20 July 2025
The RBI requirements for setting off of debtors with creditors, especially in the context of foreign exchange transactions, are governed under the Foreign Exchange Management Act (FEMA), 1999, and related RBI guidelines. Here's a concise breakdown:
๐ Set-off of Debtors and Creditors (Cross-border Transactions) If you're talking about setting off receivables (export proceeds) against payables (import dues) with the same party or group company, here's what applies:
โ Permissibility
Set-off of export receivables against import payables is permitted by RBI, but subject to conditions.
๐ Relevant Circular RBI Master Direction: Export of Goods and Services
Refer to Master Direction No. 16/2015-16 (as updated) โ Key RBI Conditions for Set-Off: Same Entity or Group Company: The set-off must be with the same party (or its group/associate company) under a valid agreement. Authorised Dealer (AD) Bank Approval: You must approach your Authorised Dealer (your bank) with all documents. AD Bank can approve the set-off under delegated powers. Documentation Required: Invoices of exports and imports Customs documents (Shipping Bill/Bill of Entry) Foreign Inward Remittance Certificate (FIRC) if available Set-off agreement with the counterparty Timelines: Export proceeds should be realized within the time limit prescribed (generally 9 months). Imports must be settled within 6 months. Netting-off Allowed When: Thereโs a bonafide business transaction Proper book entries are maintained No money laundering or FEMA violations are suspected Reporting: Set-off transactions should be reported to the RBI through the AD bank. Use appropriate forms such as Form EDF or Softex, depending on the nature of export. ๐ Not Permitted For: Unrelated parties without valid contracts Transactions involving capital account nature unless specifically permitted Where RBI approval is explicitly required ๐งพ Example: Company A in India exports goods worth $50,000 to Company B in the US and also imports $45,000 of machinery from the same company. Instead of making and receiving separate payments, they request the bank to allow a net settlement of $5,000 receivable.
With proper documentation and declaration, the AD bank can approve this set-off.