What EDPMS and IDPMS are
RBI tracks every export and import that has a foreign exchange leg through two databases that AD banks update:
- EDPMS (Export Data Processing and Monitoring System): each shipping bill from customs (and, for services and software, each export declaration) sits as an open entry until the bank links the inward remittance (IRM) that pays for it.
- IDPMS (Import Data Processing and Monitoring System): each bill of entry sits open until the bank links the outward remittance (ORM) that paid for it; each advance remittance sits open until a bill of entry is linked to it.
An entry closes only when the bank marks it closed. Paying the supplier or receiving money from the buyer is not enough: the bank has to match the two, and to do that it needs your documents.
The rules from 1 October 2026
The Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026 (notified 13 January 2026, amended 22 September 2026) took effect on 1 October 2026 and replace the earlier export regulations and the related master directions on export and import.
| Item | Position from 1 October 2026 |
|---|---|
| Export realisation (goods) | 9 months from the date of shipment |
| Export realisation (services) | 9 months from the date of invoice |
| Exports invoiced or settled in INR | 12 months |
| Extension | AD bank may extend on request, if satisfied with the reasons |
| Import payments | Monitored against the payment period in the underlying contract, not a fixed RBI period; AD bank may extend |
| Small entries | Entries up to ₹10 lakh can be closed, or reduced, on the exporter's or importer's declaration; quarterly consolidated declarations allowed |
| Reduction or non-realisation above ₹10 lakh | AD bank evaluates on documents under its own board-approved policy |
| Set-off | Export receivables against import payables with the same overseas party, or with overseas group or associate companies, subject to conditions |
| Third-party receipts and payments | Allowed where the AD bank is satisfied the transaction is genuine |
| Service exports | EDF within 30 days from the end of the month of the invoice; SOFTEX replaced |
| Unrealised exports | Where proceeds stay unrealised beyond one year after the permitted period, further exports only against full advance or an irrevocable letter of credit |
| Caution list | Exporters on RBI's caution list on 30 September 2026 stay under the existing orders until removed |
| Bank SOPs | AD banks must have documented SOPs for extensions, reductions, advances and delegation, with key features on their website |
The January 2026 text had 15 and 18 months for realisation; the September amendment brought these back to 9 and 12 months before the regulations took effect. Your bank's SOP sets the documents and the delegation for each case. Check the regulation numbers against the notification on rbi.org.in verify. Use the FEMA due-date calculator to work out the dates for a list of shipping bills or bills of entry.
Why entries stay open
| Cause | Typical fix |
|---|---|
| Payment went through a different AD bank from the one on the shipping bill or BoE | Transfer the entry to the bank that handled the payment (the bank on record raises the request), or have the paying bank report the remittance |
| Remittance purpose code or IEC wrong, so the system could not link it | Ask the bank to correct the remittance details and link manually |
| One remittance paid several bills, or one bill was paid in parts | Give the bank an allocation sheet: remittance-wise, bill-wise amounts |
| Advance paid, but the BoE was filed late, in another port, or under another GSTIN of the same IEC | BoE copy with port and date, mapped to the advance |
| Short shipment, quality claim, discount or freight deduction | Reduction with the buyer's or supplier's correspondence, credit note and revised invoice |
| Free samples, warranty replacements, nil-value or courier BoEs | Declaration that no remittance is due, with the supporting document |
| Payment received from or made to a party other than the one on the shipping documents | Third-party documentation: tripartite agreement or letter, reason, KYC of the payer or payee |
| Exports invoiced in INR and paid through a vostro account, or settled against imports | Vostro credit advice, or set-off documentation |
| Legacy entries under an old AD code or an old IEC branch | Map old AD code to new, request transfer of entries |
Documents the bank will ask for
- Exports: shipping bill (or EDF for services), commercial invoice, packing list, bill of lading or airway bill (or LR and border documents for overland exports), IRM or FIRC details, eBRC from the DGFT portal where generated, buyer correspondence for any reduction.
- Imports: bill of entry, supplier's invoice, transport document, SWIFT copy (MT103) of each remittance, Form A1 or the bank's remittance application, contract or purchase order showing payment terms.
- Both: the bank's closure annexure in its format, a covering letter signed by an authorised signatory, and a CA certificate where the bank's SOP requires one for the amount or the case.
Matching logic
- Start from the bank's outstanding report, not your books. Download or request it as on a date, by IEC and AD code.
- Work supplier by supplier (or buyer by buyer) in the bill currency. Never add USD, EUR and GBP into one total.
- Apply FIFO unless the remittance itself names the invoices it pays: the oldest open bill takes the oldest unallocated remittance.
- Record partial settlements line by line: amount allocated, balance left open on each bill and each remittance.
- Separate the residue into: (a) differences within ₹10 lakh per entry that can be closed by declaration; (b) reductions needing bank evaluation; (c) set-off cases; (d) third-party cases; (e) genuinely unpaid amounts that need payment or an extension.
- Prepare the bank annexure in the bank's columns (bill number, date, port, amount, remittance reference, amount linked), with the covering letter and document index.
- Follow up and re-download the outstanding report after the bank processes it. Entries the bank could not close come back with reasons; fix and resubmit.
Caution listing and de-caution
- An exporter with export bills outstanding beyond the permitted period, without an extension, can be caution-listed. Once listed, every further export needs an irrevocable letter of credit or full advance, and each case goes through the bank's closer scrutiny.
- Under the 2026 regulations, unrealised proceeds beyond one year after the permitted period trigger the same advance or LC restriction.
- To be removed, realise or regularise the outstanding entries (realisation, reduction, extension, write-off as permitted), then ask the AD bank to recommend de-caution listing. Exporters already listed on 30 September 2026 continue under the existing orders until removed.
Running it on a finance desk
- Monthly ageing of EDPMS and IDPMS from the bank's report, tied to the books.
- One owner per bank and AD code; one folder per entry with its documents.
- Close entries as payments happen, not at year end. The bank's quarterly reminders get harder to answer with time.
- Before an IPO, open entries become a diligence question. Clear them first; see the SME IPO readiness guide.
Common questions
Do the new rules apply to entries opened before 1 October 2026?
The AD bank can now deal with older transactions that earlier needed RBI approval. Which realisation period applies to a shipment made before 1 October 2026 depends on the transition provisions; check with your bank verify.
Our supplier was paid but the BoE is in IDPMS as open. Is that a FEMA contravention?
Not by itself; it is a reporting and matching gap. It becomes a problem if it stays open and the bank cannot establish that the import was paid for or the advance was matched to goods.
Can we close a ₹50,000 difference without documents?
Entries up to ₹10 lakh can be closed on your declaration under the 2026 regulations. Keep the working and the reason on file; the bank can still ask.