Menu

Your Indian customer says its bank or the RBI won't let it pay you. Is that true?

By Gaurav Gupta, Founder & CEO, GGA India

Last reviewed: 9 November 2026

Direct answer. Rarely, for an ordinary import. Since 1 October 2026 India's import rules let a buyer pay on the contract terms, without Reserve Bank of India (RBI) approval, and its own bank can extend the period. A bank holds a payment only while a document or check is open. Ask your buyer for the bank's written query.

GGA India at a glance — for companies outside India

The problem: you cannot see inside your buyer's bank, so "the bank is holding it" is hard to test

The claim may be true, half true or a delay tactic, and from abroad all three sound the same.

Every payment out of India for imports goes through an authorised dealer (AD) bank: an Indian commercial bank licensed by the RBI to handle foreign exchange. The RBI writes the rules. The AD bank applies them, transaction by transaction. The RBI does not approve individual import payments for ordinary goods or services.

Three things make the claim hard to check:

Meanwhile your three-year time limit for claims keeps running.

What the rules actually say since 1 October 2026

The current framework pushes the bank to see your invoice paid, not to stop it.

The rules are the Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026, issued under India's Foreign Exchange Management Act (FEMA), with the RBI's circular to banks of 16 January 2026.

Exhibit 1: The import payment rules a foreign seller should know

Rule (2026 Regulations) What it means for your invoice
Payment period follows the contract (Reg. 9) No fixed national deadline for an ordinary import. Your agreed terms set the due date.
The bank may extend the period (Reg. 9) Paying late needs the buyer's reasoned request to its own bank, not RBI approval.
The bank monitors and follows up (Reg. 9) The bank is required to chase its importer to pay within the contract period.
The bank must be satisfied the payment is genuine (Reg. 4) It checks documents before debiting the buyer. This is where real holds arise.
IDPMS entries are closed after payment (Reg. 18) Each import is a record in RBI's Import Data Processing and Monitoring System (IDPMS). The bank marks it off once you are paid.
Small entries close on a declaration (Reg. 4) For a bill of entry or invoice up to ₹10 lakh (about USD 10,500), the buyer's declaration closes the entry.
Advances: bank-set thresholds (Regs. 10 and 12) Above its own limit, the bank can ask for a standby letter of credit or guarantee before an advance leaves India.
Each bank publishes its import policy (Reg. 19) Documents, timelines, charges and extensions are written down, with an appeal route for customers.

IDPMS is a ledger, not a gate. To clear Indian customs, the importer files a bill of entry, the customs declaration for the shipment. Its data reaches the bank through IDPMS, and the bank records each payment against it. An open entry shows you are unpaid; it does not stop payment.

Real holds and convenient excuses

A genuine hold always names a document, a check or a person; an excuse names only "the bank" or "the RBI".

Exhibit 2: What the buyer says, and how to tell which it is

What you hear Real when An excuse when Ask for
"We need RBI approval." A transaction outside the 2026 Regulations, or one begun before 1 October 2026 that already needed RBI approval Your invoice is an ordinary goods or services import on agreed terms The bank's letter naming the rule
"It is past six months; the bank cannot pay." Never on that ground now; past the contract date, the buyer asks its bank for an extension Always, if the six-month rule is quoted A copy of the extension request
"Bank compliance is reviewing it." Sanctions or know-your-customer screening of your name, bank, country or goods; a name mismatch No named document after a week The bank's query, word for word
"The bill of entry is not matched." Goods not yet cleared from customs or a bonded warehouse, or the entry details are wrong Goods cleared weeks ago and the buyer holds the bill of entry Bill of entry number, date and port code
"Tax forms are pending." Services, software or royalties, where tax paperwork must reach the bank first A plain goods invoice, which needs no tax information for the bank The tax form acknowledgement number
"Your bank details do not match." Account name differs from the invoice, a new account, or a third-party account Details unchanged since earlier payments Exactly which field differs
"The bank wants a guarantee from you." An advance payment above the bank's threshold, or the buyer has older advances not yet matched to imports Payment after shipment The bank's written condition

If tax forms are the reason, the issue is withholding, not FEMA: see when your Indian customer deducts tax. If every answer ends with "the bank", the money may not be there; check whether the buyer is still in business.

The solutions: six ways to move a payment the buyer says is stuck at its bank

Every route depends on the same thing: the buyer must answer the bank's query, so the work is getting that answer sent.

