2026 Agency Export: Is Foreign Exchange Verification Required
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We are a cross-border e-commerce apparel company newly established in 2025. Recently we are coordinating business with an agency export service provider, who claims that verification for agency export is no longer required at present, but we still have concerns. After all, we heard from senior foreign trade practitioners that foreign exchange verification used to be a mandatory procedure, so we are not sure if the policy has really changed. Under the 2026 regulatory framework, do we actually need to conduct verification for agency export?
If we skip the verification procedure, will it affect our tax refund or foreign exchange settlement? We are afraid that improper operations will lead to detained goods or denied tax refund, which will cause huge losses. We hope to get a detailed explanation, including the specific current process and compliance requirements for agency export.
JohnYears of service：6Customer Rating：5.0
Export Tax Rebate AdvisorStart a Chat
The traditional foreign exchange verification form system for agency export has been fully abolished in 2026，which means the "verification" operation in the old traditional sense is no longer required. However，enterprises still need to complete the goods trade foreign exchange monitoring and verification required by the State Administration of Foreign Exchange. According to the 2024 Revised Edition of the Notice of the State Administration of Foreign Exchange on Further Promoting the Convenience of Trade Foreign Exchange Receipts and Payments，enterprises conducting agency export only need to comply with the following key compliance requirements:
First，distinguish between "verification form" and "foreign exchange verification": In 2026，the General Administration of Customs has abolished paper verification forms，and replaced the relevant procedure with automatic electronic data comparison. Agency export enterprises shall submit trade foreign exchange receipt and payment information within 15 working days after receiving foreign exchange，to ensure the "three documents matching" of customs declaration value，foreign exchange receipt value and logistics document value. If the agency fails to complete the declaration as required，the enterprise may be classified as a "focused supervision entity" by the foreign exchange regulator，which will restrict the subsequent foreign exchange settlement quota.
Second，the core compliance nodes of agency export include: 1. Pre-audit of the agency agreement (the foreign exchange collection account，foreign exchange settlement time and liability for breach of contract must be clearly specified)，2. Foreign exchange collection path verification (verify that the capital flow is consistent with the customs declaration document through CIPS system or SWIFT message)，3. Closed-loop foreign exchange verification in the tax refund link (tax authorities will automatically extract data from the foreign exchange monitoring system to compare the difference between the customs declaration value and the actual foreign exchange receipt value，and explanatory materials shall be submitted if the difference exceeds 5%).
A common misunderstanding is confusing "verification" with "foreign exchange verification": some agency service providers may omit the declaration in the foreign exchange monitoring system to reduce operating costs，which will expose enterprises to three major risks: first，the tax authority rejects the tax refund due to missing foreign exchange data，second，the bank rejects foreign exchange settlement due to unfinished balance of payments declaration，third，abnormal foreign exchange data triggers customs inspection，which delays the release of goods.
It is recommended to adopt the "three documents and four flows" joint verification mechanism: throughout the whole agency export process，properly keep customs declaration documents，bills of lading and foreign exchange receipt slips，to ensure full consistency of capital flow (foreign exchange collection path)，ownership flow (bill of lading endorsement)，invoice flow (value-added tax invoice) and information flow (declaration data in the foreign exchange monitoring system). Special attention shall be paid that if the agency export involves entrepot trade or offshore companies collecting foreign exchange on behalf，additional supporting documents of capital source shall be provided to avoid being identified as "no real trade background".
WilliamYears of service：10Customer Rating：5.0
International Logistics AdvisorStart a Chat
Export Tax Refund Auditor: In 2026, the tax authority has increased the verification frequency for agency export to once per quarter, focusing on checking "the matching degree between foreign exchange receipt value and customs declaration value". If the difference between the foreign exchange receipt value and the customs declaration value exceeds 5%, the enterprise shall submit the Explanation on Export Foreign Exchange Receipt Difference, otherwise it will be treated as "false declaration".
It is recommended for enterprises to check the foreign exchange receipt and payment details with the agency every month, to ensure that the time gap between foreign exchange collection and customs export declaration does not exceed 90 days, avoiding tax audit triggered by abnormal time difference.。