What Is the RBI Exporter Caution List and How Does an Exporter Get De-Listed?

The RBI exporter caution list is a list of exporters whom RBI has restricted because of serious concerns about unrealised export proceeds or adverse notice from enforcement agencies. A caution-listed exporter can export only against advance payment or an irrevocable letter of credit covering the full export value.

• Legal basis: RBI could direct a class of exporters to export only against an irrevocable letter of credit or similar arrangement under Regulation 16(1) of the 2015 Export Regulations.
• Who decided: RBI caution-listed an exporter based on the recommendation of the AD bank concerned, looking at the exporter's track record with the bank and investigative agencies (Master Direction, para C.28(1)).
• Where held: Under the 2016 to 2026 framework, caution and de-caution listing was handled through a module in the Export Data Processing and Monitoring System (EDPMS), where AD banks could see the updated list daily (A.P. (DIR Series) Circular No. 74, para 3.1).
• Right to respond: RBI could not give such a direction unless the exporter had been given a reasonable opportunity to make a representation (Regulation 16(2) of the 2015 Regulations).
• 2026 change: From 1 October 2026, Regulation 13 of the 2026 Regulations sets the restriction directly in law for any exporter whose proceeds stay unrealised beyond one year after the due date, without a separate listing step.
• Existing listings: Exporters on the caution list as on 30 September 2026 stay governed by RBI's order until they are removed from the list (proviso to Regulation 13).

The caution list therefore still matters for exporters listed before 1 October 2026, while every other exporter now faces the Regulation 13 restriction if export dues remain unpaid for more than a year past the due date.

The RBI exporter caution list applies to exporters named in an RBI order, mainly those whose AD bank reported serious realisation problems or adverse agency notice. From 1 October 2026, the Regulation 13 restriction applies to every exporter of goods or services whose proceeds remain unrealised beyond one year after the due date.

Up to 30 September 2026, an exporter got on the RBI caution list when RBI accepted an AD bank's recommendation to list it. From 1 October 2026, no listing is needed: the restriction in Regulation 13 applies once proceeds stay unrealised beyond one year after the due date.

1. The export is made and the realisation clock starts: nine months from invoice for services or from shipment for goods, or twelve months if invoiced or settled in rupees (Regulation 5(1)). See export realisation period.
2. The AD bank monitors open entries in EDPMS and follows up with the exporter to realise proceeds (Regulation 5(2) and Regulation 18(1)(f)). See what is EDPMS.
3. If the exporter cannot collect on time, it can ask the AD bank for an extension, a reduction in export value, or a set-off (Regulations 5, 6 and 7).
4. Under the old framework, if the exporter was under adverse agency notice, untraceable or not making sincere efforts to realise, the AD bank could recommend caution listing to RBI's Foreign Exchange Department regional office (A.P. (DIR Series) Circular No. 03 of 2020, para 2).
5. From 1 October 2026, if proceeds remain unrealised beyond one year after the due date or extended date, the exporter must undertake further exports only against full advance or an irrevocable letter of credit (Regulation 13).

The Regulation 13 restriction starts after the realisation period ends and a further year passes without the proceeds being realised. The realisation period is nine months for most goods and services, twelve months for rupee-invoiced exports, and contract terms for project exports, each extendable by the AD bank.

An exporter on the RBI caution list, or caught by Regulation 13, can export only against full advance payment or an irrevocable letter of credit. This removes open-account and usual credit terms, which can make it hard to keep regular overseas clients.

• Payment terms: Further exports only against receipt of full advance or an irrevocable letter of credit (Regulation 13).
• Document handling: For listed exporters, AD banks were not to handle shipping documents outside those conditions (Master Direction, para C.28(2)(a)).
• Guarantees: Under the old rules, AD banks needed RBI's prior approval to issue guarantees for caution-listed exporters (para C.28(2)(b)).
• FEMA penalty: Under section 13(1) of FEMA, a contravention can lead, on adjudication, to a penalty up to three times the sum involved, or up to ₹2 lakh where the amount is not quantifiable, plus up to ₹5,000 a day if continuing (RBI Master Direction on Compounding, para 1.3).
• Bank charges: An AD bank may not levy charges or penalties on an exporter for the exporter's regulatory delay or violation (Regulation 19(3)).

Contact your AD bank as soon as a payment looks late. Ask for an extension before the due date, apply for a reduction where the buyer will not pay in full, and keep proof of your recovery efforts. If the bank refuses, its SOP must offer an escalation and appeal route (Regulation 19(2)).

The exporter caution list rested on Regulation 16 of the 2015 Export Regulations and para C.28 of the Master Direction on Export of Goods and Services. From 1 October 2026, Regulation 13 of the 2026 Regulations replaces that approach and keeps existing listings in force until removal.

• Ignoring bank notices: Not replying to AD bank follow-ups on open EDPMS entries. Banks must monitor and follow up on these (Regulation 18(1)(f)).
• Late extension requests: Waiting until long after the due date before asking for more time. The AD bank can extend the realisation period when satisfied with the reasons (Regulation 5(1)).
• Unclosed small entries: Leaving invoices up to ₹10 lakh open when a declaration could close them, individually or quarterly in bulk (Regulation 4(2)).
• Unrecorded shortfalls: Accepting a discount or part payment from a buyer without applying for a reduction in export value (Regulation 6). See short realisation of export proceeds.
• Changing banks quietly: Routing an export advance and the later realisation through different AD banks without telling both banks (Regulation 10(1)).
• Missing EDF: Not filing the EDF for services within 30 days from the end of the invoice month, so the bank cannot match receipts (Regulation 3(2)). See what is an EDF form.

Every rule, deadline and form on this page is linked to its official source, checked on the dates below.

1. Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026 (Notification No. FEMA 23(R)/2026-RB, amended up to 22 September 2026), Regulations 2, 3(2), 4(2), 5, 6, 7, 10(1), 13 and proviso, 18(1), 19 (checked 8 Oct 2026)
2. RBI A.P. (DIR Series) Circular No. 20 dated 16 January 2026: Export and Import of Goods and Services, Paras 3 and 4; Annex A items listing Circular No. 74 (2016) and Circular No. 03 (2020) as superseded (checked 8 Oct 2026)
3. Foreign Exchange Management (Export of Goods and Services) Regulations, 2015 (Notification No. FEMA 23(R)/2015-RB), Regulation 16(1) and 16(2) (checked 8 Oct 2026)
4. RBI Master Direction: Export of Goods and Services (superseded from 1 October 2026), Para C.28 Exporters' Caution List; para C.22 Export claims; para C.17 Reduction in invoice value (checked 8 Oct 2026)
5. RBI A.P. (DIR Series) Circular No. 74 dated 26 May 2016: EDPMS additional modules for caution listing of exporters, Paras 3.1 and 3.2 (checked 8 Oct 2026)
6. RBI A.P. (DIR Series) Circular No. 03 dated 9 October 2020: EDPMS Module for Caution/De-caution Listing of Exporters, Review, Paras 1 to 4 (checked 8 Oct 2026)
7. RBI Master Direction: Compounding of Contraventions under FEMA, 1999 (22 April 2025), Para 1.3, restating FEMA section 13(1) penalties (checked 8 Oct 2026)