How to Maintain Proper Shipping Bills and Bill of Exports Records

May 23, 2025 8 min read

Before diving into details, here's the bottom line: auditors of export transactions zero in on the accuracy, completeness and traceability of your Shipping Bills (SB) and Bills of Export (BoE). They will ask for evidence that every SB/BoE matches your commercial invoice, packing list, Bill of Lading/Airway Bill and bank realization records; that it was filed timely (via EDI or non‑EDI on ICEGATE); and that original and backup copies are retained in an indexed, tamper‑proof system for the statutory period (generally five years). To satisfy auditors, implement standardized filing conventions (electronic and hard‑copy), reconcile SB/BoE data regularly (including via EDPMS), train staff on SOPs, and perform periodic internal reviews to catch discrepancies before customs or tax audits.

1. Common Auditors' Queries on Shipping Bills & Bills of Export

Audit Begins
Document Verification
Check SB/BoE against commercial invoice, packing list, and Bill of Lading
Data Accuracy Check
Verify HSN codes, quantities, values, and Incoterms
Timeliness Review
Confirm filing before Let Export Order date
Audit Conclusion

1.1 Data Accuracy and Completeness

  • Query: "Does each Shipping Bill accurately reflect the exporter/importer details, HSN/ITC‑HS codes, quantity, weight, FOB/CIF values and Incoterms as per the sales contract?" Auditors compare the SB data against the commercial invoice and sales contract to ensure zero discrepancies.
  • Query: "Are all requisite fields in the BoE (for multimodal exports) duly filled and signed off by the authorized Customs House Agent?" Missing or incorrect entries can trigger penalties.

1.2 Reconciliation with Supporting Documents

  • Query: "Have you reconciled the SB/BoE line items with the packing list, Bill of Lading (ocean/air), and the export invoice?" A mismatch in descriptions or quantities often flags data‑entry errors.
  • Query: "Are export proceeds under each SB reported and tracked via EDPMS, and do bank realization advices match the declared values?" Auditors will request EDPMS printouts showing payment realization status.

1.3 Timely Filing and Regulatory Compliance

  • Query: "Was the SB/BoE filed on or before the Let Export Order (LEO) date through the correct ICEGATE module (EDI vs. non‑EDI)?" Late filing can attract demurrage and other charges.
  • Query: "Do you hold copies of any amendments or cancellations to the original SB/BoE, along with authorization from Customs?" Such changes must be duly recorded and justified.

1.4 Storage, Accessibility and Audit Trail

  • Query: "Do you maintain a centralized, indexed repository (electronic & physical) for all SBs, BoEs, invoices, packing lists and correspondence?" Easy retrieval demonstrates good internal control.
  • Query: "Is there an established record‑destruction policy that aligns with the five‑year (or longer) retention requirement under FTR and CBP regulations?" Premature disposal can lead to non‑compliance findings.

2. Best Practices to Maintain Proper SB/BoE Records

Document Creation
EDI Filing
File via ICEGATE with proper documentation
Reconciliation
Match with invoices, packing lists, and BoL
Secure Storage
Physical and digital archives with access control
Periodic Review
Quarterly audits and compliance checks

2.1 Standardized Filing System

  • Use consistent file‑naming conventions (e.g., SB_YYYYMMDD_<IEC>_<BOEno>.pdf) and folder structures by financial year and export party.
  • Index every document in an internal register (electronic or ledger), capturing key metadata: SB/BoE number, exporter IEC, date, port code, and value.

2.2 Electronic Data Interchange (EDI) & ICEGATE Utilization

  • File SBs electronically via ICEGATE EDI to ensure timestamped, immutable records; retain the system‑generated acknowledgment for audit trails.
  • Maintain EDI logs showing upload, validation and LEO issuance, including any error messages and corrections.

2.3 Reconciliation & Periodic Review

  • Monthly reconciliation between SB/BoE registers, invoices, bank realization statements (EDPMS printouts) and GSTR‑1/GST‑3B data.
  • Monthly internal audit checks by the compliance team to preempt external audit findings; document discrepancies and resolution actions.
Document Creation
Active Retention (5 Years)
Immediate access required
Archival Period
Extended retention for special cases
Secure Disposal
After statutory period ends

2.4 Secure Storage & Backup

  • Store hard‑copies in fire‑proof, locked cabinets; retain digital backups on secure, access‑controlled servers or cloud storage & perform periodic restoration tests.
  • Implement version control for SB/BoE amendments, ensuring that superseded drafts are archived and accessible if auditors ask for them.

2.5 Training & Standard Operating Procedures (SOPs)

  • Document SOPs covering SB/BoE preparation, filing, amendment, reconciliation, retention and destruction policies, approved by management.
  • Conduct regular training for export operations staff and customs‑facing personnel to refresh them on regulatory changes and best practices.

Key Takeaways

Maintain 100% accuracy between SB/BoE and supporting documents
Implement electronic filing with ICEGATE for audit trails
Establish a secure, indexed document management system
Conduct monthly reconciliations and internal audits
Train staff regularly on updated procedures

By proactively addressing these areas—accuracy, reconciliation, regulatory compliance, storage, retention and internal controls—you'll be well prepared to satisfy any auditor's queries on your Shipping Bills and Bills of Export.

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