What Records Must Be Maintained Under MOOWR? (2026 Guide)

MOOWR records must be maintained in digital form. This is not a choice. Under Regulation 4 of the MOOWR (No. 2) Regulations, 2019, the applicant undertakes to maintain accounts of receipt and removal of goods in digital form and to furnish them digitally to the bond officer on a monthly basis, in accordance with the Customs Act, 1962.

The prescribed format is Annexure B of Circular No. 34/2019-Customs, which combines the data elements required under the MOOWR Regulations and the Warehouse (Custody and Handling of Goods) Regulations, 2016.

The Annexure B Account

A single account covers the receipt, processing, and removal of goods. It must record the quantity and description of goods received, the operations carried out, goods sent for and received back from job work, unit transfers, and every removal, whether for home consumption, export, or transfer.

Domestic procurements are also recorded, with a remarks column provided for entries that need explanation. Existing capital goods and inputs at the time of conversion must be accounted for in the same form.

MOOWR Records Must Be Digital, With an Audit Trail

The software used to maintain electronic records must incorporate an audit trail. That means a secure, computer-generated, time-stamped electronic record allowing reconstruction of the course of events relating to the creation, modification, or deletion of a record.

The audit trail must capture actions at record and system level, including attempts to access the system or to delete or modify a record. A spreadsheet that can be silently overwritten does not satisfy this.

Monthly Returns Under Regulation 17

Accounts are furnished digitally to the bond officer on a monthly basis. Where the warehouse is also used for non-Section 65 purposes, a separate monthly return in Form B applies under Circular No. 25/2016-Customs, issued by CBIC, so that mixed-use infrastructure can be optimally utilised.

CBIC has emphasised that maintenance of digital records, along with accurate and timely filing of monthly returns, should be strictly implemented, particularly where goods move between Section 65 units.

Retention and Off-Site Backup

Records must be preserved for a minimum period of five years from the date of removal of the goods. That obligation survives surrender of the licence.

Updated digital copies must also be preserved at a place other than the warehouse, to prevent loss of records through natural calamity. Many units discover this requirement only during an audit.

The Warehouse Keeper Signs

The warehouse keeper discharges duties on behalf of the licensee, maintains the accounts, and signs the documents. He is expected to supervise and satisfy himself as to the veracity of the declarations and accounts he signs.

He must verify quantities, endorse bills of entry and transfer forms, retain copies, and report any discrepancy to the bond officer within twenty-four hours. A digital signature is required for electronic filings.

Input-Output Norms

The applicant informs the input-output norms for raw materials and final products at the time of application, and must report any revision. SION norms do not apply, so these are self-declared.

This matters because duty on clearance is computed on the warehoused goods contained in the resultant goods. Your records must correlate imported inputs to what you clear. Norms that do not reconcile with actual consumption invite a duty demand.

Why MOOWR Records Decide Your Audit

There is no physical customs control over a Section 65 unit. Supervision was shifted to the warehouse keeper, and audits are risk-based with no prescribed frequency.

The records are therefore the entire basis on which compliance is judged. A stock mismatch between physical inventory and the Annexure B account is the most common trigger for a duty demand, and a missing monthly return will stall a surrender application.

How JPARKS INDIA Helps

At JPARKS INDIA, we set up Annexure B accounts that generate the Regulation 17 return without manual reconstruction, configure the audit trail, establish off-site backup, declare defensible input-output norms, and train the warehouse keeper on the twenty-four hour discrepancy rule. Having served 500+ importers and exporters since 2018, we keep bonded units audit-ready. Learn more about our MOOWR scheme services or book a free consultation.

Frequently Asked Questions

Q1. What records must be maintained under MOOWR?

A digital account of receipt, processing, and removal of goods in the form at Annexure B of Circular No. 34/2019, covering imports, domestic procurements, job work, transfers, and all clearances.

Q2. Can MOOWR records be kept on paper?

No. Regulation 4 requires an undertaking to maintain accounts in digital form and to furnish them digitally to the bond officer monthly. The software must incorporate an audit trail.

Q3. How long must MOOWR records be retained?

For a minimum of five years from the date of removal of the goods. Updated digital copies must also be preserved at a location other than the warehouse.

Q4. Who signs the MOOWR records?

The warehouse keeper, on behalf of the licensee. He must satisfy himself as to the veracity of the accounts he signs, and holds a digital signature for electronic filings.

Q5. How quickly must discrepancies be reported?

Within twenty-four hours. The licensee must verify quantities, endorse bills of entry and transfer forms, retain copies, and report any discrepancy to the bond officer within that window.

Related guides

• Start here: What is the MOOWR Scheme in Customs?
• Can Customs Revoke MOOWR Approval? (2026 Guide)
• MOOWR vs IGCR: What Is the Difference? (2026 Guide)
• Can a 3PL Warehouse Become a MOOWR Unit? (2026 Guide)
• Can MOOWR Be Used for Machinery Imports? (2026 Guide)

If you want this done without the back and forth, we provide MOOWR approval support.