You paid in advance for an import and the Bill of Entry is still open

What is your AD bank actually asking for?

The artefact in your inbox is a regulatory deviation letter from your Authorised Dealer bank. It lists your open regulatory items and asks you to cooperate in "zeroizing these regulatory deviations". These letters usually carry four item types at once (two on the export side and two on the import side) which is why importers so often answer the wrong one.

The item this page covers appears in the bank's own words as "BOE. Advance import payment made, BOE/IDPMS details to be shared" , with the ask stated as "share details of the Bill of Entry against the advance import remittances made".

In plain terms: you sent foreign currency out of India before the goods arrived. Your bank recorded that outward remittance in IDPMS as an Outward Remittance Message (ORM) . Until a Bill of Entry is matched against that ORM, the bank's system shows an outward flow of foreign exchange with no proof that goods ever came into India. And the bank is regulatorily obliged to chase you for that proof.

Three things matter here that the letter itself does not say.

What the letter leaves unsaid

• The obligation is yours. It sits on you as importer, not on your customs broker and not on the overseas supplier. Your broker filed the Bill of Entry; only you can tell the bank which remittance it belongs to.
• Value is irrelevant to the obligation. Para C.7.1(i) applies "irrespective of the value of foreign exchange remitted / paid for import into India". A USD 3,000 advance carries the same evidence obligation as a USD 300,000 one. The USD value thresholds in paras C.1.1 and C.1.4 only govern whether a standby letter of credit or guarantee was needed for the advance itself. They do not change the evidence deadline.
• In the ordinary EDI case the bank wants data, not paper. BOE number, port code, BOE date. Sending a courier envelope of photocopies is usually the slower answer, not the safer one.

For the other items on the same letter, see our guides on IDPMS Bill of Entry status (imports made, payment pending), EDPMS reporting (export made, realisation pending) and small-value EDPMS and IDPMS closure .

Is your entry Outstanding or Overdue, and what does Overdue actually cost you?

The letter puts every item into one of two buckets, and it defines them itself, because these definitions appear nowhere else you are likely to find them:

The bank's two status terms

• Outstanding. The item is open but still within the stipulated timeline for submission.
• Overdue. The item has crossed the stipulated timeline for submission.

What actually follows once an item crosses the line splits into what the Master Direction says and what happens in practice.

What the Master Direction says. Where documentary evidence of import has not been furnished within three months of remittance, the AD Category-I bank must rigorously follow up for the next three months, using various modes of communication, with at least one communication sent by registered letter (para C.10(i), FED Master Direction No. 17/2016-17). And unsettled Outward Remittance Messages must be followed up on an ongoing basis (para C.8(xvi)). The entry never ages out, never lapses, and does not quietly disappear.

The registered letter is worth watching for specifically. It is the bank discharging a regulatory duty, and it simultaneously creates a record of notice against you. Respond to it in writing, and keep the acknowledgement.

What happens in practice. These consequences are practical rather than penal, and worth stating plainly:

Practical effect of sitting overdue

• Your AD bank will typically decline to process further advance remittances for you while items sit overdue.
• Requests to open fresh letters of credit tend to stall at the same desk, for the same reason.
• An unclosed entry beyond the permitted period is a FEMA contravention, and the file stays live until it is settled or closed.

How long do you have after the advance payment to prove the goods arrived?

The operative benchmark is three calendar months from the date of remittance . Para C.7.1(ii) of FED Master Direction No. 17/2016-17 lets the AD bank, where the importer has genuine reasons, allow reasonable time "not exceeding three months from the date of remittance" to submit the evidence of import. Para C.10(i) uses the same three-month point as the trigger for the bank's follow-up duty.

So what about the 90 days on your letter? The regulation is expressed in months, not days. Three calendar months is between 89 and 92 actual days depending on which months are spanned, so a system counting a flat 90 days will flag some items one or two days early. This is a rounding difference, not a wrong rule. The bank's figure is substantively correct as a prompt, and you should treat the letter as real.

Now the part most importers do not know. A materially longer outer limit exists for advance remittances generally. The standard advance-remittance condition at para C.1.3 is that physical import of goods into India is made within six months (three years in the case of capital goods) from the date of remittance , and that the importer undertakes to furnish documentary evidence of import within fifteen days from the close of that period.

So where goods legitimately arrive after month three, the compliant path is six months (or three years for capital goods) plus fifteen days. The three-month point is when the bank starts chasing you; it is not the point at which you become non-compliant with the import condition.

Finally, keep the second clock separate in your head. Once goods are shipped, settlement of import dues runs six months from the date of shipment under para B.5.1(i). Not 180 days from the Bill of Entry date, as bank systems often display. The direction of that error matters: the BoE date is later than the shipment date, often by two to six weeks on ocean cargo, so a 180-day-from-BoE counter flatters you and will not warn you before the statutory limit passes.

Two carve-outs on that second clock. Deferred payment arrangements, including suppliers' and buyers' credit, are treated as trade credits under para B.5.2 and are not six-month items at all. And where a genuine delay in settlement arises, extension is available from the AD bank itself under para B.5.4. Up to six months at a time, to a maximum of three years, where the reasons are genuine, the importer is not under investigation and the bank is satisfied as to bona fides, without any reference to RBI.

