Home > Policy for handling Export Transactions

Policy for handling Export Transactions

Introduction

BNP Paribas India (hereinafter called “Bank”) offers a range of award-winning trade and supply chain finance services that helps its customers leverage existing supply chains, improve key relationships and optimize their working capital.

Among others, our product offering includes:

  • Pre-shipment financing
  • Export bills on collection services
  • Export bills negotiation/ discounting
  • Post-shipment financing under LC
  • Open account transactions
  • LC Advising
  • LC confirmations

As prescribed by Reserve Bank of India (RBI) in its Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026, issued on January 13, 2026, and its subsequent amendments, if any, a Policy on handling Import transactions has been prepared.

This Policy shall apply to all branches, trade-processing units, centralized processing centers, treasury/operations units and other functions of the Bank handling export, import and MTT transactions.

This policy is to be read in conjunction with the latest FEMA 1999 regulations and any other rules, regulations, directions, notifications, circulars, policies etc. issued by Reserve Bank of India or any other regulatory authorities, and as updated from time to time, as applicable.

It covers transactions in goods, services and software, project exports, export/import advances, third-party receipts/payments, set-off, reduction/non-realization, delayed import payments, import advances, factoring, INR trade settlement and MTT, as applicable.  It covers the associated reporting, monitoring, reconciliation and closure of EDPMS/IDPMS entries.

This policy provides standard framework for handling of import transactions and related regulatory scenarios that are ordinarily encountered.  Any exceptional or specific circumstances that fall outside the scope of prescribed framework or require an alternative approach/ interpretation may be considered and addressed on a case-to-case basis, subject to applicable regulatory.  Where another law, regulation, RBI/DGFT instruction, sanctions requirement or court/authority direction imposes a stricter requirement, the stricter applicable requirement shall prevail.

Documentation Requirement

The following table lists the minimum (high level) documents that must be provided for each category of import transactions. These documents enable the bank to initiate processing in line with regulatory directives. Depending on the outcome of the bank’s due diligence review, additional documents may be required on a case by case basis to support the case. The bank will promptly inform the customer of any such additional requirements, the reasons for the same, and the revised processing timeline. Processing of transactions will be subject to the Bank being satisfied with the bonafides of the transactions and subject to presentment of satisfactory underlying documentary evidence. Click here for the document list.

Turn Around Time (TAT)

Provided that all the documents are presented to the Bank to their complete satisfaction to perform the due diligence before the agreed cut-off time, the transactions will be processed by the Bank as per the defined Turn Around Time (TAT) unless otherwise agreed and will be subject to compliance with extant FEMA guidelines and other applicable regulatory requirements as well as sanctions screening. Click here for details.

Charges

Standard charges for the various services offered by the bank are available on BNP Paribas India’s website, as updated from time to time, unless otherwise agreed specifically with the customer. Please find the schedule of charges for transactions offered by BNP Paribas India: Schedule of Charges.

Approval Matrix

The Bank performs relevant due diligence checks as per the agreed Standard Operating Procedures to their satisfaction and confirms whether the documents submitted comply with the applicable regulations, directions and the said policy. Every transaction is examined by a minimum of two independent bank staff members to ensure adequate due diligence. Deviation, if any, will be subject to Bank’s internal authorisation matrix duly approved by the Management committee of the Bank, and as updated from time to time. Click here for the Approval Matrix.

Escalation Matrix and Grievance Redressal Mechanism

At BNP Paribas, we strive to provide our clients with the highest possible standards of service. If for any reason the customer is not entirely satisfied with our service, products or employees, they can contact the assigned Relationship Manager, Desk Head or usual BNP Paribas contact person.

Banks Escalation Matrix and Grievance Redressal Mechanism is available at the link below. Client Complaints – BNP Paribas in India

Indication of importer-exporter code number

The importer-exporter code number allotted by the Director General of Foreign Trade under Section 7 of the Foreign Trade (Development & Regulation) Act, 1992 (22 of 1992) needs to be indicated on all copies of the declaration forms submitted by the exporter and in all correspondence of the exporter with the Bank.

