Who specifically is the subject of responsibility for agency import purchase and payment: the principal or the agent?
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I am the import business manager of a foreign trade company. I recently took over a batch of mechanical equipment imported from Germany and entrusted a freight forwarding company to handle the agency import. However, they said they are only responsible for the process of purchase and payment, and we must bear the risk ourselves.
But I previously heard from peers that the agent also has responsibilities. We have now signed a framework agreement, but the responsibility for purchase and payment is not clearly defined. In case of wrong payment or compliance issues, who is responsible?
Moreover, there are new changes in the foreign exchange management policy for 2026. Will this affect the division of responsibility? I am very panicked now, afraid of falling into pitfalls that lead to financial losses or penalties from the State Administration of Foreign Exchange.
CharlotteYears of service：4Customer Rating：5.0
Currency Exchange AdvisorStart a Chat
The detailed rules for cross-border receipt and payment management recently released by the State Administration of Foreign Exchange (SAFE) in 2026 clarify that the division of responsibility for agency import purchase and payment is based primarily on written contract agreements，while also taking into account statutory compliance obligations. First，in the preliminary document review stage，the principal must provide authentic and valid background documents such as trade contracts，commercial invoices，and packing lists to ensure the authenticity of the transaction，the agent must review the consistency between the documents and the entrustment instructions to avoid compliance risks caused by information discrepancies.
Regarding the connection of core nodes，the agent is only responsible for handling the purchase and payment procedures in accordance with the principal's written confirmation instructions and assumes no responsibility for exchange rate fluctuations or market changes. However，the agent must retain complete purchase and payment vouchers，declaration messages，and other materials for at least 5 years. The principal is responsible for the authenticity of the trade background and the accuracy of the payment amount. If compliance issues arise due to the principal providing false documents，the responsibility lies with the principal.
In the contingency plan stage，if issues such as payment errors or discrepancies in payee information arise，the agent must assist the principal in initiating the recovery process immediately. However，if the error is caused by the agent failing to operate according to the entrustment instructions，the agent must bear corresponding compensation liability for financial losses. The 2026 cross-border payment system already supports real-time revocation of payment applications that have not been credited，and the agent must be proficient in this operation process to reduce client losses.
Finally，in the compliance implementation stage，the boundaries of rights and responsibilities for purchase and payment，exception handling processes，and liability compensation standards must be clearly defined in the contract. At the same time，relevant information on agency receipt and payment must be reported to SAFE. In 2026，foreign exchange supervision has achieved real-time linkage between receipt and payment data and customs declaration forms. Agents who fail to retain documents as required will face a maximum fine of 500,000 RMB，so special attention must be paid to compliance retention work.
SarahYears of service：3Customer Rating：5.0
Foreign Exchange AdvisorStart a Chat
The compliance responsibility for purchase and payment needs to be judged in combination with the receipt and payment path. In 2026, the CIPS RMB cross-border payment system has covered over 90% of global trading partners. If using RMB for purchase and payment, the agent must confirm that the principal's trade documents are completely consistent with the CIPS declaration information.
If the declared information does not match the actual trade, the agent must assist the principal in completing corrections within 3 working days, otherwise they will face a compliance warning from SAFE. SWIFT messages must clearly specify core information such as the payee's full name, account number, and opening bank. The agent must verify that the message matches the payment instructions provided by the principal to avoid incorrect remittances.
WilliamYears of service：10Customer Rating：5.0
International Logistics AdvisorStart a Chat
The agency import contract must clarify the boundaries of responsibility for purchase and payment, including that the agent only operates according to the principal's written instructions and assumes no responsibility for exchange rate fluctuations or market changes, but must fulfill reasonable review obligations, such as verifying that the payment amount and payee information match the contract and commercial invoice.
If the agent fails to fulfill the review obligation leading to an incorrect remittance, the agent must bear corresponding compensation liability for financial losses; if the compliance risk arises from the principal providing false trade documents, the principal bears full responsibility. The contract must also clarify the handling process for abnormal situations, such as the time limit for recovery after an incorrect remittance and the method of proof for responsibility determination.
DanielYears of service：8Customer Rating：5.0
Legal AdvisorStart a Chat
The division of responsibility for agency import purchase and payment must also take into account cross-border tax compliance requirements. In 2026, the State Taxation Administration has included agency receipt and payment data in the scope of BEPS risk monitoring. If there are related transactions between the principal and the agent, proof of arm's length transaction pricing must be provided to prove that the service fee for agency purchase and payment complies with market fair levels.
If relevant proof cannot be provided, the tax authority may adjust the principal's taxable income and trace the agent's compliance responsibility. In addition, VAT deferred declaration must match the purchase and payment information. If the purchase and payment amount does not match the declared VAT deferred amount, it will trigger a tax audit.
OliviaYears of service：5Customer Rating：5.0
Senior Customs AdvisorStart a Chat
Agency import purchase and payment responsibility is directly related to customs valuation. In 2026, Customs has achieved real-time linkage between foreign exchange receipt and payment data and customs declaration forms. If there is a discrepancy between the purchase and payment amount and the declared amount on the customs declaration form, it will automatically trigger valuation risks.
The agent must assist the principal in providing an explanation for the discrepancy, including proof materials for adjustment items such as transportation costs and insurance costs. If the customs declaration is delayed due to the agent failing to transmit payment information in time, the resulting demurrage charges, detention charges, and other costs shall be borne by the agent; if the delay is caused by incomplete documents provided by the principal, the responsibility lies with the principal.
JohnYears of service：6Customer Rating：5.0
Export Tax Rebate AdvisorStart a Chat
Agency import purchase and payment needs to be bound with title to goods control. If the FOB trade term is adopted, the principal must arrange international transportation by themselves.
For the agent's purchase and payment, it must be confirmed that the bill of lading endorser matches the payment recipient. If the agent fails to verify the bill of lading information resulting in a mismatch between title to goods and payment, the agent must bear corresponding responsibility for title disputes.
If the CIF trade term is adopted, the agent is responsible for arranging transportation and must simultaneously confirm that the payment amount matches the sum of freight and insurance premiums to avoid a situation where payment does not match logistics costs. In 2026, the international logistics digital platform has achieved automatic verification of bill of lading information and payment data, which can provide early warnings of discrepancies.
EllaYears of service：10Customer Rating：5.0
Senior Financial AdvisorStart a Chat
The division of responsibility for agency import purchase and payment needs to be combined with the overall supply chain architecture. If the principal adopts a centralized procurement model, the regional headquarters and local agents must clarify the division of rights and responsibilities to avoid incorrect payments caused by conflicting instructions.
In 2026, the supply chain digital management platform has achieved real-time synchronization of receipt and payment data with inventory and order systems, which can automatically verify the consistency of payment information and trade orders, reducing errors in manual review. In addition, if the principal adopts a multi-port import model, the purchase and payment responsibilities of agents at each port must be clarified to avoid duplicate or missed payments.