EDPMS caution list: what it is and how removal works

Key points

Regulation 13 does not create a new caution list. It restricts further exports when proceeds are unrealised for more than a year past the due date or an extension.
The proviso keeps exporters who were on the caution list on 30 September 2026 under the order that listed them, until they are removed.
From 9 October 2020, listing was on the AD bank's recommendation to the RBI regional office, not an automatic two-year trigger. That circular is in the annex superseded on 1 October 2026.
While a caution listing is in force, the 2016 handling rule that the 2020 circular left in place required a full advance or an irrevocable letter of credit before the bank would handle the shipping documents.
The 2026 regulations do not set out the steps for removal. Ask the AD bank that holds the listing what it will recommend now.

The rule that applies from 1 October 2026

Regulation 13 of the Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026 says that if export proceeds remain unrealised beyond one year from the due date of realisation, or from an extended period the authorised dealer allowed, the exporter shall undertake further exports only against receipt of a full advance or an irrevocable letter of credit.

That is a condition on the next export. The regulation does not say the exporter is placed on a caution list, and it does not describe an application to RBI. The year runs from the due date, not from the date of shipment. The due date is the end of the realisation period in regulation 5, nine months or twelve when invoiced or settled in rupees, unless the bank has extended it. An extension that the bank has granted pushes this one-year count out with it.

Clearing the open EDPMS entries, or getting the extension before the due date, is what keeps an exporter off this restriction. The guide to an entry that will not close is the practical next step when the money has already arrived and the bill is still open.

Who was caution-listed, and why that procedure changed

Until 30 September 2026 the caution list was an RBI list of exporters. A.P. (DIR Series) Circular No. 74 of 26 May 2016 put the listing and de-listing onto EDPMS. As first written, an exporter was caution-listed if any shipping bill stayed open for more than two years and no extension had been granted, and was de-caution-listed automatically once the bills were realised and closed or an extension was granted. The same circular also allowed an earlier listing on the bank's recommendation, where the exporter had come to the notice of the Enforcement Directorate, the CBI, the Directorate of Revenue Intelligence or another agency, or was not traceable, or was not making serious efforts to realise the proceeds.

A.P. (DIR Series) Circular No. 03 of 9 October 2020 withdrew those two automatic limbs, paragraphs 3(1)(i) and 3(1)(ii) of the 2016 circular. From then, the Reserve Bank caution-listed an exporter on the recommendation of the AD bank, based on the exporter's track record with the bank and with investigative agencies. The bank recommended listing to the regional office of the Foreign Exchange Department where the exporter had come to the adverse notice of those agencies, or was not traceable, or was not making sincere efforts to realise the proceeds. De-caution listing was also a recommendation from the bank to that regional office, under the procedure then laid down. The 2020 circular left the handling of shipping documents, paragraph 3.2 of the 2016 circular, unchanged.

What a listing did to the next shipment

Under the 2016 paragraph that stayed in force after 2020, the bank told the exporter it had been listed and which shipping bills were outstanding. It could accept shipping documents for negotiation, purchase, discount or collection only if the exporter showed a full advance or an irrevocable letter of credit for the full value. A usance bill needed the letter of credit to cover the full value and to permit the drawing, and the bill had to mature inside the realisation period. Outside those cases the bank was not to handle the documents. A guarantee for a caution-listed exporter needed the Reserve Bank's prior approval.

Both circulars are in the annex to A.P. (DIR Series) Circular No. 20 of 16 January 2026, which superseded them from 1 October 2026. They are the history of how someone got onto the list. They are not the instruction for a new listing after that date.

Exporters who were already on the list

The amendment of 22 September 2026 added a proviso to regulation 13: exporters on the caution list as on 30 September 2026, under orders the Reserve Bank issued under regulation 16 of the 2015 export regulations, continue to be governed by that order until the exporter is removed from the caution list.

The 2026 regulations do not say who files the removal, what papers close it, or how long it takes. The last procedure published for removal is the one in the 2020 circular: the AD bank recommends de-caution listing to the regional office. That circular has since been superseded for new cases. If you were on the list on 30 September 2026, ask the AD bank that deals with the listing which office still holds the order and what it will now send. This guide will not invent a form or a timeline RBI has not published for the removal.

What to do before the year runs out

Match every open shipping bill to a receipt, an extension or a reduction while it is still inside the realisation period. A bill of up to ₹10 lakh can be closed on a declaration, and the declarations may go in quarterly. A bill that will be paid late needs the extension before the due date, because the one-year count in regulation 13 starts at that due date or at the end of the extension.

The FxLayer platform reads the bank's outstanding list into the EDPMS check and prepares the closure, transfer and extension letters from the records. It does not caution-list or de-list anyone, and it does not write to RBI. Removal, where an old order still applies, is between the exporter, the AD bank and the Reserve Bank.

Questions

Not by itself, from 1 October 2026. The regulations no longer describe an automatic listing. If the proceeds are still unrealised more than a year after the due date or the bank's extension, further exports are only against a full advance or an irrevocable letter of credit.

Yes, if you were on the list on 30 September 2026 under an order issued under the 2015 regulations. That order continues until you are removed. The 2026 text does not set out a new removal process.

That was paragraph 3(1)(i) of the circular of 26 May 2016. The circular of 9 October 2020 withdrew it. Listing then depended on the AD bank's recommendation. Both circulars were superseded on 1 October 2026.

Only against a full advance or an irrevocable letter of credit, which is what regulation 13 says. Realising or regularising the overdue bills is what brings later exports back to ordinary terms. Confirm with your AD bank that it has marked the entries off.

Sources

This article is general information on Indian foreign exchange and tax rules as they stood on the date shown. It is not legal or tax advice. Rules and limits change; confirm the current position with your AD bank, the relevant RBI Master Direction or your adviser before acting.

The EDPMS caution list: who was on it, what it did, and what applies now