Home > Policy for handling Import Transactions

Policy for handling Import 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:

  • Import Letters of Credit/ Standby Letters of Credit
  • Import Collections
  • Import Financing
  • Open account Imports
  • Advance Import Payment

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, centralised processing centres, 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-realisation, 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.

Click here for the list of documents.

Turn Around Time

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.

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 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 below link.

Client Complaints – BNP Paribas in India

Import Licenses

Except for goods included in the negative list which require licence under the Foreign Trade Policy in force, BNP Paribas India may freely open letters of credit and allow remittances for import. While opening letters of credit, the ‘For Exchange Control purposes’ copy of the licence should be called for and adherence to special conditions, if any, attached to such licences should be ensured. After effecting remittances under the licence, BNP Paribas India will preserve the copies of utilised licence /s till they are verified by the internal auditors or inspectors.

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 importer and in all correspondence of the importer with the Bank.

Obligation of Purchaser of Foreign Exchange

(i) In terms of Section 10(6) of the Foreign Exchange Management Act, 1999 (FEMA), any person acquiring foreign exchange is permitted to use it either for the purpose mentioned in the declaration made by him to an BNP Paribas India under Section 10(5) of the Act or for any other purpose for which acquisition of foreign exchange is permissible under the said Act or Rules or Regulations framed there under.

(ii) Where foreign exchange acquired has been utilised for import of goods into India, BNP Paribas India needs to ensure that the importer furnishes evidence of import viz., as in IDPMS, Postal Appraisal Form or Customs Assessment Certificate, etc., and satisfy himself that goods equivalent to the value of remittance have been imported. BNP Paribas India needs to ensure that all import remittances outstanding on the notified date of IDPMS are uploaded in IDPMS.

Manner of payment for import 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 further that in the case of import where the Bill of Entry (for goods) or invoice (for services) is up to ₹10 lakh (or its equivalent in foreign currency), entry in IDPMS may be closed based on a declaration from the importer to the effect that the payment for import has been made either in full or otherwise. Alternatively, such declaration may be submitted by an importer to BNP Paribas India on a quarterly basis for bulk closure of entries in IDPMS.

Time Limit for Settlement of Import Payments

(i) Remittances against imports should be completed within the period specified in the underlying contract.

(ii) BNP Paribas India may permit settlement of import dues delayed due to disputes, financial difficulties, etc. beyond the period specified in the underlying contract where interest is not involved. However, interest if any in such delayed payments, usance bills or overdue interest is payable only for a period of up to three years from the date of shipment and subject to extant Trade Credit framework, as amended from time to time.

Extension of Time

(i) BNP Paribas India can consider granting extension of time for settlement of import dues beyond the period specified in the underlying contract, irrespective of the invoice value for delays on account of disputes about quantity or quality or non-fulfilment of terms of contract; financial difficulties and cases where importer has filed suit against the seller, or any other reason acceptable to the Bank.

(ii) While granting extension of time, BNP Paribas India needs to ensure that:

a. The import transactions covered by the invoices are not under investigation by Directorate of Enforcement / Central Bureau of Investigation or other investigating agencies;

b. While considering extension beyond one year from the due date, the total outstanding of the importer does not exceed 10 per cent of the average import remittances during the preceding two financial years.

Reduction of invoice/ Write Off

BNP Paribas India may permit reduction of invoice/ write off provided that the Bank is satisfied with the bonafides of the transactions.

Third Party Payment for Import Transactions

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 Remittance for Import of Goods and Services

1. Advance Remittance for Import of Goods and Services

BNP Paribas India may allow advance remittance for import of goods without any ceiling subject to the following conditions:

(a) If the amount of advance remittance exceeds USD 5,000,000 or its equivalent, an unconditional, irrevocable standby Letter of Credit or a guarantee from an international bank of repute situated outside India or a guarantee of an AD Category – I bank in India needs to be provided by the importer.

(b) A Public Sector Company or a Department/Undertaking of the Government of India / State Government/s which is not in a position to obtain a guarantee from an international bank of repute against an advance payment, is required to obtain a specific waiver for the bank guarantee from the Ministry of Finance, Government of India before making advance remittance exceeding USD 100,000.

