RBI Compliance
Every RBI Form Indian Exporters Need. Complete Guide
GR/SDF, SOFTEX, BCX, ENC, Schedules 3-6, EEFC, ECB forms, A2, FC-GPR. Which forms you file, which your bank files.
By Aaryan Kakani · · 15 min read
The RBI Forms Ecosystem. What Exporters Need to Know
The Reserve Bank of India maintains a forms directory at rbi.org.in > Forms > BS_ViewForms.aspx that currently lists approximately 105 forms. These span banking supervision, monetary policy, FEMA (Foreign Exchange Management Act) compliance, and payment systems. If you are a goods exporter, most of them are irrelevant to your work.
The forms that matter to exporters fall into three categories:
Export declaration forms
GR/SDF, SOFTEX. These declare that goods or services have been exported and trigger the FEMA obligation to realise proceeds within the prescribed period. Filed by the exporter (now electronically).
Bank reporting forms
Schedules 3-6, ENC, BCX. These track the flow of export proceeds from the overseas buyer to the exporter's bank account. Filed by the Authorised Dealer (AD) bank, but the exporter provides the underlying data.
Capital account and borrowing forms
ECB forms, FC-GPR, FC-TRS, A2, EEFC. These come into play when an exporter borrows in foreign currency, receives foreign investment, or operates a foreign currency account. Not every exporter needs these, but they are important for growing export businesses.
GR Form / SDF Declaration
The GR (Guaranteed Remittance) Form was historically the most important RBI form for goods exporters. Every consignment shipped out of India required a GR form declaring the value, description, and buyer details. The Statutory Declaration Form (SDF) served a similar purpose for exports through EDI-enabled ports.
What happened to the GR Form?
In 2014, RBI replaced physical GR/SDF filing with electronic reporting through EDPMS (Export Data Processing and Monitoring System) . Shipping bill data now flows automatically from ICEGATE (Customs) to EDPMS, and your AD bank monitors realisation against this data.
You no longer fill out a paper GR form. But the concept is alive and well. Every EDPMS entry is essentially a digital GR record. When your bank says "your GR is open," they mean your EDPMS entry shows unrealised export proceeds. When RBI circulars reference "GR/SDF forms," they mean the electronic equivalent in EDPMS.
| Aspect | Old GR/SDF (Physical) | Current (EDPMS Electronic) |
|---|---|---|
| Filing method | Paper form at customs port | Automatic via ICEGATE-EDPMS integration |
| Who initiates | Exporter prepares, customs countersigns | Shipping bill filing triggers EDPMS entry |
| Copies | Original + duplicate (bank copy) | Single electronic record, bank has real-time access |
| Tracking | Manual follow-up with bank | Automated alerts for unrealised proceeds |
| Closure | Bank marks as realised, sends to RBI | Bank closes EDPMS entry, RBI sees real-time |
| Overdue follow-up | RBI circular letter to AD bank | Automated caution-listing via EDPMS |
SOFTEX Form. Software and IT Service Exports
The SOFTEX form is the declaration for software and IT/ITeS service exports, analogous to what the GR/SDF form does for goods exports. It is filed with the designated authority. Typically STPI (Software Technology Parks of India) or the SEZ Development Commissioner.
When does a goods exporter need SOFTEX?
If you are a pure goods exporter, you generally do not file SOFTEX. But two situations bring it into play:
- Mixed exports: Your company exports both physical goods and software/IT services. The goods go through customs (shipping bill → EDPMS), but the services component needs a SOFTEX declaration.
- Embedded software: You export hardware with significant embedded software value. For example, industrial controllers, medical devices, or IoT equipment. If the software is invoiced separately or if customs splits the goods and services components, SOFTEX may be required for the software portion.
SOFTEX filing is now electronic through the STPI or SEZ portal. The form captures contract details, invoice value, buyer information, and the mode of delivery (electronic transmission vs physical media). STPI certifies the form and forwards the data to RBI, which creates a corresponding entry for monitoring realisation of service export proceeds.
Form BCX. Bank Certificate for Export Proceeds
Form BCX is the Bank Certificate for Export Proceeds. It is issued by your Authorised Dealer bank to formally certify that export proceeds against a specific shipping bill (or set of shipping bills) have been received in India within the prescribed FEMA timeline.
