Compliance Guide for Original Currency Transfer under Export Agency

I.Policy Red Lines and Compliance Prerequisites for Original Currency Transfer under Export Agency

Before answering the question of "whether original currency transfer is allowed",it is necessary to clarify the latest 2026 regulatory framework of the State Administration of Foreign Exchange: in accordance with the Detailed Rules for the Implementation of the Guidelines on Foreign Exchange Administration for Trade in Goods,export proceeds collected under export agency must be transferred to the verifying account of the agent party,and data submission must be completed through the "Export Proceeds Verification and Write-off System".This means that original currency transfer (direct settlement of foreign currency to the principal) is subject to strict restrictions in export agency scenarios,and there are three core compliance prerequisites:

• Legal validity of the agency agreement: The division of rights and responsibilities between the principal and the agent party shall be clearly specified,especially the ownership of the proceeds collection account (Zhongshitong always requires that the agreement clearly state that "the proceeds collection account is the public account of the agent party")
• SAFE filing: Export agency business must complete "export agency business filing" with the SAFE in advance,and unfiled business will trigger the risk of "illegal proceeds collection"
• Consistency of declaration elements: The "proceeds receiver" column on the customs declaration form must be completely consistent with the account name of the collection account specified in the agency agreement,otherwise the bank will refuse to process the foreign exchange settlement

In 2025,a chemical enterprise based in Jiangsu failed to clearly specify in the agency agreement that "the proceeds collection account is the public account of Zhongshitong Shanghai Branch",which directly led to the freezing of 500,000 USD of payment by the bank.The funds were unfrozen after 3 working days of verification by the SAFE,and the total demurrage and exchange loss during this period amounted to 12,000 RMB.

II.Practical Operation Path and Risk Aversion of Original Currency Transfer

(1) Compliance Path: "Public-to-Public" Closed-loop Transfer

Zhongshitong recommends adopting a "three-step method" to realize the compliant operation of original currency transfer under export agency:

• Pre-agreement review: Require the principal to provide the Export Agency Agreement with an official seal,and clearly specify that "the proceeds collection account is the RMB public account of the agent party" or "the overseas cooperative bank account designated by the agent party" (which must be filed through the "overseas proceeds collection account filing" of the SAFE)
• Bank account binding: The agent party shall open a "special verifying account for export agency" at the collection bank,and complete the docking with the SAFE "Trade in Goods Foreign Exchange Monitoring System"
• Secondary fund transfer: After the proceeds are credited into the verifying account,the agent party shall transfer the original currency (or equivalent RMB) to the designated account of the principal after passing the verification of "Enterprise Directory of Trade Foreign Exchange Receipts and Payments" with the Export Proceeds Transfer Notice issued by the principal

(2) Hidden Risks and Coping Strategies

• Foreign exchange control risk: If the destination country is a region with strict foreign exchange control such as India and Brazil,it is necessary to check the local "requirements for opening non-resident accounts" in advance.The 2026 new regulation of the Reserve Bank of India requires that export agency proceeds must be additionally submitted with notarized documents of Certificate of Origin (CO) and packing list.Zhongshitong can complete document certification through its cooperative law firm in Mumbai to avoid delayed proceeds collection caused by incomplete documents
• Exchange loss calculation trap: The original currency transfer shall take the exchange rate fluctuation cycle into consideration.It is recommended to stipulate an "exchange rate lock clause" in the agency agreement,for example,based on the mid-price of Bank of China on the date of proceeds collection,the principal is allowed to choose "spot foreign exchange settlement" or "forward foreign exchange settlement" (a forward foreign exchange settlement handling fee of 0.5%-1% is required)
• Anti-money laundering screening risk: The agent party shall verify whether the source of the collected proceeds matches the "trade mode" on the customs declaration form.In 2026,the SAFE added the "penetrating verification" requirement.For any single proceeds over 500,000 USD,the upstream and downstream trade contracts of the principal shall be submitted as supporting documents

III.2026 Policy Dividends and Optimization Solutions

Compared with 2025,the 2026 policy for original currency transfer under export agency presents two major optimization directions:

The above policy dividends shall be selected and applied according to the actual situation of the enterprise.For example,a Shanghai medical device enterprise exported products to Germany via Zhongshitong as agent.Since the products involve EU CE certification,the adoption of "RMB original currency transfer" saved 23,000 RMB in settlement costs and shortened the fund return cycle by 5 working days.

IV.Key Q&A and Practical Operation Checklist

(1) Answers to Frequently Asked Questions

• Q: Can the US dollar be directly transferred to an individual under export agency?
  A: In 2026,the SAFE explicitly prohibits "export agency proceeds being collected into individual foreign exchange accounts".The transfer must be completed through the public account of the principal.If individual collection is indeed required,it is necessary to complete "overseas investment filing" in advance and submit supporting documents required by the Measures for the Administration of Individual Foreign Exchange.
• Q: Will original currency transfer affect export tax rebate?
  A: No.Enterprises can submit tax rebate applications through the Electronic Tax Bureau with documents such as special customs declaration form for export agency and export agency agreement.The tax rebate amount is calculated by converting the original currency amount into RMB.

(2) Practical Operation Compliance Checklist

• Check whether the Foreign Trade Operator Record Registration Form and the Export Agency Agreement of the principal are within the validity period
• Complete the declaration of "export agency goods customs declaration form" through the "Single Window",and ensure that the "proceeds receiver" column is filled with the public account information of the agent party
• Complete the "export proceeds difference" registration through the "Trade in Goods Foreign Exchange Monitoring System" within 24 hours after the proceeds are credited into the account
• Check the balance of the foreign exchange account at the end of each quarter,and proactively contact the SAFE to explain the reasons for funds that have not been transferred for more than 90 days

Zhongshitong always adheres to the principle of "compliance as the foundation,service as the priority".In 2026,we have assisted more than 200 enterprises in the Yangtze River Delta region to complete the compliance transformation of original currency transfer under export agency,with an average 30% reduction in proceeds collection cycle and exchange loss controlled within 0.3%.For customized solutions,please contact Zhongshitong Shanghai Headquarters (Tel: 139-1777-6136) for one-on-one consultation.