2. Advance Remittance for Import of Aircrafts/Helicopters, other Aviation Related Purchases and Shipping Vessels

(a) As a sector specific measure, entities which have been permitted under the extant Foreign Trade Policy to import aircrafts and helicopters (including used / second hand aircraft and helicopters) or any other person who has been granted permission by the Directorate General of Civil Aviation (DGCA) to operate Scheduled or Non-Scheduled Air Transport Service (including Air Taxi Services), can make advance remittance without bank guarantee or an unconditional, irrevocable Standby Letter of Credit, up to USD 50 million. Accordingly, BNP Paribas India may allow advance remittance, without obtaining a bank guarantee or an unconditional, irrevocable Standby Letter of Credit, up to USD 50 million, for direct import of each aircraft, helicopter and other aviation related purchases.

(b) Importers of Aircrafts/ Helicopters and other Aviation related Purchases, not eligible under clause (a) above can make advance remittance without bank guarantee upto an amount of USD 5 million.

The remittances for the transactions at (a) and (b) above shall be subject to the following conditions:

  1. BNP Paribas India will undertake the transactions based on its commercial judgment and after being satisfied about the bonafide of the transactions. KYC and due diligence exercise will be done by BNP Paribas India for the Indian importer entity and the overseas manufacturer company as well.
  2. Advance payments should be made strictly as per the terms of the sale contract and directly to the account of the manufacturer (supplier) concerned.
  3. In the case of a Public Sector Company or a Department / Undertaking of Central /State Governments, the BNP Paribas India shall ensure that the requirement of bank guarantee has been specifically waived by the Ministry of Finance, Government of India for advance remittances exceeding USD 100,000.
  4. Physical import of goods into India is made within the period specified in the underlying contract and the importer gives an undertaking to furnish documentary evidence of import within fifteen days from the close of the relevant period. It is clarified that where advance is paid as milestone payments, the date of last remittance made in terms of the contract will be reckoned for the purpose of submission of documentary evidence of import.
  5. Prior to making the remittance, the BNP Paribas India needs to ensure that the requisite in principle approval of the Ministry of Civil Aviation in case of Scheduled Air Service Operators and in other cases approval of the Director General of Civil Aviation / other agencies in terms of the extant Foreign Trade Policy has been obtained by the company, for import.
  6. In the event of non-import of aircraft and aviation sector related products, BNP Paribas India should ensure that the amount of advance remittance is immediately repatriated to India.
  7. BNP Paribas India needs to ensure generation of ORMs, BoE entries and BoE settlement with the respective ORMs etc. as per extant IDPMS guidelines.

(c) Importers are allowed to make advance remittance for import of shipping vessel, without bank guarantee, or an unconditional, irrevocable standby Letter of Credit, up to USD 50 million, subject to approval from Director General of Shipping being in place and subject to above conditions.

Interest on Import Bills

(i) BNP Paribas India may allow payment of interest on usance bills or overdue interest on delayed payments for a period of less than three years from the date of shipment at the rate prescribed for trade credit from time to time.  Cases beyond three years will attract guidelines relating to External Commercial Borrowings and will need to be followed. 

(ii) In case of pre-payment of usance import bills, remittances may be made only after reducing the proportionate interest for the unexpired portion of usance at the rate at which interest has been claimed or SOFR/ any other widely accepted/Alternative reference rate of the currency in which the goods have been invoiced, whichever is applicable. Where interest is not separately claimed or expressly indicated, remittances may be allowed after deducting the proportionate interest for the unexpired portion of usance at SOFR /any other widely accepted/Alternative reference rate of the currency of invoice.

(iii) In case of change in value due to (i) or (ii) above, BNP Paribas India needs to ensure proper remark/ indicator is entered for ORM mark off in IDPMS etc. as per extant IDPMS guidelines.

