Bank domiciliation for imports: what Instruction 05-2026 and Note 01/DGC/2026 change
📌 In short: In May 2026 the Bank of Algeria issued two texts in quick succession that reshape how importing works. Note no. 01/DGC/2026 of 14 May requires bank domiciliation to take place before the goods are shipped. Instruction no. 05-2026 of 19 May makes any domiciliation of an import of goods intended for resale in the state conditional on two ratios: net assets ≥ share capital, and outstanding unsettled balance ≤ 100% of equity across all banks. In practice, your ability to import is now decided on your balance sheet — before the order is even placed.
Keywords in this article
1. What changed in May 2026: three texts to read together
Taken separately these texts look technical. Read together they follow a single logic: moving the control upstream, from settlement to commitment. Where a file used to be regularised along the way, it is now settled before the supplier ships anything at all.
| Text | Date | What it requires | Applies to |
|---|---|---|---|
| Instruction no. 03-26 | 26 April 2026 | Caps banks' external commitments by signature at 50% of their regulatory equity | Banks and financial institutions |
| Note no. 01/DGC/2026 | 14 May 2026 | Bank domiciliation mandatory before the goods are shipped | Approved intermediary banks |
| Instruction no. 05-2026 | 19 May 2026 | Financial standing requirements for importing goods intended for resale in the state | Domiciliary banks and operators |
📌 The point most often missed: Instruction 03-26 is not addressed to importers, yet it hits them directly. By capping banks' external commitments by signature at 50% of regulatory equity, it shrinks the overall envelope available. A bank approaching its ceiling becomes selective — regardless of how good your file is.
A shared legal basis
Both May measures rest on the same foundation: Regulation no. 07-01 of 3 February 2007 on the rules applicable to current transactions with foreign countries and to foreign currency accounts, as amended and supplemented. The 14 May note is based on paragraph 3 of its Article 29; the 19 May instruction, signed by Governor Mohamed Lamine Lebbou, on its Article 42. This is therefore not a new regime, but a tightened application of an existing framework.
2. Financial standing: two hard numerical conditions
Instruction no. 05-2026 sets out a simple principle: the domiciliary bank must assess the operator's financial standing before any domiciliation of an import of goods intended for resale in the state. That assessment is not left to interpretation — the text fixes two thresholds.
Condition 1 — Net assets must be at least equal to share capital
Before any domiciliation, the bank must satisfy itself that the operator's net assets are equal to or greater than its share capital. The check is performed on the basis of the financial statements of the past financial year as declared to the tax administration. In other words: it is your filed accounts that speak, not a position reconstructed for the occasion.
The practical consequence is severe for a very common category of company: those carrying accumulated losses. Once retained losses have absorbed part of the capital, net assets fall below share capital — and domiciliation becomes impossible until the position is restored.
Condition 2 — Unsettled balance capped at 100% of equity
The second lock is a ceiling on external trade debt: the outstanding balance of imports for resale in the state domiciled by the operator across all approved intermediary banks and not yet settled must at no time exceed one hundred per cent (100%) of its equity.
Three elements deserve emphasis:
- "across all banks" — the ceiling is consolidated. Splitting domiciliations between institutions does not raise it.
- "at no time" — compliance is continuous, not measured at a closing date.
- "not yet settled" — an operation counts as settled only when the domiciliary bank makes the final debit of the operator's account for the value of the operation. Until that final debit, the balance stays consumed.
The multi-bank declaration
To make the consolidated ceiling auditable, the instruction requires the operator to provide, before any domiciliation, a declaration in the annexed form stating the outstanding balances of its operations domiciled with other approved intermediary banks. That declaration binds its signatory.
⚠️ Newly incorporated companies. The text provides that the bank may rely on an opening balance sheet and/or an interim financial position duly certified by a statutory auditor. This is flexibility, not exemption: both ratios still apply — only the source of the figures changes.
3. The new sequence of an import operation
Note no. 01/DGC/2026 reverses a habit built up over years. Domiciliation is no longer a formality completed while the goods are in transit: it now conditions their departure.
Check eligibility — before negotiating
Test both ratios against the latest filed financial statements, and calculate the balance already consumed across all banks. Feasibility is decided at this stage, not later.
Domicile the file
Proforma invoice or contract, declaration of balances held with other banks, and the past year's financial statements as declared to the tax authorities. The bank assesses financial standing and opens — or refuses — the domiciliation.
Authorise shipment — only then
The shipping instruction must reach the supplier only once domiciliation is open. Any earlier shipment pushes the operation into non-compliance.
Face the documentary date check
The bank systematically verifies that the transport document date is later than the domiciliation date. Documents examined include the commercial invoice, Bill of Lading, Airway Bill, CMR, shipping certificates and any document establishing the effective shipping date.
If the transport document predates the domiciliation, the bank must refuse the operation — unless an exceptional authorisation expressly provided for by exchange regulations applies. The note also recalls that failure to comply constitutes an offence under exchange legislation and regulations, and instructs banks to inform their customers accordingly.
🗓️ Transitional measure. The new provisions do not apply to operations whose effective shipment to national customs territory took place before the note was published. Proof is established by the date on the transport document. Instruction 05-2026 contains an equivalent carve-out for goods already shipped before its promulgation.