Declaration of exports and submission of documents

  • An exporter of goods shall furnish to the specified authority* a declaration in the Export Declaration Form (EDF) specifying the amount representing the full export value of goods at the time of export along with underlying documents within 21 days from the date of shipment.
  • An exporter of services shall furnish to the specified authority, a declaration in EDF specifying the amount representing the full export value of services, within 30 days from the end of month in which invoice for services has been raised, provided that: (a) the exporter of services who has exported services to one or more recipients in a month, may submit a single EDF for all such exports; (b) the exporter of services other than software, may submit an EDF on or before the date of receipt of payment; (c) BNP Paribas India may, on a request from the exporter citing reasons for delay, extend the period for submission of the EDF after satisfying itself about the reasonableness of the request.
  • In the case of a non-EDI port for export of goods; or where the specified authority for export of services is other than an Authorized Dealer, the duly authenticated EDF, shall be forwarded by the specified authority to the respective Authorized Dealer.
  • In case of any delays in submission of documents/ EDF as applicable, BNP Paribas India may accept the same on a case-to-case basis and with suitable rationale from the exporter customers.

*Note: “Specified authority” means:

(i) Commissioner of Customs in Domestic Tariff Area (DTA) and Development Commissioner of Special Economic Zone (SEZ) in SEZ, for goods;

(ii) An Authorized Dealer in DTA and Development Commissioner of Special Economic Zone (SEZ) in SEZ, for services other than software; and

(iii) An Authorized Dealer or Software Technology Parks of India (STPI) in DTA, and Development Commissioner of Special Economic Zone (SEZ) in SEZ, for software.

Exemptions

Export of goods / software may be made with “NIL” EDF declaration in the following cases:

a) Trade samples of goods and publicity material supplied free of payment;

b) Ship’s stores, trans-shipment cargo and goods supplied under the orders of Central Government or of such officers as may be appointed by the Central Government in this behalf or of the military, naval or air force authorities in India for military, naval or air force requirements;

c) Tugs or Tugboats, Dredgers and Vessels used for providing offshore support services, subject to their re-import into India;

d) By way of gift of goods accompanied by a declaration by the exporter that they are not more than five lakh rupees in value

e) Aircrafts or aircraft engines and spare parts for overhauling and/or repairs abroad subject to their reimport into India after overhauling /repairs, within a period of six months from the date of their export;

f) Re-export of leased aircraft/helicopter and/or engines/auxiliary power units (APUs), either completely or in partially knocked down condition re-possessed by overseas lessor and duly de-registered by the Directorate General of Civil Aviation (DGCA) on the request of Irrevocable Deregistration and Export Request Authorization (IDERA) holder under ‘Cape Town Convention’ or any other termination or cancellation of the lease agreement between the lessor and lessee subject to permission by DGCA/Ministry of Civil Aviation for such export/s;

g) Goods imported free of cost on re-export basis;

h) The following goods which are permitted by the Development Commissioner of the Special Economic Zones, Electronic Hardware Technology Parks, Software Technology Parks or Free Trade Zones to be re-exported, namely:

1. Imported goods found defective, for the purpose of their replacement by the foreign suppliers/collaborators;

2. goods imported from foreign suppliers/collaborators on loan basis;

3) goods imported from foreign suppliers/collaborators free of cost, found surplus after production operations.

i) goods listed at items (1), (2) and (3) of clause (i) to be re-exported by units in Special Economic Zones, under intimation to the Development Commissioner of Special Economic Zones / concerned Assistant Commissioner or Deputy Commissioner of Customs

j) replacement goods exported free of charge in accordance with the provisions of Foreign Trade Policy in force, for the time being.

k) goods sent outside India for testing subject to re-import into India;

l) defective goods sent outside India for repair and re-import provided the goods are accompanied by a certificate from an authorized dealer in India that the export is for repair and re-import and that the export does not involve any transaction in foreign exchange.

m) any other case which is acceptable to the Bank

Period within which export value of goods/software/ services to be realised

(1) The amount representing the full export value of goods needs to be realized and repatriated to India within 9 months from the date of shipment.  For services, the period of realization is 9 months from the date of invoice.  In case goods or services are invoiced and/or settled in INR, a period of 12 months can be availed by the customer.

(2) Where the goods are exported to a warehouse established outside India, the amount representing the full export value of goods exported needs to be paid to BNP Paribas India as soon as it is realized and in any case within 9 months from the date of sale of goods from the warehouse.