When you need Form BCX
- Claiming export incentives (RoDTEP, MEIS legacy, Duty Drawback) where proof of realisation is required
- Responding to FEMA audit queries or show-cause notices from RBI
- DGFT requests for proof of realisation against advance authorisation or EPCG obligations
- Bank finance applications where export track record matters
- Tax assessments where the assessing officer questions export income
The AD bank generates Form BCX from EDPMS data. This means your EDPMS entries must be clean and closed before you can request it. If there are mismatches between the shipping bill amount and the realised amount (due to buyer deductions, discounts, or commission adjustments), the bank will need supporting documentation before issuing BCX.
ENC Form. Export Bills Negotiation/Collection
The ENC (Export Negotiation/Collection) Form tracks export bills that the AD bank handles on behalf of the exporter. Either through negotiation (the bank pays the exporter upfront and collects from the buyer) or collection (the bank sends the bill to the buyer's bank and remits proceeds upon receipt).
How ENC relates to export financing
When you ship goods on a documentary collection basis (D/P or D/A terms), the AD bank uses the ENC form to log the bill. The form captures:
- Shipping bill number and date
- Invoice value in foreign currency
- Terms of payment (sight, usance, deferred payment)
- Whether the bill is negotiated (bank has extended credit to exporter) or on collection basis
- Due date for payment from the overseas buyer
- Correspondent bank details for the buyer's side
For exporters using Letter of Credit (LC) terms, the ENC form is filled when the bank negotiates the LC documents. For open account transactions (where the buyer pays directly via wire transfer), ENC is less relevant because there is no bill negotiation or collection. Proceeds simply arrive in the exporter's account and the bank matches them to EDPMS entries.
Schedules 3, 4, 5, and 6. RBI Reporting Returns
Schedules 3 through 6 are periodic returns that AD banks file with RBI to report on export-related foreign exchange flows. While the bank files these, the underlying data comes from you, the exporter. Errors in your data become errors in these schedules, which triggers RBI scrutiny directed back at you.
| Schedule | Full Name | What It Reports | Frequency | Exporter's Role |
|---|---|---|---|---|
| SCH-3 | Payment Schedule for Export Proceeds | Payments received by the bank against export shipments | Monthly | Ensure remittance references match shipping bills |
| SCH-4 | GR/PP Form Status Report | Status of each GR/PP (now EDPMS) entry. Realised, pending, overdue | Monthly | Close EDPMS entries on time; provide BRCs for partial realisations |
| SCH-5 | Advance Remittance for Exports | Advance payments received from overseas buyers before shipment | As received | Report advance receipts to bank with contract/order details |
| SCH-6 | Write-off / Extension Requests | Requests to write off unrealised export proceeds or extend the realisation period | As needed | Prepare write-off application with supporting evidence |
Schedule 3 (SCH-3). Payment Schedule
This is the bread-and-butter schedule. Every time export proceeds hit your bank account, the AD bank reports it under SCH-3. The data must match the EDPMS entry. Same shipping bill number, same currency, and the amount must reconcile (allowing for bank charges, exchange rate differences, and buyer deductions documented via credit notes). If your buyer pays in multiple tranches, each tranche creates a separate SCH-3 entry linked to the same EDPMS record.
Schedule 4 (SCH-4). GR/PP Form Status
SCH-4 is the surveillance schedule. It tells RBI the status of each export declaration. Fully realised, partially realised, or overdue. This is the schedule that feeds into caution-listing decisions . An exporter with many "overdue" entries on SCH-4 will draw RBI attention faster than one with a few scattered partial realisations.
Schedule 5 (SCH-5). Advance Remittances
When an overseas buyer sends advance payment before you ship the goods, the AD bank reports this under SCH-5. The advance must be adjusted against a subsequent shipment within the prescribed period. Exporters who receive advances must ensure they (a) inform the bank immediately with the buyer's order reference, (b) ship goods within the timeline, and (c) link the advance to the correct shipping bill when filing. Un-adjusted advances are a red flag in RBI's monitoring.
Schedule 6 (SCH-6). Write-off and Extension
If export proceeds cannot be realised (buyer insolvency, goods rejected, trade dispute) the exporter applies through the AD bank for a write-off or extension of the realisation period. The bank files this under SCH-6 with supporting documentation: correspondence with the buyer, legal notices, ECGC claim status, and the exporter's own write-off approval from their board (for amounts above the AD bank's delegation limit). RBI allows AD banks to write off amounts up to a threshold on their own authority; larger amounts require RBI approval.
EEFC Account Forms. Retaining Export Earnings in Forex
The Exchange Earners' Foreign Currency (EEFC) account allows exporters to hold export proceeds in foreign currency instead of immediately converting to INR. This is useful if you have upcoming import payments, overseas travel expenses, or other permissible current account debits in foreign currency.