4. Who is affected — and who is not
The distinction is decisive and frequently misunderstood: the two texts do not have the same scope.
| Situation | Note 01/DGC/2026 domiciliation before shipment | Instruction 05-2026 financial standing |
|---|---|---|
| Import of goods for resale in the state | ✓ applies | ✓ applies |
| Import of inputs and raw materials processed locally | ✓ applies | — outside the text's scope |
| Import of equipment for own account | ✓ applies | — outside the text's scope |
| Goods shipped before publication of the texts | — excluded | — excluded |
| Newly incorporated company | ✓ applies | ✓ applies, on a certified opening or interim statement |
In short: every importer is affected by the sequencing rule (domicile before shipping), but only importers of goods intended for resale in the state face the two financial standing ratios. A manufacturer importing its inputs is not subject to the thresholds of Instruction 05-2026 — which of course does not exempt it from its own bank's requirements.
5. Self-diagnosis: will your file pass?
Four calculations, doable in an hour on your latest filed statements, are enough to know where you stand before approaching your bank.
| # | What to calculate | Regulatory threshold |
|---|---|---|
| 1 | Net assets = total assets − total liabilities | ≥ share capital |
| 2 | Equity (shareholders' funds in the filed balance sheet) | basis of the ceiling |
| 3 | Domiciled unsettled balance, all banks | ≤ 100% of equity |
| 4 | Remaining headroom = equity − balance (3) | maximum still domiciliable |
Worked example
Illustrative figures, intended to show the mechanism:
- Share capital: 20,000,000 DZD
- Equity after accumulated losses of 4,000,000 DZD: 18,500,000 DZD
- Domiciled unsettled balance — bank A: 9,000,000 DZD · bank B: 6,000,000 DZD → 15,000,000 DZD
Condition 1: net assets 18,500,000 < share capital 20,000,000 → not met. Domiciliation is blocked, whatever the size of the intended operation.
Condition 2: 15,000,000 / 18,500,000 = 81% → below the ceiling, with 3,500,000 DZD of headroom. But that headroom is unusable until condition 1 is restored.
💡 The consolidated-ceiling trap. Many operators reason bank by bank and discover the blockage when filling in the annexed declaration. The consolidated balance must be tracked internally and continuously — it is the only way to know, before ordering, how much can still be domiciled.
6. Net assets below share capital: how to restore the position
Where condition 1 is not met, the gap is closed either by increasing equity or by reducing the reference share capital. The levers below exist under Algerian law; their relevance, tax cost and feasibility depend entirely on the company's situation and must be decided with its advisers.
- Cash capital increase — immediate effect on equity, but ties up cash and requires shareholder agreement.
- Conversion of shareholder current accounts — turns a debt owed to shareholders into equity. Often the fastest lever where current accounts are significant.
- Allocation of profit to reserves — no effect in a loss-making year, but structurally sound over several years.
- Capital reduction to absorb losses, followed by an increase — the "accordion" operation, which clears accumulated losses. A heavy procedure, to be weighed with a lawyer.
- Staggering orders — does not solve condition 1, but once it is restored, allows the balance to stay under the ceiling by sequencing domiciliations.
🔎 Field observation (from our engagements, not from a regulatory text). On the import files we have supported, the blockage rarely comes from the business itself: it comes from a balance sheet that was never managed as a financing tool. Accumulated losses left untreated for three years cost far more, on the day the rule changes, than they would have cost to address when they first appeared.
This article sets out the applicable regulatory framework and constitutes neither legal advice nor a recommendation to carry out any operation. Every situation must be examined against the company's actual financial statements.
7. Five mistakes that stop an operation
Observations drawn from practice supporting importing operators, not from regulatory provisions.
- Issuing the shipping instruction before domiciliation is open. This is now the costliest error: the Bill of Lading date freezes the position and leaves the bank no discretion.
- Reasoning bank by bank. The 100% ceiling is consolidated across all approved intermediary banks, and the annexed declaration makes it verifiable.
- Counting an operation as settled too early. Until the final debit of the account has taken place, the balance stays consumed — a partial payment or a provision releases nothing.
- Presenting accounts that differ from those filed with the tax authorities. The text refers expressly to financial statements "as declared to the tax administration". Any discrepancy is immediately visible.
- Discovering your net asset position at order time. Restoring equity takes weeks of formalities; it cannot be decided while the supplier is waiting for the shipping instruction.
FAQ — Frequently asked questions
🔎 Sources and references
- Instruction no. 05-2026 of 19 May 2026 setting financial standing requirements for imports of goods intended for resale in the state — Bank of Algeria — Exchange regulations · Verified on 01/08/2026
- Note to banks no. 01/DGC/2026 of 14 May 2026 — Directorate General of Exchange — Bank of Algeria · Verified on 01/08/2026
- Regulation no. 07-01 of 3 February 2007 on rules applicable to current transactions with foreign countries and to foreign currency accounts (Art. 29 §3 and Art. 42), as amended and supplemented — Bank of Algeria · Verified on 01/08/2026
- Instruction no. 03-26 of 26 April 2026 setting the level of external commitments of banks and financial institutions — Bank of Algeria · Verified on 01/08/2026
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