Which documents actually satisfy the evidence-of-import requirement?

Deadline coverage always skips this half of the problem. Start with the single most important distinction: in the ordinary EDI-port case what you owe the bank is three data fields, not a document set . Submission of the hardcopy Exchange Control copy of the Bill of Entry has been discontinued (para C.8(iii)). What the bank needs is the BOE number, the port code and the BOE date, so that it can locate the entry in BOE Master and settle it against the ORM.

The exceptions are where importers get stuck. Non-EDI and manual Bills of Entry, courier imports, Customs Assessment Certificate cases and Postal Appraisal Form cases have no auto-fetch in IDPMS at all, and must be submitted by the importer in physical or scanned form.

What each document proves

• Request Letter. Your formal instruction to the bank identifying which outward remittance and ORM is to be regularised, and against which Bill of Entry, carrying the remittance reference the bank needs to make the match. It is the spine of the reply pack. It is bank- operational documentation, not a form prescribed by name in the Master Direction.
• Bill of Entry, or its number, port code and date. Customs' certification that the goods entered India, with the assessed value. This is the proof of import itself.
• Outward remittance advice or SWIFT copy. Fixes the date and amount of the advance, which is what the three-month clock runs from.
• Commercial invoice. The declared value against which the remittance is measured.
• Bill of Lading, Airway Bill or motor transport document. Proves the goods physically moved and fixes the shipment date, which matters for the separate six-month payment clock. Name the road transport document explicitly if you import across a land border; those consignments are routinely overlooked.
• Packing list. Ties invoice value to the physical consignment where the bank needs to satisfy itself on bona fides.
• Customs Assessment Certificate or Postal Appraisal Form. The substitute evidence of import for postal and certain courier consignments where no ordinary Bill of Entry exists.
• Where the goods have not arrived. A supplier confirmation, the purchase order and a shipment schedule, supporting a request for reasonable time.

How does the Bill of Entry reach IDPMS from ICEGATE, and why is your entry still showing open?

Walk the mechanism end to end once and you can reason about your own case instead of guessing.

Advance remittance to IDPMS closure

1. :

That many-to-many settlement in step 4 is exactly how part- advances and split shipments are handled, and it is worth remembering before you conclude that your numbers do not tie.

Now the real question: the goods cleared months ago, so why is the entry still open? The concrete failure modes are these.

Why an entry stays open after clearance

• The AD code declared at Customs belongs to a different bank or a different branch from the one holding the remittance, so the bank writing to you cannot see the BoE at all.
• The import cleared at a non-EDI port or on a manual BoE , so nothing was ever pushed to BOE Master.
• It was a courier, postal or Customs Assessment Certificate case, where there is no auto-fetch.
• The ORM and BoE values do not tie , so the settlement message will not go through.
• The BoE simply has not been linked , because the bank has no instruction from you telling it which BoE belongs to which remittance.

The practical consequence is that the bank's letter is your only visibility . Do not try to verify the position yourself. Ask the bank in writing for the ORM reference and the full list of open items, and expect an acknowledgement slip in return for a submission rather than any kind of system access.

What if the import is cancelled and the advance has to come back?

The supplier never shipped, the order was cancelled, the goods were rejected before dispatch, or the supplier has gone under. The logic first: the open item in IDPMS is an outward flow of foreign exchange with no corresponding inward movement of goods. There are only two ways to square that. Goods arrive and a Bill of Entry settles the ORM, or the money comes back to India and the inward refund evidences the reversal.

If the import is dead, the second route is the only one. And the entry does not quietly disappear because the deal fell through: unsettled ORMs are followed up on an ongoing basis under para C.8(xvi).

The refund evidence pack

• Cancellation correspondence, or the amended purchase order.
• The supplier's written confirmation of the refund.
• The inward remittance advice for the returned funds, naming your original outward remittance.
• A Request Letter linking the refund back to the specific ORM.

The partial cases are worth naming explicitly. Partial shipment with partial refund is handled by the BoE settling part of the ORM and the refund evidencing the rest. Short shipment or destruction of goods is handled under para C.8(xi), which permits the AD bank to consider closure involving write-off arising from quality issues, short shipment or destruction of goods, subject to satisfactory documentation.

Two cautions on those closures. They are performed by the AD bank on its own due diligence, and the outcome depends on the quality of your documentation. Not on you asserting that the import was cancelled.

Finally, the guarantee angle where it applies. If the advance was covered by a standby letter of credit or a bank guarantee because it exceeded the value thresholds in paras C.1.1 and C.1.4, invoking that instrument is the commercial route to recovering the funds. The recovery still has to be evidenced back to the ORM.

What if the Bill of Entry value does not match what you remitted, or the entry is a small one?

Most importers who receive one of these letters are looking at a handful of unresolvable small items rather than one big one. Three closure levers exist for that awkward tail.

First lever: the small-value declaration route. Since A.P. (DIR Series) Circular No. 12 dated October 01, 2025 (RBI/2025-26/89), for IDPMS entries of Rs 10 lakh or less per entry or bill, the entry may be reconciled and closed on the basis of a declaration by the importer that the amount has been paid, and declarations may be given quarterly in consolidated form covering multiple bills.