Exhibit 3: Options when an Indian buyer blames its bank

Option What it can do What it cannot do Right choice when
Handle it yourselves from abroad Ask for the query, send documents, set a date Reach the treasury team or see the bank's reply The buyer answers you and the gap is a document you hold
Your lawyer at home A formal letter on the contract terms Read Indian banking practice or move an Indian treasury The contract is under your law and you are preparing a claim
An Indian law firm A FEMA opinion, a notice, mediation, a suit Fix a missing document cheaply The buyer refuses after a complete file, or a real FEMA question exists
A home-country agency that subcontracts in India Reminders through a partner Show you who works the file in India Small, simple claims where visibility matters less
Your credit insurer's panel Act within the policy's rules Act without the insurer's consent The receivable is insured; follow the policy first
GGA's India Desk Work with the buyer's treasury and tax team on the bank's query in their city Speak to the buyer's bank, which deals only with its customer The buyer is trading and the hold is a file, not a dispute

If the buyer disputes the goods or the price, the bank is not the issue; the pillar guide to recovering B2B debt from an Indian company covers the legal routes, and cost and time by route shows what each takes. A legal notice sent while a bank query is still open usually moves the file to the buyer's lawyers, not to its treasury.

What you can do this week

  1. Ask in writing for the name and branch of the buyer's AD bank, the exact document or check outstanding, and a copy of the bank's email or letter.
  2. Send a clean payment set: commercial invoice, packing list, bill of lading or airway bill, and a letter from your bank confirming your account name and number. The account name must match the invoice exactly.
  3. Ask for the bill of entry number, date and port code. If the goods are still in a bonded warehouse, ask when they will be cleared.
  4. For services or software, ask whether the buyer's tax form is with the bank, and send your tax residency certificate.
  5. If the contract date has passed, ask the buyer to request an extension from its own bank, and to copy you on the request.
  6. Read the bank's published import policy on its website.
  7. Once told "remitted", ask for the SWIFT reference. Your bank can trace it.

Why GGA: we work on the document the bank is waiting for

The bank answers your buyer; GGA works with your buyer's treasury team until the answer is sent.

GGA is not the answer under USD 20,000, for a FEMA opinion (Indian counsel's work) or for a buyer in insolvency. All topics are on the India Desk page.

What GGA would do

First establish whether a bank query exists; then close it; then track the money to your account.

  1. Days 1–3: File and claim check against the 2026 import rules. You receive: a note saying whether the stated reason can be real for this invoice, and what is missing from your side.
  2. Week 1: Find the open item. We ask the buyer's treasury for the bank's written query, the bill of entry details and the bank name. You receive: the query, or written confirmation that none exists.
  3. Weeks 1–2: Build the response. We assemble the documents the bank asked for with you and the buyer, and flag any tax question for your adviser. You receive: the response set and the date the buyer will lodge it.
  4. Weeks 2–4: Follow it through. We stay with the buyer's treasury until the bank accepts the file, including any extension request. You receive: a weekly status note and the remittance date once fixed.
  5. After payment: Reconcile. You receive: the SWIFT reference, the amount received against the invoice, and any shortfall raised with the buyer.

Terms: cases from USD 20,000; a file-opening fee and success commission agreed in writing before work begins; commission only on amounts actually recovered.

What we need from you

Four items are enough to tell you whether the bank story holds.

To start

To act

Missing some of these? Send what you have — telling you what is missing is part of the first reply.

How you stay in control

The buyer pays your account; any regulatory question goes to your advisers, not to GGA.

Send us one unpaid invoice. Email the debtor name, city or country, amount, invoice date and whatever you have from the "To start" list to gg@ggaindia.co.in. Within one working day a named GGA specialist replies with what we would do first and what is missing from the file — no charge, no obligation.

A different situation? Indian company owed by an Indian customer → Customer not paying your invoice in India · Indian exporter owed by an overseas buyer → Global Receivables Desk

Frequently asked questions

Does an Indian company need RBI permission to pay a foreign supplier?

Not for an ordinary import of goods or services. Its AD bank handles the payment under the 2026 Regulations. RBI approval is needed only for transactions outside the rules, which an ordinary invoice is not.

Is there still a six-month limit for Indian import payments?

No. From 1 October 2026 the payment period follows the contract. If the buyer pays later than agreed, its own bank can extend the period on a reasoned request.

What is IDPMS, and can it block our payment?

The RBI's database linking each bill of entry to its payments. Banks mark an entry off once you are paid. An open entry records non-payment; it does not block one.

What can we ask our Indian buyer to show us?

The bank's written query, the bank name and branch, the bill of entry number and date, any extension request, and the SWIFT reference once paid. A buyer with a genuine hold can share these.

Can GGA contact the buyer's bank for us?

No. An Indian bank discusses payments only with its own customer. GGA works with the buyer's treasury team, which does.

Related questions for foreign creditors: Our Indian customer has no complaint about the goods but still has not paid. Why? · My Indian distributor has stopped paying. What can we do? · Country guides: UK · Europe · USA

Sources

This page summarises the position as at 9 November 2026. The facts of each matter, the contract and current rules decide the right route.