(3) In case of project exports, the period of realization should be as per payment terms of the contract.

Manner of payment for export of goods

(1) The receipts and payments for export and import of goods and services shall be in the manner specified in the Foreign Exchange Management (Manner of Receipt and Payment) Regulations, 2023, as amended from time to time.

(2) BNP Paribas India shall make a credit or debit to the account of an exporter or an importer, for receipt of export or payment for import, only after having satisfied itself of the genuineness of the transaction, and shall, simultaneously close or update the respective entry in Export Data Processing and Monitoring System or Import Data Processing and Monitoring System (EDPMS or IDPMS)1:

Provided that in the case of export where the shipping bill (for goods) or invoice (for services) is up to ₹10 lakh (or its equivalent in foreign currency), entry in EDPMS may be closed based on a declaration from the exporter in the format as prescribed by BNP Paribas India from time to time, to the effect that the payment against the shipping bill / invoice has been realized either in full or otherwise. Alternatively, such declaration may be submitted by an exporter to BNP Bank India on a quarterly basis for bulk closure of entries in EDPMS.

Reduction in the export realisation

BNP Paribas India may, on request from the exporter citing reasons for under-realization or non-realization of full export value, allow reduction in realization of export value, provided the Bank is satisfied of the reasons cited and subject to presentment of satisfactory underlying documentary evidence.

Set off of export receivables against import payables

BNP Paribas India may allow set-off of export receivables against import payables from/to the same overseas buyer or supplier or with their overseas group or associate companies, within the stipulated period for realization of export proceeds or extended period, if any, allowed by the Bank.  Export receivables pertaining to goods may be allowed to be set off against import payables for services and vice versa.

Third party receipts and payments

BNP Paribas India may permit third party (other than the parties undertaking export and import) receipts and payments for export and import transactions provided that the Bank is satisfied with the bonafides of the transactions.

Advance payment for exports

(1) An exporter shall, in case of advance receipt for export, route the advanced amount, and realization of export proceeds, if any, through the same Authorized Dealer. However, an exporter may route the transactions through any other Authorized Dealer provided the exporter has intimated the change to both the Authorized Dealers.

(2) An exporter shall ensure that interest payable, if any, on advance payment received for export shall not exceed the all-in-cost ceiling of trade credit in terms of the Foreign Exchange Management (Borrowing and Lending) Regulations, 2018, as amended from time to time.

(3) In case the exporter is not able to make the shipment pertaining to the advance amount received upto 3 years, BNP Paribas India may allow the refund to be remitted, if satisfied with the reason/s provided by the exporter customer.

Merchanting Trade Transaction (MTT)

(1) A person undertaking Merchanting Trade, in accordance with the Foreign Trade Policy, shall ensure that:

(a) the period between the outward remittance and inward remittance or vice versa does not exceed six months:

Provided that BNP Paribas India may, on request citing reasons for delay, allow extension of time, if the Bank is satisfied of the reasons cited.

(b) outward remittances are sent only to the overseas seller, and inward remittances are received only from the overseas buyer:

Provided that the Bank may, on request from the customer citing reasons, allow receipt from and/ or payment to any third party, if the Bank is satisfied of the reasons cited.

(c) the documents evidencing the MTT are provided to the Bank to establish the genuineness of the transactions and commercial rationale for the same.

(2) BNP Paribas India will:

(a) credit or debit the account of its customer for any cross-border transaction related to MTT after having been satisfied with the genuineness of the same and shall, simultaneously close or update the respective entry in EDPMS and/or IDPMS.

(b) monitor and follow-up with the person undertaking merchant trading to ensure that both the legs of the transaction are completed within the period and manner as specified in these Regulations.

Foreign Currency Account

(1) As permitted under Foreign Exchange Management (Foreign Currency Accounts by a person resident in India) (Seventh Amendment) Regulations, 2025, a person resident in India, being an exporter, may open, hold and maintain a Foreign Currency Account with a bank outside India, for realization of full export value and advance remittance received by the exporter towards export of goods or services. Funds in this account may be utilized by the exporter for paying for its imports into India or repatriated into India within a period not exceeding the end of

(a) three months in case of accounts maintained with banks in an International Financial Services Centre; or

(b) next month for all other jurisdictions;

from the date of receipt of the funds after adjusting forward commitments, provided that the realization and repatriation requirements are followed by the customer.

