The Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026, coming into force on October 1, consolidate the trade monitoring framework and delegate greater authority to authorised dealer banks. According to reports from Business Standard, since October 2025, RBI has allowed EDPMS and IDPMS entries of up to ₹10,00,000 to be closed on declarations by exporters or importers, individually or through quarterly bulk declarations. These reforms are welcome developments, but transaction matching continues under the new framework, with exports of services also entering EDPMS.
Sections 7 and 8 of the Foreign Exchange Management Act, 1999 require export declarations and reasonable steps to realise and repatriate foreign exchange within the period and manner specified by RBI. As reported by Business Standard, these sections do not mandate perpetual invoice-level matching through EDPMS, but RBI's current practice continues this universal transaction matching approach. The philosophy of monitoring every trade entry goes back to the pre-liberalisation exchange-control regime, when each resident individual could remit only $250,000 annually under the liberalised remittance scheme. Today, each resident individual may remit up to $250,000 annually under the liberalised remittance scheme for permitted transactions, with subject to applicable conditions including restrictions on pooling for certain capital-account transactions, a family's aggregate permitted remittances can be substantial.
Official enforcement outcomes reveal a significant gap between estimates and actual recoveries. According to Business Standard reports, until March 2025, Black Money Act assessments raised demands of ₹35,105 crore, while actual recovery was only ₹338 crore, besides ₹2,476 crore collected via the 2015 compliance window. These figures demonstrate the substantial gap between estimates of undisclosed foreign assets and amounts actually recovered, challenging the assumption that every unmatched trade entry represents an attempt to accumulate personal wealth abroad. Trade transactions can be misused through mispricing, fictitious advances, sham service payments and related-party arrangements, but policing every transaction is as impractical as assigning a policeman to follow every individual to prevent crime.
The analysis suggests replacing universal transaction matching with proportionate, risk-based monitoring that identifies cases through analytics and examines them selectively. As reported by Business Standard, banks would retain underlying records and produce them only when selected for examination, preserving an audit trail without treating every delay or mismatch as presumptively suspect from the outset. Repeated or prolonged non-realisation, abnormal prices, high-risk jurisdictions, third-party payments and unexplained advances can be identified through analytics and examined selectively. In genuine transactions, commercial discipline ordinarily impels exporters to pursue receivables and importers to pursue goods paid for.
The period before October 1 offers RBI an opportunity to reconsider whether matching every import-export transaction should give way to aggregate reporting, with transaction-level follow-up reserved for identified risks. According to Business Standard reports, the more fundamental question is whether universal transaction-level control remains necessary at all, as the new framework may merely make an old control system easier to administer without fundamental reforms to the monitoring approach. EDPMS also supports enforcement of conditions attached to drawback, duty credits, GST refunds and duty-exemption schemes, whether non-realisation should trigger recovery of tax remission on goods physically exported raises a separate issue.