Remittance against Replacement imports

Where goods are short-supplied, damaged, short-landed or lost in transit and the Exchange Control Copy of the import licence has already been utilised to cover the opening of a letter of credit against the original goods which have been lost, the original endorsement to the extent of the value of the lost goods may be cancelled by BNP Paribas India and fresh remittance for replacement imports may be permitted without reference to Reserve Bank, provided, the insurance claim relating to the lost goods has been settled in favour of the importer. It may be ensured that the consignment being replaced is shipped within the validity period of the license.  BNP Paribas India needs to ensure that proper remark/indicator is entered for ORM mark off/closure of Bills in IDPMS etc. as per extant IDPMS guidelines.

Guarantee for Replacement Imports

In case replacement goods for defective import are being sent by the overseas supplier before the defective goods imported earlier are reshipped out of India, BNP Paribas India may issue guarantees at the request of importer client for dispatch/return of the defective goods, according to their commercial judgment.

Import of Equipment by Business Process Outsourcing (BPO) Companies for their overseas sites

BNP Paribas India may allow BPO companies in India to make remittances towards the cost of equipment to be imported and installed at their overseas sites in connection with the setting up of their International Call Centres (ICCs) subject to the following conditions:

(i) The BPO company should have obtained necessary approval from the Ministry of Communications and Information Technology, Government of India and other authorities concerned for setting up of the ICC.

(ii) The remittance should be allowed based on BNP Paribas India’s commercial judgment, the bonafides of the transactions and strictly in terms of the contract.

(iii) The remittance is made directly to the account of the overseas supplier.

(iv) BNP Paribas India needs to obtain a certificate as evidence of import from the Chief Executive Officer (CEO) or auditor of the importer company that the goods for which remittance was made have actually been imported and installed at overseas sites.

(v) BNP Paribas India needs to ensure compliance with IDPMS guidelines as applicable.

Receipt of Import Bills/ Documents by the Importer Directly from Overseas Suppliers

BNP Paribas India needs to ensure generation of ORMs, BoE entries and BoE settlement with the respective ORMs in compliance with IDPMS guidelines as applicable.

1. Receipt of import documents by the importer directly from overseas suppliers
Import bills and documents should be received from the banker of the supplier by the banker of the importer in India. BNP Paribas India will make remittances where import bills have been received directly by the importers from the overseas supplier, where it is satisfied with the bonafides of the transaction.

2. Receipt of import documents by the AD Category – I bank directly from overseas suppliers
At the request of importer clients, BNP Paribas India may receive bills directly from the overseas supplier as above, provided the BNP Paribas India is satisfied with the bonafides of the transaction.

Evidence of Import of Goods and Services

1. Physical Imports

(i) In case of all imports, irrespective of the value of foreign exchange remitted / paid for import into India, the importer needs to submit: –

(a) BoE number, port code and date for marking evidence of import under IDPMS.

(b) Customs Assessment Certificate or Postal Appraisal Form, as declared by the importer to the Customs Authorities, where import has been made by post, or Courier Bill of Entry as declared by the courier companies to the Customs Authorities in cases where goods have been imported through couriers, as evidence that the goods for which the payment was made have actually been imported into India, or

(c) For goods imported and stored in Free Trade Warehousing Zone (FTWZ) or SEZ Unit warehouses or Customs bonded warehouses, etc., the Exchange Control Copy of the Ex-Bond Bill of Entry or Bill of Entry issued by Customs Authorities by any other similar nomenclature the importer shall submit applicable BoE number, port code and date for marking evidence of import under IDPMS.

(ii) In respect of imports on Delivery against acceptance basis, the Bank shall verify the evidence of import from IDPMS at the time of effecting remittance of import bill. However, if importers fail to produce documentary evidence due to genuine reasons such as non- arrival of consignment, delay in delivery/ customs clearance of consignment, etc., AD bank may, if satisfied with the genuineness of request, allow reasonable time, not exceeding three months from the date of remittance, to the importer to submit the evidence of import.

2. Import of Services

Customer declaration in BNP Paribas India’s format along with underlying contract/ agreement/ invoice to be provided.

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.

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.

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).