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RBI: Submission on draft Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2025
RBI: Submission on draft Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2025

May 1, 2025

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The Reserve bank of India (RBI) released the draft Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2025 to streamline export and import transactions, aiming to enhance ease of doing business.

In response to this, nasscom provided industry feedback on the draft regulations highlighting the following points:

  1. Rather than requiring exporters to duplicate information by filing Export Declaration Form (EDF), a more efficient approach would involve establishing robust data integration mechanisms between the GST authorities and the RBI. This would allow for automatic population of common data fields in the EDF using information already submitted through GST returns.
  2. Allow exporters to file a single EDF accompanied by a comprehensive Annexure 1-A that consolidates all invoice details, regardless of individual invoice values.
  3. Provide a standardised list of essential documentation required for export verification.
  4. Allow exporters to submit documentation within 30 days from the end of the month in which invoices are issued.
  5. AD banks should be authorised to credit export proceeds to exporters' accounts immediately upon receipt, without waiting for complete documentation or EDPMS portal entry closure. Similarly, in case of e-commerce exports, payments should be credited to the exporter’s account without waiting for the closure of entry on the EDPMS portal.
  6. For e-commerce exporters, realisation timeline for exports should be linked with the export date rather than the variable sale dates of individual items.
  7. Issue detailed implementation guidelines for the AD banks to ensure that payments made to third parties for imports are accepted by the AD banks
  8. Provide a maximum time limit within which payment needs to be made for imports by the importer.
  9. The cap for unrealised exports value should be fixed to INR 25 crore or a certain percentage of annual export turnover of the company, whichever is higher. A similar percentage may be prescribed for imports not materialised. Further, RBI should exempt large and established service exporters with four or five-star export house certification from these restrictions.
  10. Need for a harmonised framework with standardized minimum requirements.

Our submission to RBI is attached for your reference. Please write to tejasvi@nasscom.in in case you need any clarification.


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20250430-RBI_ExportImport_nasscomsubm.pdf

Tejasvi

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