IDPMS: why an import entry is still showing as open

The Import Data Processing and Monitoring System is the Reserve Bank's record of what money left India for goods and what came in against it. It pairs an outward remittance with a bill of entry. The Reserve Bank's FED Master Direction No. 17/2016-17 on Import of Goods and Services provides at paragraph C.7.1 that authorised dealer banks are required to create an Outward Remittance Message for all such outward remittances irrespective of value, and to carry out the subsequent activity of document submission, matching with the ORM and closing of transactions as per IDPMS guidelines. An open entry means one half of that pair is sitting alone.

What is the system actually holding?

Two messages. The remittance side is the ORM, created by your authorised dealer bank when it pays your supplier. The import side is the bill of entry, which paragraph C.7.2 of the Master Direction records is downloaded from the BoE Master in IDPMS in the case of EDI ports, with duplicate or customs certified copies required at non-EDI ports, or a bill of entry waiver obtained from the Reserve Bank.

The pairing is deliberately flexible. Paragraph C.8 provides that multiple ORMs can be settled against a single bill of entry and multiple bills of entry can be settled against one ORM, which is what makes part payments and consolidated shipments workable. That flexibility is also why an entry can sit unsettled without anything looking wrong: nothing forces a one to one relationship, so nothing complains until someone reconciles.

Why does the bank ask for a bill of entry you already filed?

Because filing it with customs and evidencing it to the bank are two different acts. Paragraph C.7.1 of the Master Direction provides that in the case of all imports, irrespective of the value of foreign exchange remitted or paid, it is obligatory on the part of the authorised dealer bank through which the remittance was made to ensure that the importer submits the bill of entry number, port code and date for marking evidence of import under IDPMS.

The same paragraph names the alternatives for goods that did not arrive through an EDI port: a Customs Assessment Certificate or Postal Appraisal Form where the import was by post, a Courier Bill of Entry where goods came by courier, and for goods stored in a Free Trade Warehousing Zone, an SEZ unit warehouse or a customs bonded warehouse, the applicable bill of entry number, port code and date for the ex-bond bill of entry. If your import took one of those routes and nobody told the bank which, the entry has no import side to match. The bill of entry and its filing deadline covers the document itself.

Which clock is actually running?

Not the one most importers assume. Paragraph B.5.1(i) of the Master Direction records that in terms of the extant regulations, remittances against imports should be completed not later than six months from the date of shipment, except in cases where amounts are withheld towards guarantee of performance. The same paragraph records the pandemic relaxation that extended that period to twelve months for imports made on or before 31-07-2020, which is a useful reminder that the rule to apply is the one in force on your shipment's own dates.

Extensions are a bank decision within limits. Paragraph B.5.4(i) allows an authorised dealer bank to grant extension of time for settlement of import dues up to a period of six months at a time, to a maximum of three years, irrespective of invoice value, for disputes about quantity or quality, non-fulfilment of contract terms, financial difficulties and cases where the importer has sued the seller. Paragraph B.5.4(ii) adds two conditions that decide most applications: the transaction must not be under investigation by the Directorate of Enforcement, the Central Bureau of Investigation or another investigating agency, and for an extension beyond one year from the date of remittance the importer's total outstanding must not exceed USD one million or 10 percent of average import remittances during the preceding two financial years, whichever is lower. Paragraph B.5.4(iv) provides that the extension is reported in IDPMS through the Bill of Entry Extension message with the date entered in the extension date column.

The five reasons an import entry is still open

In descending order of how often each one turns out to be the answer on a real list.

1. The bill of entry was never evidenced to the bank. The goods cleared, the broker filed, and nobody sent the number, port code and date to the bank that paid.
2. The remittance was an advance and the goods arrived later. The ORM exists from the day the money moved, and the import side follows weeks or months afterwards.
3. The amounts differ. The value on the bill of entry and the amount remitted are not the same, usually because of freight, insurance or a price adjustment nobody recorded.
4. The goods went to a warehouse or a zone. The pairing needs the ex-bond bill of entry that paragraph C.7.1 names, and the into-bond entry alone will not settle it.
5. The import did not happen. An advance paid against a supply that failed. The smallest category, and the only one that is a commercial problem rather than a documentation one.

What closes a difference, and what does the bank owe you?

Small operational differences have an explicit route. Paragraph C.8 of the Master Direction permits closure of the bill of entry or ORM in IDPMS involving a write off to the extent of 5 percent of invoice value in cases where the amount declared in the bill of entry varies from the actual remittance due to operational reasons, subject to the authorised dealer bank being satisfied with the justification. A missing bill of entry has a narrower substitute: paragraph C.7.2(i) allows the bank to accept a certificate from the chief executive officer or auditor of the company that the goods have actually been imported, provided the foreign exchange remitted is less than USD 1,000,000 or its equivalent and the importer is a company listed on a stock exchange in India with a net worth of not less than Rs 100 crore as at its last audited balance sheet, or is a public sector company or a Government of India undertaking or department. Most importers do not qualify.

The follow-up obligation runs the other way and it is timed. Paragraph C.10(i) provides that where an importer does not furnish documentary evidence of import within 3 months from the date of remittance involving foreign exchange, irrespective of value, the authorised dealer bank should rigorously follow up for the next 3 months using various modes of communication, with at least one communication by registered letter. Paragraph C.10(ii) records that all outstanding import remittances, irrespective of amount, are reported in IDPMS, and that the separate BEF statement was required only until the half year ended December 2017. Against that, paragraph C.8 requires the bank to issue an acknowledgement slip to the importer on settlement. Ask for it: an acknowledgement is the cheapest possible proof that an entry is closed.

