Old vs new: what changed from the 2025 draft
The final Guidelines did not appear out of thin air. IFSCA had placed a draft “Good Delivery Guidelines 2025” for public consultation, inviting comments until 31 December 2025. The 2026 final version is the binding outcome of that exercise. Key shifts:
Who is affected
- Indian gold refiners (including in SEZs and IFSCs) that want their bars accepted as Good Delivery on the IFSC Bullion Exchange — accreditation is now the gateway.
- Overseas refiners targeting IIBX delivery or the IFSC OTC market — the Guidelines expressly cover refiners outside India, with the “higher of the two standards” rule for AML/CFT.
- The Bullion Exchange (IIBX) — it must implement the Guidelines: set certification criteria, empanel auditors, keep the public registry, and police suspension/termination timelines.
- CA, CS and Cost Accountant firms — a new empanelment opportunity as third-party auditors, but with strict eligibility (2 years’ experience, clean regulatory record, ISAE 3000 capability).
- Aggregators, suppliers and intermediaries in the gold supply chain — expect far deeper due diligence, chain-of-custody documentation and formal payment channels from accredited refiners.
🧰 A note on grandfathered stocks
Gold products with a verifiable date up to the issuance of these Guidelines are treated as “Grandfathered Stocks” and are exempt from the requirement to determine origin — verifiable via physical date stamps or inventory lists. Everything refined after issuance must go through the full due-diligence machinery.
What to do next
- Refiners eyeing accreditation: start building the RFRC and RBOE frameworks now — adopt the Gold Supply Chain Policy, designate a Compliance Officer with real authority, map your supply chain to mine level, and move all supplier payments to banking channels. The Exchange’s certification criteria (to be specified in consultation with IFSCA) will test exactly this.
- Audit firms: check yourself against the empanelment criteria — ICAI/ICSI/ICMAI registration, clean record across RBI/ECGC/SEBI/CIC lists, 2 years’ audit experience, ISAE 3000 systems — and watch the Bullion Exchange’s website for the empanelment window and the public registry.
- Suppliers and aggregators: get your chain-of-custody documentation, beneficial-ownership disclosures and permits in order; accredited refiners are now obliged to walk away from opaque counterparties.
- Everyone: the Authority can issue clarificatory circulars and guidance notes — track IFSCA’s “Legal Framework” page for follow-ups.
Frequently asked questions
Q1. Do the Guidelines apply to silver as well?
No. The scope clause covers Good Delivery standards in relation to Gold only — for refiners seeking Accredited Refiner certification and for Accredited Refiners.
Q2. Can an overseas refiner become an Accredited Refiner?
Yes. The Guidelines expressly cover refiners established or operating outside India that intend to be certified by the Bullion Exchange. They must also comply with their home jurisdiction’s AML/CFT measures — and where those differ from IFSCA’s, the higher standard applies (to the extent local law permits).
Q3. What happens if a refiner’s gold comes from a conflict zone?
Gold from or transiting CAHRAs triggers enhanced due diligence — security, human-rights, anti-bribery and AML controls, plus origin verification. If due diligence establishes support to armed groups, money laundering, terrorist financing or serious abuses, procurement must stop immediately; if confirmed, the supplier relationship must be terminated.
Q4. How often must an Accredited Refiner be audited?
Under ISAE 3000: Limited Assurance within the first 2 years of accreditation and Reasonable Assurance within the first 5 years, with the same periodicity thereafter. The Bullion Exchange can require a Reasonable Assurance audit at any time. A “High Risk Deviations” rating forces a follow-up Reasonable Assurance audit within 180 days.
Q5. Is existing gold stock exempt from origin checks?
Only “Grandfathered Stocks” — products with a verifiable date (physical date stamps and/or inventory lists) up to the issuance of these Guidelines. Everything after that needs full origin determination.
Q6. Who certifies a refiner as an “Accredited Refiner”?
The Bullion Exchange in IFSC, against eligibility criteria it will specify in consultation with IFSCA — and only after the refinery has undergone the prescribed due-diligence process. (The Exchange’s criteria are not yet published — NOT CHECKED.)
Sources
- International Financial Services Centres Authority (Good Delivery) Guidelines, 2026 — official PDF (46 pages), IFSCA website: ifsca.gov.in — Good Delivery Guidelines, 2026
- IFSCA (Bullion Market) Regulations, 2025 — enabling regulations cited in the Guidelines’ preamble
- Draft IFSCA Good Delivery Guidelines, 2025 — public consultation (comments invited till 31 December 2025), via IFSCA Public Consultation page
- IFSCA (Anti-Money Laundering, Counter-Terrorist Financing, and Know Your Customer) Guidelines, 2022 — cross-referenced for AML/CFT measures
Date note: the Guidelines state they come into force with immediate effect; the 15 October 2026 date is per IFSCA’s official file record. The Bullion Exchange’s accreditation eligibility criteria were not yet published at the time of writing.
