EDPMS for Exports Under ₹10 Lakh: Simplified Closure, No Penalties, Quarterly Declarations

What did RBI change?

On October 1, 2025, RBI issued Circular No. 12 (A.P. DIR Series) under Sections 10(4) and 11(1) of FEMA, 1999. The circular simplifies EDPMS and IDPMS reconciliation for export and import transactions valued at ₹10 lakh or below per shipping bill.

Who benefits from this?

The ₹10 lakh threshold is per shipping bill, not per exporter. Any exporter (regardless of total annual export volume) can use simplified closure for individual shipping bills valued at ₹10 lakh or below.

Exporters who benefit most

• E-commerce sellers. Amazon, eBay, Etsy, Shopify sellers with high-volume, low-value shipments. Most individual orders are well under ₹10 lakh.
• Handicraft and artisan exporters (Small consignments to boutique buyers, typically ₹50,000) ₹5 lakh per shipment.
• Sample and trial shipments. First-time exports to new markets, product samples, small trial orders before bulk contracts.
• Freelancers and service exporters. Software developers, consultants, and designers invoicing under ₹10 lakh per project.
• High-volume exporters with mixed shipments. Even large exporters doing ₹50 crore annually have individual SBs under ₹10 lakh that qualify.

What is still required?

The circular reduces paperwork for closure, but it doesn't eliminate EDPMS obligations entirely. Here's what you still need to do:

Still mandatory

• File shipping bills. Every export shipment still requires a shipping bill on ICEGATE. EDPMS entries are auto-created.
• Repatriate proceeds. Payment must still come into India within the prescribed period of 9 months from the date of export.
• Submit declaration to AD bank. You still need to provide a written declaration confirming that export proceeds have been realised. The declaration is just simpler now.
• File eBRC on DGFT. For claiming export incentives (RoDTEP, duty drawback, AA/EPCG closure), you still need eBRC. The EDPMS simplification doesn't replace the eBRC requirement.
• Maintain records. Keep bank credit advices, platform settlement reports, and remittance references for audit purposes even if not submitted for closure.

How does the declaration process work?

Step-by-step

1. 1 Export goods and receive payment Ship goods, file SB on ICEGATE, receive payment from buyer in your AD bank account. Business as usual.
2. 2 Prepare self-declaration Draft a declaration on company letterhead stating: (a) the shipping bill numbers, (b) that export proceeds have been realised, (c) the amount and date of credit. No FIRC, SWIFT copy, or detailed mapping document needed.
3. 3 Submit to AD bank Email or submit the declaration to your AD bank's forex/trade finance desk. The bank closes the EDPMS entries based on the declaration. No back-and-forth for supporting documents.
4. 4 Bank closes EDPMS entries The AD bank reconciles the declaration against its records, closes the EDPMS entries with RBI, and confirms closure to you. Data flows to DGFT for eBRC.

How do quarterly bulk declarations work?

Instead of filing individual declarations for each shipping bill as payments arrive, you can consolidate all small-value closures into one quarterly submission. This is the biggest time-saver in the circular.

The "submit by" dates above are recommended best practice, not regulatory deadlines. The circular doesn't prescribe specific quarterly deadlines, but filing within 15 days of quarter-end keeps your EDPMS entries from aging into the caution-list zone.

What a quarterly declaration looks like

Subject: Quarterly consolidated declaration for EDPMS closure (Q2 FY 2026-27)

We hereby declare that export proceeds for the following shipping bills (each valued at ₹10 lakh or below) have been duly realised and credited to our account with your bank:

Write-offs under ₹10 lakh

One of the most valuable provisions in the circular: for shipping bills valued at ₹10 lakh or below, any reduction in export value (including partial or full non-realisation) can be permitted based solely on the exporter's self-declaration.

Previously, if a buyer didn't pay or paid less than the invoice value, you had to go through a multi-step write-off process: submit documentation to your AD bank, the bank evaluated whether the shortfall was genuine, and for amounts beyond the bank's own authority (5% of average annual turnover), RBI approval was needed.

Common write-off scenarios under ₹10 lakh

• Amazon returns. Customer returned the product and Amazon deducted the refund from your settlement. Declare the shortfall in your quarterly declaration.
• Platform commission higher than expected. Referral fees, FBA fees, or advertising costs exceeded the estimate. Realised amount is lower than FOB.
• Buyer default on small order. Sample buyer never paid. Declare as non-realised in your quarterly declaration instead of chasing write-off approval.
• Currency loss. Exchange rate moved against you between shipment and payment. The INR equivalent is lower than the SB value.

What about FEMA 2026?

RBI issued FEMA Notification No. 23(R)/2026-RB on January 13, 2026, which is a comprehensive overhaul of India's export-import regulatory framework. It takes effect on October 1, 2026, and supersedes the existing FEMA (Export of Goods & Services) Regulations 2015 along with 167 prior circulars.

Action checklist

Set up once

• Inform your AD bank's forex desk that you want to use the simplified closure process under RBI Circular No. 12
• Ask if your bank has a preferred declaration template or email format
• Set up a spreadsheet or system to track shipping bills under ₹10 lakh separately from higher-value ones
• Confirm your bank will not levy penal charges on small-value EDPMS delays (cite the circular if needed)

Every quarter

• Compile all shipping bills under ₹10 lakh from the quarter where payment has been received
• Match each SB to its bank credit reference (or platform settlement reference for e-commerce)
• Note any shortfalls (returns, fee deductions, non-realisations) with a brief reason
• Draft consolidated declaration with the full SB table
• Submit to AD bank forex desk within 15 days of quarter-end
• Confirm bank has closed the EDPMS entries within 2 weeks of submission
• File eBRC on DGFT portal for the closed entries (needed for incentive claims)

Update history

• 2026-08-10 First published.