(2) Exporter customers can open a temporary foreign currency account abroad. They may deposit the foreign exchange obtained by sale of goods at the international exhibition/ trade fair and operate the account during their stay outside India provided that the balance in the account is repatriated to India through normal banking channels within a period of one month from the date of closure of the exhibition/trade fair and full details are submitted to their banker concerned.

(3) An Indian entity can also open, hold and maintain a foreign currency account with a bank outside India, in the name of its overseas office/branch, by making remittance for the purpose of normal business operations of the said office/branch or representative.

(4) A unit located in a Special Economic Zone (SEZ) may open, hold and maintain a Foreign Currency Account with BNP Paribas India in India.

Note: All the above accounts need to follow the current regulations provided by RBI in its Foreign Exchange Management (Foreign currency accounts by a person resident in India) Regulations, 2015, as updated from time to time.

Exchange Earners’ Foreign Currency Account (EEFC Account)

(1) A person resident in India may open an account in foreign currency with BNP Paribas India called as the Exchange Earners’ Foreign Currency (EEFC) Account.

(2) This account will be non-interest-bearing current account. No credit facilities, either fund-based or non-fund based, will be permitted against the security of balances held in EEFC accounts.

(3) All categories of foreign exchange earners can credit 100% of their foreign exchange earnings to their EEFC Accounts, subject to the condition that the sum of the accruals in the account during a calendar month should be converted into Rupees on or before the last day of the succeeding calendar month after adjusting for utilization of the balances for approved purposes or forward commitments.

(4) The eligible credits should represent inward remittance received through normal banking channel

(5) Remittances representing foreign currency loan raised or investment received from outside India or those received for meeting specific obligations by the account holder are not permitted to be credited to the EEFC account.

(6) Bank may permit its exporter constituents to extend trade related loans/ advances to overseas importers out of their EEFC balances without any ceiling subject to certain conditions.

(7) BNP Paribas India may permit exporters to repay packing credit advances whether availed in Rupee or in foreign currency from balances in their EEFC account and / or Rupee resources to the extent exports have actually taken place.

(8) Where a part of the export proceeds is credited to an EEFC account, the export declaration (duplicate) form may be certified as: “Proceeds amounting to …… representing ….. percent of the export realization credited to the EEFC account maintained by the exporter with……”

Exports to neighbouring countries by road, rail or river

The following procedure should be adopted by exporters to file original copies of EDF where exports are made to neighboring countries by road, rail or river transport:

(i) In case of exports by barges/country craft/road transport, the form should be presented by exporter or his agent at the Customs station at the border through which the vessel or vehicle has to pass before crossing over to the foreign territory. For this purpose, exporter may arrange either to give the form to the person in charge of the vessel or vehicle or forward it to his agent at the border for submission to Customs.

(ii) As regards exports by rail, Customs staff has been posted at certain designated railway stations for attending to Customs formalities. They will collect the EDF for goods loaded at these stations so that the goods may move straight on to the foreign country without further formalities at the border. The list of designated railway stations can be obtained from the Railways. For goods loaded at stations other than the designated stations, exporters must arrange to present EDF to the Customs Officer at the Border Land Customs Station where Customs formalities are completed.

Project Exports

(1) BNP Paribas India may permit receipts/ payments for project exports as per the underlying contract, after satisfying itself of the genuineness of the project.

(2) Subject to monitoring by BNP Paribas, India, a project exporter may deploy temporary cash surplus, generated outside India, from such exports, for investments in short-term instruments (with original or residual maturity of one year or less) including in treasury bills and in deposits with banks, outside India.

Export of goods on lease, hire, etc.

Prior approval of BNP Paribas India is required for export of machinery, equipment, etc., on lease, hire basis under agreement with the overseas lessee against collection of lease rentals/hire charges and ultimate re-import.

Export of goods through Post

Postal Authorities allow export of goods by post only if the original copy of the EDF has been countersigned by an AD Bank. Therefore, EDF, which involves sending goods by post, should be first presented by the exporter to the Bank for countersignature.

