EDPMS Caution-Listing of Exporters: Revised Procedure
Current · Source: Reserve Bank of India · RBI/2020-2021/50 · issued 09 Oct 2020 · ~2 min read
Quick answerRBI has withdrawn the automatic caution-listing criteria for exporters in EDPMS. Now, AD banks must recommend caution-listing based on exporter track record and adverse reports from law enforcement agencies, making the process more equitable.
The rule, in the simplest words
RBI stopped automatically putting exporters on a caution list; now the bank must suggest it.
The bank looks at the exporter’s past behavior and any bad notices from agencies like the Enforcement Directorate (ED), Central Bureau of Investigation (CBI), or Directorate of Revenue Intelligence (DRI).
If the exporter is missing, not trying to get export money, or has a bad notice, the bank can recommend caution‑listing to RBI.
To remove an exporter from the caution list, the bank also has to recommend de‑caution‑listing to RBI.
How it plays out — a real example
Rohit, an export‑loan officer at an authorised dealer bank in Mumbai, checks his daily reports. He sees that a client, XYZ Exports, has been flagged by the ED for a pending investigation and has not sent the shipping documents to claim export proceeds. Rohit prepares a recommendation to the RBI regional office, explaining XYZ's recent adverse notice and poor track record, and asks for the exporter to be caution‑listed. Later, when XYZ clears the investigation, Rohit again writes to RBI recommending de‑caution‑listing, ensuring the process follows the new rule.
What changed
RBI withdrew the earlier automatic caution-listing triggers under para 3(1)(i) and 3(1)(ii) of the 2016 circular. Now, caution-listing happens only on AD bank recommendations, considering the exporter's track record and adverse notices from agencies like ED, CBI, or DRI. De-caution-listing also requires AD bank recommendations.
What it means for you
Banks now have greater discretion and responsibility in managing exporter caution-listing. This shift reduces automatic penalties and allows banks to assess each exporter's situation, promoting fairness. However, banks must diligently monitor exporter compliance and coordinate with enforcement agencies to ensure timely recommendations.
What you must do
Review and update internal procedures for caution-listing exporters in EDPMS to align with the new recommendation-based process.
Train staff to identify exporters who come to adverse notice of ED, CBI, DRI, or other law enforcement agencies.
Establish a clear process for making recommendations to the RBI Regional Office for both caution-listing and de-caution-listing.
Communicate the revised procedure to all relevant constituents and update internal compliance manuals.
Who it affects
All Category-I Authorised Dealer Banks, Exporters using EDPMS, RBI Foreign Exchange Department Regional Offices
❓ Common questions
What triggered the change in caution-listing procedure?
RBI revisited the earlier automatic criteria to make the system more exporter-friendly and equitable, as per the Statement on Development and Regulatory Policies issued on October 9, 2020.
How should an AD bank recommend caution-listing now?
The AD bank must recommend caution-listing to the RBI Regional Office if the exporter is not traceable, not making sincere efforts to realize export proceeds, or has come to the adverse notice of enforcement agencies like ED, CBI, or DRI.
Are the procedural aspects for handling shipping documents of caution-listed exporters changed?
No, the procedural aspects outlined in Para 3.2 of the earlier circular remain unchanged.
📜 Read the original circular — full text as issued by RBI
RBI/2020-2021/50
A.P. (DIR Series) Circular No.03
October 09, 2020
To
All Category - I Authorised Dealer Banks
Madam / Sir,
Export Data Processing and Monitoring System (EDPMS) Module for ‘Caution/De-caution Listing of Exporters’ - Review
Please refer to Para 4 of Statement on Development and Regulatory Policies issued on October 9, 2020 . In this connection, attention of Authorised Dealer Category – I banks (AD banks) is invited to Para 3.1 of the APDIR Circular No. 74 dated May 26, 2016 on the Module for ‘Caution/ De-caution Listing of Exporters’ in the EDPMS. The extant procedure as laid down in the above para has since been revisited and it has been decided to withdraw the existing para 3 (1) (i) and 3 (1) (ii) with a view to make system more exporter friendly and equitable.
2. Under the revised procedure, an exporter would be caution-listed by the Reserve Bank based on the recommendations of the AD bank concerned, depending upon the exporters track record with the AD bank and investigative agencies. The AD bank would make recommendations in this regard to the Regional Office concerned of the Foreign Exchange Department of the Reserve Bank in case the exporter has come to the adverse notice of the Enforcement Directorate(ED) / Central Bureau of Investigation (CBI) / Directorate of Revenue Intelligence (DRI) /any such other law enforcement agency and/or the exporter is not traceable and/or is not making sincere efforts to realise the export proceeds.
3. Similarly, the AD bank would also make recommendations to the Regional Office of the Reserve Bank for de-caution-listing an exporter as per the laid down procedure.
4. The procedural aspects on handling of shipping documents of the caution-listed exporters by the AD banks, as outlined in Para 3.2 of the circular ibid, remain unchanged.
5. AD banks may bring the contents of this circular to the notice of their constituents concerned. The Master Direction number 16/2015 dated January 1, 2016 is being updated to reflect the above changes.
6. The directions contained in this circular have been issued under Section 10 (4) and Section 11 (1) of the Foreign Exchange Management Act (FEMA), 1999 (42 of 1999) and are without prejudice to permissions / approvals, if any, required under any other law.
Yours faithfully,
(Ajay Kumar Misra)
Chief General Manager-in-Charge
Reproduced for reference with acknowledgment — Source: Reserve Bank of India · RBI/2020-2021/50 · issued 09 Oct 2020. The plain-English explanation above is BankPulse’s own independent summary.
Example: if you are a Compliance officer at a bank this circular applies to (All Category-I Authorised Dealer Banks, Exporters using EDPMS, RBI Foreign Exchange Department Regional Offices), your first concrete step on “EDPMS Caution-Listing of Exporters: Revised Procedure” is: “Review and update internal procedures for caution-listing exporters in EDPMS to align with the new recommendation-based process.” (RBI issued this 09 Oct 2020).
Circular: RBI/2020-2021/50 -- EDPMS Caution-Listing of Exporters: Revised Procedure
Issued: 09 Oct 2020
Action required: Review and update internal procedures for caution-listing exporters in EDPMS to align with the new recommendation-based process.
Action required: Train staff to identify exporters who come to adverse notice of ED, CBI, DRI, or other law enforcement agencies.
Action required: Establish a clear process for making recommendations to the RBI Regional Office for both caution-listing and de-caution-listing.
Action required: Communicate the revised procedure to all relevant constituents and update internal compliance manuals.
Owner: ____________ Target date: ____________
Board/committee approval needed? Y / N
Evidence filed in compliance register on: ____________
Built only from this circular’s own published fields — not legal advice; always confirm against the official RBI source.
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BankPulse Compliance Evidence Pack — generated 03 Aug 2026 · status cross-checked against RBI’s official withdrawal register (refreshed weekly). Official RBI source: https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=11978&Mode=0 — Plain-English summary by BankPulse (bankpulse.ai), reviewed by our expert reviewer, CA Amit Jain. Independent platform, not affiliated with the Reserve Bank of India; is our own plain-English paraphrase, not RBI’s original wording.
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