FEMA · RBI Compliance

Set-Off of Export Receivables Against Import Payables: RBI Documentation Checklist

Finin2min Compliance Desk·June 2026·7 min readSET-OFF

Netting or set-off sounds efficient, but export receipts and import payments are regulated flows. The documentation should prove commercial basis, bank approval route and accounting closure.

Set-off file

Document	Control
Export invoices	Receivable being adjusted.
Import invoices	Payable being adjusted.
Counterparty/group relationship	Supports commercial basis for netting.
Bank approval/communication	AD bank route and evidence.
Accounting entries	Receivable/payable closure and GST/tax trail.

Controls

Do not net off without bank/professional review.
Keep invoice-wise matching sheet.
Document exchange rate used.
Reconcile export ageing after set-off.
Check GST and tax impact separately.

Finin2min warning

Netting is not just an accounting shortcut. Export/import set-off needs bank and evidence discipline.

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Official sources used

This article is intentionally source-limited to official RBI / India Code material. Verify final filing positions with the latest FEMA Act, regulations, RBI directions, bank instructions and portal advisories before publishing.

FAQs

Can export receivable be set off against import payable? ▾

It should be reviewed under RBI/FEMA and bank procedures before doing so.

What documents are needed? ▾

Export/import invoices, matching sheet, bank communication and accounting entries.

Does GST matter? ▾

Yes. GST/export/import records should be reconciled.