Opening and operating an EEFC account
There is no single standalone RBI form for EEFC. The process is governed by FEMA Notification No. 10(R)/2015 and your AD bank's application format. The steps are:
- Submit your AD bank's EEFC account opening application form (each bank has its own format compliant with RBI guidelines)
- Provide proof of export earnings. Recent shipping bills, BRCs, or EDPMS statements showing regular export realisation
- Declare the currencies you want to hold (typically USD, EUR, GBP)
- Sign the terms and conditions covering utilisation restrictions, balance limits, and conversion requirements
| EEFC Rule | Details |
|---|---|
| Retention limit | Up to 100% of export proceeds can be credited to EEFC |
| Balance utilisation | Must be used for permissible current account transactions or converted to INR within the prescribed period |
| Permissible debits | Import payments, business travel, freight, commission to overseas agents, approved capital account transactions |
| Interest | No interest is paid on EEFC account balances |
| Interbank transfer | EEFC balance can be transferred to the same entity's EEFC account at another AD bank |
ECB Forms. External Commercial Borrowings
External Commercial Borrowing (ECB) forms come into play when an exporter borrows in foreign currency from an overseas lender. A foreign bank, international financial institution, overseas branch of an Indian bank, or even a foreign equity holder.
Form ECB (formerly ECB-1). Registration
Filed when the ECB is first drawn down. The AD bank submits this to RBI on behalf of the borrower (your export company). The form captures: borrower details, lender details, loan amount, currency, all-in-cost (interest rate plus fees), minimum average maturity period, end-use of funds, and the repayment schedule. RBI allocates a Loan Registration Number (LRN) upon successful filing.
Form ECB-2. Monthly Reporting
Filed monthly by the AD bank to report actual transactions against the registered ECB. Drawdowns, interest payments, principal repayments, and outstanding balance. Even months with no activity require a nil return. Missing ECB-2 filings trigger RBI compliance notices.
Common reasons exporters raise ECBs include expanding manufacturing capacity for export production, purchasing capital goods (CNC machines, packaging lines), and refinancing existing expensive rupee borrowing with cheaper foreign currency debt. The ECB must comply with RBI's framework on all-in-cost ceiling, minimum average maturity (3 years for most categories), end-use restrictions, and hedging requirements.
FLM-8. Foreign Exchange Dealer Licence Form
FLM-8 is the application form for entities seeking to become Authorised Dealers (ADs) or Authorised Money Changers under FEMA. This form is not something a typical goods exporter fills out. However, understanding it helps in two contexts:
Large export houses with treasury operations
Some large export conglomerates apply for an AD Category II or Category III licence to handle their own forex transactions (and sometimes those of group companies). FLM-8 is the application they file with RBI. This is rare and typically involves companies with forex turnover exceeding several hundred crore annually.
Choosing your AD bank
When evaluating AD banks for export transactions, knowing that the bank had to go through FLM-8 and RBI's licensing process means they are bound by specific reporting obligations, net worth requirements, and compliance standards. Full-service AD Category I banks (all scheduled commercial banks) offer the most comprehensive forex services for exporters.
A2 Form. Capital Account Transactions
Form A2 is used for outward remittances from India for capital account transactions that do not fall under the Liberalised Remittance Scheme (LRS). For exporters, A2 becomes relevant in specific situations involving overseas investments or establishment of foreign offices.
When exporters use A2
- Setting up an overseas subsidiary or branch: Remitting capital for establishing a warehouse, sales office, or marketing subsidiary abroad
- Overseas direct investment (ODI): Investing in a foreign joint venture or wholly-owned subsidiary to strengthen your export distribution network
- Guarantee issuance: Issuing guarantees on behalf of overseas subsidiaries or step-down entities involved in export activities
- Certain commission/royalty payments: Payments to overseas agents that fall under capital account classification rather than current account
Form A2 is submitted to the AD bank along with supporting documentation. Board resolution, valuation certificate (for investments), RBI approval letter (if under the approval route), and the underlying agreement. The bank verifies FEMA compliance and processes the remittance. Many banks now accept A2 submissions electronically, though some still require a physical signature.
Form FC-GPR / FC-TRS. Foreign Investment Reporting
These forms become relevant when your export company receives foreign investment. Either as fresh equity from an overseas investor (FC-GPR) or upon transfer of shares from a resident to a non-resident (FC-TRS).
