5.3 Roshan Digital Accounts & ESFCA Retention
Key Takeaways
- SBP’s Roshan Digital Account page states that RDA may be foreign-currency and/or PKR, conventional or Shariah-compliant, and that funds in the account can be remitted back from Pakistan without bank or SBP approval.
- RDA can be funded from abroad and with income earned on investments made from those funds; local resident rupees cannot be deposited, because the account is repatriable.
- EPD Circular Letter No. 06 of 2026 (6 April 2026) did not change the IT/ITeS/freelancer retention numbers: USD 5,000 per month or 50% of export proceeds, whichever is higher. It did impose one-working-day processing and dropped Form R for those export receipts.
- Authorized Dealers must credit the permissible ESFCA amount unless the exporter writes to retain less or none. ESFCA balances cannot be transferred to another FCY/FE-25 account; cash withdrawal in Pakistan is not allowed.
- Other legitimate services exporters retain 35% of net FX earnings (Chapter 12 paragraph 36). Incremental goods-export retention is 50% of additional earnings if USD earnings grow at least 10% versus last financial year, with FEOD permission on Appendices V-22 and V-23.
Roshan Digital Accounts — official SBP page, not folklore
Open https://www.sbp.org.pk/our-operations/roshan-digital-accounts. The live page is the source for this independent OpenExamPrep subsection.
The customer may choose a foreign currency account, a PKR account, or both. The two are interoperable, with real-time online conversion FCY to PKR and PKR to FCY. Single, joint, current, and savings accounts are available. Both conventional and Shariah-compliant accounts can be opened.
Fully repatriable: funds in the Roshan Digital Account can be remitted back from Pakistan without any approval from the bank or SBP.
Funding rule (SBP note on the same page): funds can be transferred into RDA only from abroad. Income earned from investments made through those funds — rent or profit on property bought through RDA, profits on Naya Pakistan Certificates (NPCs), share dividends, and similar — may be added. No other funds can be deposited locally. That bar exists so resident Pakistanis cannot load local rupees into a repatriable wrapper and take them out.
Eligibility on the SBP page:
- Non-resident Pakistanis with Pakistani passport, NICOP, POC, or NIC
- Employed, self-employed, unemployed, housewives/homemakers, students, children, and pensioners
- Foreign companies and foreign-national individuals
Account opening is digital through a participating bank. SBP quotes confirmation within 48 hours for individuals and 5 days for entities. After opening, transfer funds through banking channels from the country of residence. Complaints about excessive documents go to RDASupport@sbp.org.pk.
NPCs are GOP instruments in USD, PKR, Euro, SAR, AED, and GBP, conventional and Shariah-compliant, administered by SBP. Islamic NPC profits follow Mudarabah on monthly financials. The Federal Government’s RDA tax regime (profit on RDA deposits tax-exempt; NPC profit 10% full and final for NRPs and for residents with declared foreign assets; listed share/mutual-fund capital gains and many dividends at published full-and-final rates) is tax-law content on the SBP page — teach it as published there, not as an FE Manual paragraph.
RDA is a non-resident digital product. It is not an ESFCA. A freelancer in Karachi who is tax-resident in Pakistan does not “open RDA instead of ESFCA.”
ESFCA — locked numbers, then Circular Letter 06 of 2026
Exporters’ Special Foreign Currency Accounts (ESFCA) are Chapter 12 retention accounts. Three layers matter, in date order.
EPD Circular Letter No. 17 of 2023 (23 October 2023) raised IT / ITeS / freelance retention from 35% to 50% of export proceeds and let those exporters make current-account payments abroad from ESFCA without prior SBP approval. Other services in paragraph 36 stayed at 35% of net FX earnings.
EPD Circular Letter No. 02 of 2024 (23 February 2024) amended Chapter 12 paragraph 40: all exporters may freely use ESFCA balances for all types of current-account payments abroad for their own business, without prior SBP approval. ADs may issue debit cards against ESFCA balances on request. No FCY cash withdrawal in Pakistan. Transfers are allowed ESFCA-to-ESFCA of the same exporter at another AD, not to ordinary FCY/FE-25 accounts. PKR conversion is allowed anytime on request.
EPD Circular Letter No. 06 of 2026 (6 April 2026) attaches a revised Chapter 12 paragraph 12 as Annexure-A. Retention numbers did not change. Teach the new process as Circular Letter 06, and say so.
Circular Letter 06 Annexure-A — what actually changed
Definitions. IT companies are entities (sole proprietorships, partnerships, companies) registered with PSEB or P@SHA and engaged in export of software, IT, and ITeS. Freelancers are individuals resident in Pakistan who provide online services, including IT and ITeS, to international clients on a contract or project basis, without being employed by a single organization, and who are paid from abroad.
Account opening. Open ESFCA concurrently with the primary PKR account. Use SBP’s consolidated Customer Onboarding Framework (BPRD Circular No. 1 dated 25 July 2025).
Inward processing. Take a one-time declaration of the nature of service at account opening (and from existing customers when required). Tag the service and purpose code to the account for ITRS, unless the exporter declares a different purpose or the SWIFT contradicts the tag. Multi-service exporters must tell the AD when a receipt’s purpose differs from the tag.
ADs must process inward export receipts of IT companies and freelancers within one working day from receipt of funds, unless the exporter uses the three-day shop-around in Chapter 12 paragraph 7, or until the exporter intimates a purpose-code change. If the beneficiary banks elsewhere, the receiving AD passes funds within one working day; the beneficiary bank then credits within one working day of receiving those funds.