The procedure is as under:

(i) Bank shall countersign EDF after ensuring that the parcel has been addressed to their branch or correspondent bank in the country of import and return the original copy to the exporter, who shall then submit the EDF to the post office with the parcel.

(ii) The duplicate copy of EDF will be retained by the Bank to whom the exporter shall submit relevant documents together with an extra copy of invoice for negotiation/collection, within the prescribed period of 21 days.

(iii) The concerned overseas branch or correspondent shall be instructed to deliver the parcel to consignee against payment or acceptance of relative bill.

(iv) Bank may, however, countersign EDF covering parcels addressed directly to the consignees, provided it is satisfied on the basis of the standing and track record of the exporter and the arrangements made for realization of the export proceeds.

(v) Any alteration in the name and address of consignee on the EDF form should also be authenticated by Bank under its stamp and signature.

Consolidation of air cargo/sea cargo

(i) Consolidation of air cargo

a) Where air cargo is shipped under consolidation, the airline company’s Master Airway Bill will be issued to the Consolidating Cargo Agent. The Cargo agent in turn will issue his own House Airway Bills (HAWBs) to individual shippers.

b) Bank will negotiate HAWBs only if the relative letter of credit specifically provides for negotiation of these documents in lieu of Airway Bills issued by the airline company.

(ii) Consolidation of sea cargo

a) BNP Paribas India may accept Forwarder’s Cargo Receipts (FCR) issued by IATA approved agents, in lieu of bills of lading, for negotiation / collection of shipping documents, in respect of export transactions backed by letters of credit, if the relative letter of credit specifically provides for negotiation of this document, in lieu of bill of lading even if the relative sale contract with the overseas buyer does not provide for acceptance of FCR as a shipping document, in lieu of bill of lading

b) Further, BNP Paribas India may, at their discretion, also accept FCR issued by Shipping companies of repute/IATA approved agents (in lieu of bill of lading), for purchase/discount/collection of shipping documents even in cases, where export transactions are not backed by letters of credit, provided their ‘relative sale contract’ with overseas buyer provides for acceptance of FCR as a shipping document in lieu of bill of lading. However, the acceptance of such FCR for purchase/ discount would purely be the credit decision of the bank concerned who, among others, should satisfy itself about the bona fides of the transaction and the track record of the overseas buyer and the Indian supplier since FCRs are not negotiable documents. It would be advisable for the exporters to ensure due diligence on the overseas buyer, in such cases.

“Write-off” of unrealised export bills

1. An exporter customer who has not been able to realize the outstanding export dues despite best efforts, may approach BNP Paribas India for its approval (if BNP Paribas India had handled the relevant shipping documents), with appropriate supporting documentary evidence.

2. The write-off by BNP Paribas India shall be subject to the following conditions:

a. The relevant amount has remained outstanding for more than one year;

b. Satisfactory documentary evidence is furnished indicating that the exporter had made all efforts to realize the export proceeds;

c. The exporter is a regular customer of the bank for a period of at least 6 months, is fully compliant with KYC/AML guidelines and BNP Paribas India is satisfied with the bonafides of the transaction.

d. The case falls under any of the undernoted categories:

  • There is a disagreement between the overseas buyer and the exporter on the quality/ quantity of goods exported.
  • The overseas buyer has been declared insolvent and a certificate from the official liquidator, indicating that there is no possibility of recovery of export proceeds, has been produced.
  • The unrealised amount represents the balance due in a case settled through the intervention of the Indian Embassy, Foreign Chamber of Commerce or similar Organization;
  • The goods exported have been auctioned or destroyed by the Port / Customs / Health authorities in the importing country;
  • The overseas buyer is not traceable over a reasonably long period of time.
  • The unrealised amount represents the undrawn balance of an export bill remaining outstanding and turned out to be unrealizable despite all efforts made by the exporter;
  • The cost of resorting to legal action would be disproportionate to the unrealised amount of the export bill or where the exporter even after winning the Court case against the overseas buyer could not execute the Court decree due to reasons beyond his control;
  • Bills were drawn for the difference between the letter of credit value and actual export value or between the provisional and the actual freight charges, but the amounts have remained unrealized consequent on dishonor of the bills by the overseas buyer and there are no prospects of realization.
  • Any other reason supported by documentary evidence and subject to satisfaction of BNP Paribas India.