Form FC-GPR. Foreign Currency-Gross Provisional Return
Filed when your company issues shares to a non-resident investor. The AD bank submits this through the FIRMS portal (Foreign Investment Reporting and Management System) within 30 days of allotment. The form captures: company details, investor details, number and type of shares allotted, pricing (must comply with FEMA pricing guidelines), sector classification, and compliance with sectoral caps. For export companies in manufacturing, 100% FDI is typically permitted under the automatic route.
Form FC-TRS. Foreign Currency Transfer of Shares
Filed when existing shares of your company are transferred between a resident and non-resident. For example, a promoter selling shares to a foreign PE fund, or a foreign partner exiting by selling shares to an Indian buyer. Filed within 60 days of transfer via the FIRMS portal. Requires a FEMA-compliant valuation from a chartered accountant or SEBI- registered merchant banker.
Both forms are now filed electronically through the FIRMS portal at firms.rbi.org.in . The AD bank initiates the filing, but the exporter must provide all underlying documents. Board resolution, valuation report, FIRC (Foreign Inward Remittance Certificate), share certificate copies, and the investment agreement.
How to Access and Download RBI Forms
RBI maintains all its forms in a central directory. Here is how to find and download the forms you need.
Step-by-step: RBI website navigation
- Go to rbi.org.in
- Navigate to Forms > List of Forms (or directly access rbi.org.in/Scripts/BS_ViewForms.aspx)
- Use the department filter to narrow by category: FEMA. For GR, SOFTEX, A1, A2, ECB, FC-GPR, FC-TRS
- Foreign Exchange. For FLM-8, dealer licence forms
- Banking Regulation. For bank-filed returns including Schedules
- Click on the form name to download as PDF. Some forms are available in both English and Hindi
- For the latest version, check the "Last Updated" date. RBI occasionally revises form formats via circulars
Other portals where forms are filed
| Portal | URL | Forms/Returns Filed Here |
|---|---|---|
| EDPMS | edpms.rbi.org.in | GR/SDF electronic equivalents, export realisation tracking |
| FIRMS | firms.rbi.org.in | FC-GPR, FC-TRS, LLP-I, LLP-II, DRR |
| ECB Portal | ecb.rbi.org.in | Form ECB (registration), ECB-2 (monthly return) |
| STPI Portal | stpi.in | SOFTEX forms for IT/software exports |
| ICEGATE | icegate.gov.in | Shipping bills (data feeds into EDPMS automatically) |
Common Filling Mistakes and How to Avoid Them
After working with hundreds of exporters, these are the mistakes we see most frequently. Each one has caused real compliance problems.
- Not closing EDPMS entries within 9 months
- Caution-listing, blocked AD code registration, delayed incentive claims
- Set up a monthly EDPMS reconciliation process. Match every shipping bill to its realisation. Flag entries approaching 6 months as amber, 8 months as red.
- Shipping bill amount does not match realisation
- EDPMS entry stays open even after proceeds arrive; bank cannot close it
- When the buyer deducts commission, quality claims, or discount, issue a proper credit note and provide it to the bank along with the buyer's debit note. The bank needs documentation to adjust the EDPMS amount.
- Not reporting advance remittances
- Advances sit in the bank as unidentified credits; not linked to future shipments; Schedule 5 shows gaps
- Immediately inform your AD bank when you receive an advance payment. Provide the buyer's purchase order or contract reference so the bank can create the correct EDPMS advance entry.
- Using the wrong purpose code for incoming payments
- RBI data shows the payment as something other than export proceeds; EDPMS matching fails
- Instruct your overseas buyer to use the correct purpose code in their payment instructions. Provide your bank with a list of purpose codes you commonly use. See our purpose codes guide for the full list.
- Filing SOFTEX late or not at all for mixed exports
- Service export proceeds are unaccounted in RBI's monitoring; potential FEMA violation
- If your company exports both goods and services, maintain separate billing streams. File SOFTEX for the services component within the prescribed timeline through STPI/SEZ portal.
- Missing FC-GPR filing deadline after receiving foreign investment
- Compounding penalty under FEMA; delays in subsequent fundraising
- Set a calendar reminder for Day 1 after share allotment. The AD bank has 30 days to file FC-GPR. Provide all documents (board resolution, valuation, FIRC) to the bank within the first week.
- Inadequate documentation for write-off requests under Schedule 6
- Bank rejects the write-off application; EDPMS entry stays open indefinitely
- Prepare a comprehensive write-off file: buyer correspondence trail, legal notice copies, ECGC claim status (if insured), board resolution authorising write-off, and a note on steps taken to recover the dues.