Retention (numbers unchanged). IT companies and freelancers may retain USD 5,000 (or equivalent) per month or 50% of export proceeds, whichever is higher. ADs must credit the permissible amount unless the exporter requests in writing, preferably at account opening, that a lesser amount or none be credited.
Utilization. IT companies: all current-account payments for own business (imports, foreign services, profit/dividend on registered shares, and similar) without prior SBP approval. Freelancers: personal and work-related current-account payments (digital services, digital marketing, memberships, certification, education, and similar) without prior SBP approval. Capital and financial-account uses (equity investment abroad, FCY loan repayments) still follow Chapters 20 and 19. Convert to PKR anytime. Cannot credit or transfer to any other FCY account. Outward remittances from ESFCA: one working day from the customer’s request; if documents are missing, tell the exporter within one working day what is needed, then remit within one working day of receiving it. Digital-channel service payments: obtain agreement/invoice post-facto within three working days, preferably digitally. Debit cards on specific request; no cash withdrawal in Pakistan. Same-exporter ESFCA-to-ESFCA transfer across ADs remains.
Reporting. Monthly software-export statement Appendix V-13 to FEOD, SBP-BSC. IT companies and freelancers shall not submit Form R to ADs for their export receipts. ADs still report under the correct purpose codes. EPD also told ADs to build an internal complaint mechanism for IT companies and freelancers.
EPD Circular Letter No. 07 of 2026 (same day) revised Forms R, IRV, and M for the wider market. Do not import a newspaper “USD 25,000 Form R threshold” into paragraph 12 unless you are reading Circular Letter 07’s own annexure. For IT/freelancer export receipts, Circular Letter 06’s rule is simpler: no Form R.
| Exporter class | Retention | Permission needed? | 2026 process note |
|---|---|---|---|
| IT / ITeS / freelance (para 12 as revised 6 Apr 2026) | USD 5,000/month or 50% of proceeds, whichever higher | AD credits unless written opt-down | One-working-day inward and outward; no Form R on those export receipts |
| Other legitimate services (para 36) | 35% of net FX earnings | AD under para 36 | CL 06 did not rewrite para 36 |
| Incremental goods/export earnings (para 37) | 50% of additional earnings | FEOD on V-22 (bank-wise) and V-23 (consolidated) | Requires at least 10% USD growth versus last financial year |
| Goods-export commission leftover (para 35(iii)) | Unused commission/discount within prescribed FOB limits | AD | Separate from para 12 |
Paragraph 36 examples include financial, distribution, logistics, storage, communications, telecom, medical, educational, engineering, real estate development, tourism, technical testing, and consultancy — not covered under paragraph 12. A consultancy firm that is not a PSEB/P@SHA IT exporter does not get the 50%/USD 5,000 test.
Paragraph 37: exporters with at least 10% growth in net FX earnings in USD over last financial year’s performance may, with FEOD, SBP-BSC, Karachi permission, retain 50% of additional export earnings. File Appendix V-22 bank-wise and Appendix V-23 consolidated. The facility is in addition to paragraph 35(iii). It is not self-granted by the branch.
Paragraph 40 (as amended 2024) remains the utilization spine for goods and other-services ESFCAs: current-account payments for own business without prior SBP approval; capital-account payments only through Chapters 19/20 procedures; debit cards on request; no FCY cash in Pakistan; no transfer to other FCY/FE-25; PKR conversion on request.
Pakistani AD branch scenarios
Scenario A — USD 3,000 freelance month. 50% is USD 1,500; the floor is USD 5,000. Credit USD 3,000 to ESFCA unless the freelancer has written to retain less. Do not cap at 50% of 3,000.
Scenario B — USD 20,000 IT invoice. 50% is USD 10,000, which is higher than USD 5,000. Credit USD 10,000 to ESFCA unless a written opt-down exists.
Scenario C — RDA loading. A resident brother offers to cash-deposit PKR into a sister’s RDA in Dubai. SBP’s page forbids local funding of a repatriable RDA. Refuse.
Scenario D — Form R habit. Operations still demands Form R on every Upwork receipt. Circular Letter 06: IT companies and freelancers shall not submit Form R for those export receipts. Tag the purpose code from the one-time declaration.
Scenario E — incremental retention without FEOD. A textile exporter grew 12% in USD and wants 50% of the increment in ESFCA this week. Paragraph 37 requires V-22/V-23 and FEOD permission first.
Scenario F — ESFCA to personal FE-25. A founder wants dollars moved from ESFCA to a personal FE-25. Paragraph 12 and paragraph 40 both forbid transfer to any other FCY/FE-25. Same-exporter ESFCA at another AD is the permitted transfer.
Traps
- Saying Circular Letter 06 raised retention above 50% or above USD 5,000 — it did not
- Applying the 50%/USD 5,000 test to paragraph 36 services exporters
- Granting paragraph 37 incremental retention without FEOD
- Transferring ESFCA to ordinary FE-25
- Paying FCY cash from ESFCA in Pakistan
- Funding RDA with local resident rupees
- Treating RDA as a substitute ESFCA for a resident freelancer
Under EPD Circular Letter No. 06 of 2026 Annexure-A, what is the ESFCA retention entitlement for IT companies and freelancers?
Which funding rule matches the official SBP Roshan Digital Account page?
An exporter of logistics services (not a PSEB/P@SHA IT company) wants ESFCA retention. Which published Chapter 12 figure applies?