The small value route most importers have never used

Paragraph C.17 of the Master Direction sets out a special procedure that removes a large share of a typical open list in one pass. Notwithstanding anything else in the Master Direction, authorised dealer banks shall adopt the following while closing entries, including outstanding entries, in IDPMS of value equivalent to Rs 10 lakh per entry or bill or less: such entries shall be reconciled and closed based on a declaration provided by the concerned importer that the amount has been paid, and any reduction in declared value or invoice value of the bills of entry shall also be accepted based on the importer's declaration.

Two further limbs make it practical. The same paragraph provides that those declarations may be received on a quarterly basis in a consolidated manner, combining several bills in one declaration, for bulk reconciliation and closing. It also directs banks to review the charges levied for handling small value import transactions in the light of the relaxation, and provides that they shall not levy any penal charges for delays in adherence to any regulatory guidelines. An importer carrying a long tail of small entries has a route here that does not involve reconstructing a three year old payment.

How to work an open import list down

The order matters more than the effort, because the categories cost very different amounts to resolve.

1. Get the list in a form you can sort. Ask your authorised dealer bank for outstanding entries with the remittance date, amount, supplier and the bill of entry it expects, rather than a single total.
2. Split by value first. Separate entries at or below Rs 10 lakh, because paragraph C.17 lets those be closed on your declaration, and lets the declarations be given quarterly in consolidated form.
3. Send the bill of entry particulars you already hold. For the remainder, supply the bill of entry number, port code and date that paragraph C.7.1 requires, including the ex-bond entry where the goods went into a warehouse or a zone.
4. Name every difference. Where the remitted amount and the bill of entry value do not agree, identify the reason and take it to the route the Master Direction recognises, such as the 5 percent operational write off under paragraph C.8.
5. Escalate only what is genuinely unsettled. Advances against supplies that failed are the residue, and they are the only part that should reach an extension request under paragraph B.5.4 or any other approval route.

Where to go from here

An open import entry sits between the customs file and the banking file, so the guides below each pick up one edge of it.

• The document the pairing needs. The bill of entry, field by field covers what is filed and when.
• When that document changes after filing. Half of India's bills of entry get amended, and an amendment is a common reason two values stop agreeing.
• The export mirror of this problem. Why your shipping bill is still showing as open runs the same diagnosis on the money coming in.
• What the remitted amount should have been. Import duty, in the order it is actually calculated.
• The certificate on the other leg. eBRC is a sibling service that works on electronic bank realisation certificates against the remittances banks report.

Purser keeps the purchase order, the bill of entry and the remittance on one record, so the particulars the bank asks for are already assembled when it asks. Purser never submits to a government portal and it never sends an outbound message without a recorded human approval event, so the declaration to your bank is yours to approve and yours to send. Purser Inbound holds that record.

Frequently asked questions

Why is my import entry still open in IDPMS when the goods were cleared?

Because clearing the goods and evidencing them to your bank are separate acts. Paragraph C.7.1 of the Reserve Bank's FED Master Direction No. 17/2016-17 on Import of Goods and Services obliges the authorised dealer bank to ensure the importer submits the bill of entry number, port code and date for marking evidence of import under IDPMS. Until those particulars reach the bank that made the remittance, the outward remittance message has nothing to pair with.

What is the time limit for settling an import payment?

Paragraph B.5.1(i) of the Reserve Bank's FED Master Direction No. 17/2016-17 records that in terms of the extant regulations, remittances against imports should be completed not later than six months from the date of shipment, except where amounts are withheld towards guarantee of performance. The same paragraph records that the period was extended to twelve months for imports made on or before 31-07-2020 because of the pandemic.

Can small import entries be closed on a declaration?

Yes. Paragraph C.17 of the Reserve Bank's FED Master Direction No. 17/2016-17 provides that for entries in IDPMS, including outstanding entries, of value equivalent to Rs 10 lakh per entry or bill or less, authorised dealer banks shall reconcile and close them based on a declaration by the importer that the amount has been paid, shall accept a reduction in declared or invoice value on the same basis, and may receive those declarations quarterly in consolidated form.

What if the remitted amount and the bill of entry value do not match?

Paragraph C.8 of the Reserve Bank's FED Master Direction No. 17/2016-17 permits closure of the bill of entry or outward remittance message in IDPMS involving a write off to the extent of 5 percent of invoice value where the amount declared in the bill of entry varies from the actual remittance for operational reasons, subject to the authorised dealer bank being satisfied with the justification. Larger differences have to be explained rather than written off.

Can an importer get more time to settle an import payment?

Paragraph B.5.4(i) of the Reserve Bank's FED Master Direction No. 17/2016-17 allows an authorised dealer bank to grant extension for settlement of import dues up to six months at a time, to a maximum of three years, irrespective of invoice value, for disputes over quantity or quality, non-fulfilment of contract terms, financial difficulty or where the importer has sued the seller. Beyond one year from the date of remittance, paragraph B.5.4(ii) caps total outstanding at USD one million or 10 percent of average import remittances over the preceding two financial years, whichever is lower.