Digital vs Physical. Which Forms Are Electronic-Only
RBI has progressively digitised its forms ecosystem. As of 2026, most exporter-relevant forms are filed electronically. Here is the current status.
| Form | Filing Mode | Portal | Notes |
|---|---|---|---|
| GR / SDF | Electronic only | EDPMS (via ICEGATE) | Physical GR eliminated since 2014 |
| SOFTEX | Electronic only | STPI / SEZ portal | Manual submissions no longer accepted |
| Form BCX | Bank-generated | EDPMS | Exporter requests; bank generates from EDPMS data |
| ENC Form | Bank internal | AD bank's CBS | Exporter provides underlying documents |
| Schedules 3-6 | Electronic only | RBI reporting portal | Filed by AD bank; exporter provides data |
| EEFC application | Mostly paper | AD bank branch | Some banks accept digital applications |
| Form ECB | Electronic only | ECB online portal | AD bank files on borrower's behalf |
| ECB-2 | Electronic only | ECB online portal | Monthly return by AD bank |
| FLM-8 | Paper + online | RBI Department of Regulation | Rarely relevant for exporters |
| A2 Form | Paper (transitioning) | AD bank branch | Many banks now accept scanned / digital |
| FC-GPR | Electronic only | FIRMS portal | Filed within 30 days of allotment |
| FC-TRS | Electronic only | FIRMS portal | Filed within 60 days of transfer |
The trend is clear: physical forms are being phased out. Even the remaining paper forms (A2, EEFC applications) are likely to move fully online within the next 1-2 years as RBI completes its PRAVAAH (Platform for Regulatory Application, Validation and Authorisation) initiative.
Quick Reference: All RBI Forms for Exporters
A single table summarising every form covered in this guide, who files it, and when.
| Form | Purpose | Filed By | When |
|---|---|---|---|
| GR / SDF | Export declaration | Exporter (auto via EDPMS) | Every shipment |
| SOFTEX | Software/IT export declaration | Exporter via STPI/SEZ | Every IT service export |
| Form BCX | Bank certificate for export proceeds | AD bank | On request / after realisation |
| ENC | Export bill negotiation/collection | AD bank | When bill is negotiated/sent for collection |
| SCH-3 | Payment schedule for export proceeds | AD bank | Monthly |
| SCH-4 | GR/PP form status report | AD bank | Monthly |
| SCH-5 | Advance remittance for exports | AD bank | When advance is received |
| SCH-6 | Write-off / extension request | AD bank | When proceeds are irrecoverable |
| EEFC | Forex account application | Exporter via AD bank | One-time (account opening) |
| Form ECB | ECB registration | AD bank | On first drawdown |
| ECB-2 | ECB monthly return | AD bank | Monthly |
| FLM-8 | Forex dealer licence | Applicant entity | One-time (licence application) |
| A2 | Capital account remittance | Exporter via AD bank | Per transaction |
| FC-GPR | Foreign investment reporting | AD bank via FIRMS | Within 30 days of allotment |
| FC-TRS | Share transfer reporting | AD bank via FIRMS | Within 60 days of transfer |
Exporter's RBI Forms Compliance Checklist
- EDPMS entries: Reconcile monthly. Flag anything approaching 6 months unrealised. Target 100% closure within 9 months.
- Advance payments: Report to AD bank immediately with order reference. Track adjustment against subsequent shipments.
- Purpose codes: Brief your overseas buyers on the correct RBI purpose codes to use in payment instructions.
- Form BCX: Request quarterly from your AD bank for all closed shipping bills. Build a compliance archive.
- SOFTEX: If you have any service export component, file SOFTEX through STPI/SEZ portal. Do not assume goods-only shipping bill coverage is sufficient.
- EEFC account: Review whether retaining forex proceeds could save conversion costs. Especially relevant if you also import raw materials in the same currency.
- Foreign investment: If you receive FDI, calendar the FC-GPR 30-day deadline on the day of share allotment. Not the day the money arrives. The day you allot shares.
- Write-offs: Start the SCH-6 process early. Gather documentation as soon as you suspect non-recovery, not after 9 months when the caution-list is already triggered.
Related resources
EDPMS Reporting Guide
Complete walkthrough of EDPMS entries, closure, and troubleshooting common errors.
Common FEMA Violations
The top FEMA violations Indian exporters face and how to avoid compounding penalties.
RBI Returns Guide
All the RBI returns your AD bank files and what data you need to provide.
Update history
- First published.