3. The exporter needs to submit documentary evidence towards surrendering proportionate export incentives if any, availed of in respect of the relative export bill.

4. The exporter customer needs to provide a certificate from Chartered Accountant indicating the export realization in the preceding calendar year and details of the amount of write-off, if any, already availed of during the current calendar year along with the requisite details of the EDF/Export Bill under the write-off request. This certificate shall also indicate that the export benefits, if any, availed by the exporter have been surrendered.

5) The following cases, however, would not qualify for the “write-off” facility:

  • Exports made to countries with externalization problems, i.e. where the overseas buyer has deposited the value of exports in local currency, but the amount has not been allowed to be repatriated by the Central Bank/ authorities of the country concerned.
  • EDF/Softex which are under investigation by agencies like Enforcement Directorate, Directorate of Revenue Intelligence, Central Bureau of Investigation, etc. also the outstanding bills which are subject matter of civil / criminal suits

Part Drawings/ Undrawn Balances

  • In certain lines of export trade, it is the practice to leave a small part of the invoice value undrawn for payment after adjustment due to differences in weight, quality, etc., to be ascertained after arrival and inspection, weighment or analysis of the goods. In such cases, BNP Paribas India may negotiate the bills, provided:
  • The amount of undrawn balance is considered normal in the particular line of export trade, subject to a maximum of 10 per cent of the full export value.
  • An undertaking is obtained from the exporter on the duplicate of EDF forms that he will surrender/account for the balance proceeds of the shipment within the period prescribed for realization.
  • In cases where the exporter has not been able to arrange for repatriation of the undrawn balance in spite of best efforts, BNP Paribas India, on being satisfied with the bona fides of the case, will ensure that the exporter has realized at least the value for which the bill was initially drawn (excluding undrawn balances) or 90 per cent of the value declared on EDF form, whichever is more and a period of one year has elapsed from the date of shipment.

Refund of export proceeds

BNP Paribas India, through whom the export proceeds were originally realized may consider requests for refund of export proceeds of goods exported from India and being re-imported into India on account of poor quality. While permitting such transactions, BNP Paribas India will:

  • Exercise due diligence regarding the track record of the exporter;
  • Verify the bona-fides of the transactions;
  • Obtain from the exporter a certificate issued by DGFT / Custom authorities that no export incentive has been availed by the exporter against the relevant export or the proportionate incentives availed, if any, have been surrendered;
  • Not insist on the requirement of re-import of goods, where exported goods have been auctioned or destroyed by the Port / Customs / Health authorities/ any other accredited agency in the importing country or for any other reason, subject to submission of satisfactory documentary evidence.

In all other cases BNP Paribas India shall ensure that procedures as applicable to normal imports are adhered to and that an undertaking from the exporter, to re-import the goods within three months from the date of refund of export proceeds, shall be obtained.

Change of buyer/consignee

If goods after having been shipped are required to be transferred to a buyer other than the original buyer in the event of default by the latter, the same may be permitted by BNP Paribas India provided the Bank is satisfied of the reasons cited and subject to presentment of satisfactory underlying documentary evidence

Opening / Hiring of Warehouses abroad

BNP Paribas India may consider the applications received from exporters and grant permission for opening / hiring warehouses abroad subject to the following conditions:

  • Applicant’s export outstanding does not exceed 5 per cent of exports made during the previous financial year.
  • Applicant has a minimum export turnover of USD 100,000/- during the last financial year.
  • Period of realization should be as applicable.
  • All transactions should be routed through the designated branch of BNP Paribas India.
  • The above permission will be granted to the exporters initially for a period of one year and renewal may be considered subject to the applicant satisfying the requirement above.

Transactions prior to 1st October 2026

BNP Paribas, India will handle transactions related to the export and import of goods and services, as well as merchanting trade, undertaken prior to October 01, 2026, which hitherto required approval of the Reserve Bank of India, under the Foreign Exchange Management (Export of Goods and Services) Regulations, 2015, Master Direction – Export of Goods and Services (FED Master Direction No. 16/2015-16, dated, January 01, 2016 as updated till July 17, 2026), and Master Direction – Import of Goods and Services (FED Master Direction No. 17/2016-17, dated, January 01, 2016 as updated till January 12, 2026).