Be precise about what that changes. It removes the documentary burden, not the bank's role: the AD bank still executes the closure and still applies its own due diligence. For an importer facing a long tail of small overdue entries this is the single most useful lever available. Ask your AD bank for its declaration format and its quarterly consolidation cut-off, since the format is bank-operational.

Second lever: the operational variance write-off. Where the amount declared in the Bill of Entry varies from the actual remittance due to operational reasons (exchange rate movement between remittance and assessment, freight or insurance treatment, rounding, or bank charges deducted in the correspondent chain) AD banks may consider closure of the BoE/ORM in IDPMS involving write-off to the extent of 5 percent of invoice value (para C.8(x)).

Third lever: the substantive write-off. Closure is also permitted where the write-off arises from quality issues, short shipment or destruction of goods, subject to satisfactory documentation (para C.8(xi)).

For either write-off lever, give the bank a reconciliation statement : the remitted amount, the BoE assessable value, the difference, and the cause of the difference. With the supporting document for that cause attached.

Every advance-import deviation resolves into one of four replies: BOE details for an already-cleared EDI import; a full physical document set for a non-EDI, manual, courier or postal import; a supported request for reasonable time where the goods are legitimately still in transit inside the six-month (or three-year capital goods) window; or evidence of the inward refund where the import has been cancelled. Identify the remittance date and the clearance status first, and the correct reply follows mechanically. What you never do is try to close the entry yourself, because closure is an act the AD bank performs inside IDPMS. </> } steps= , , , , , ]} />

Meridian Components Pvt Ltd, a Pune-based importer, wires an advance of USD 48,000 to a supplier in Shenzhen for machine spares. The bank's outward remittance advice shows a value date of 12 March 2026. The goods are delayed at the supplier's end. On 15 June 2026 a regulatory deviation letter arrives from the AD bank, listing the item as Overdue with the note "90 Days from Import Payments being made". The goods are in fact shipped on 02 June 2026 and the Bill of Entry is filed at Nhava Sheva (port code INNSA1) on 21 June 2026. USD 6,000 of the invoice value was held back and is still unpaid. </> } result= >

The response. Because Nhava Sheva is an EDI port, the BoE is in BOE Master and the bank can download it under para C.8(iii). Provided the AD code declared to Customs is the code of the branch holding the remittance. Meridian's finance team checks the AD code on the BoE, confirms it matches, and sends a Request Letter on 24 June quoting the bank's letter reference, the outward remittance date and amount, and the BoE number, port code INNSA1 and BoE date 21 June 2026, with the commercial invoice and the outward remittance advice attached. No hardcopy Exchange Control copy is sent, because that requirement has been discontinued. The letter also asks the bank to confirm the ORM reference and to list any other open items, and separately diarises 02 December 2026 for the USD 6,000 balance.

Reply pack for an open advance-import Bill of Entry

Work through the branch that matches your case and hand it to your accounts team. Sending the wrong pack is the main cause of a second letter.

Branch A. Goods cleared at an EDI port under this bank's AD code

• Request Letter identifying the outward remittance and the Bill of Entry to be matched against it
• BOE number, port code and BOE date
• Outward remittance advice or SWIFT reference
• Commercial invoice
• Not the hardcopy Exchange Control copy of the Bill of Entry. That requirement has been discontinued

Branch B. Non-EDI port, manual BoE, courier, postal or Customs Assessment Certificate case

• Everything in Branch A
• The physical or scanned Bill of Entry
• Customs Assessment Certificate or Postal Appraisal Form, as applicable
• Transport document. Bill of Lading, Airway Bill or motor transport document
• Packing list, where the bank asks for it

Branch C. Goods not yet arrived, inside the six-month (or three-year capital goods) advance-remittance window

• Request Letter explaining the position and asking for reasonable time
• Supplier confirmation and a revised shipment schedule
• Purchase order or contract
• Booking or vessel documentation, where available
• An undertaking to furnish documentary evidence of import within fifteen days of the close of the relevant period

Branch D. Import cancelled

• Cancellation correspondence or amended purchase order
• Supplier refund confirmation
• Inward remittance advice for the returned funds, referencing the original outward remittance
• Request Letter linking the refund to the specific ORM

Branch E. Entry of Rs 10 lakh or less

• The bank's declaration format, confirming the amount has been paid
• Give it quarterly in consolidated form across several bills, under A.P. (DIR Series) Circular No. 12 dated October 01, 2025

Do not skip these, whichever branch you are on

• Send the reply in writing and keep the acknowledgement. You have no way to verify the IDPMS position yourself.
• Ask the bank for the ORM reference and the full list of open items in the same reply, so you fix the whole tail at once.
• Quote the bank's own reference number from the deviation letter.
• Check the AD code declared to Customs against the bank holding the remittance before assuming the bank can auto-fetch.
• Reply even when you cannot fully resolve the item. A documented explanation on file is materially better than silence against a registered letter.

Update history

• 2026-08-14 First published.