The Export-Import Bank of the United States (U.S. Exim) is falling behind its international counterparts due to outdated content rules, a slow approval process, and insufficient staffing, according to the bank’s latest annual competitiveness report and feedback from exporters and lenders.
Global export credit agencies (ECAs) provided a total of $115.4 billion in medium- to long-term (MLT) export credit in the past year, marking a 20% rise from 2023. China led the list with $23.5 billion in MLT support, followed by Germany ($18.6bn), Italy ($16.9bn), France ($12.1bn), and Korea ($9.2bn). U.S. Exim ranked seventh, issuing $5.9 billion, up from $4.7 billion in 2023.
Despite this growth, U.S. Exim has failed to match the flexibility and innovation of other ECAs. Acting President and Chair James Cruse described the agency as operating with a ’20th-century’ mindset in a rapidly evolving 21st-century landscape. Cruse noted that U.S. Exim’s rigid policies, especially around content requirements and risk appetite, are being used by competitors to dissuade buyers from using the U.S. agency.

Nearly two-thirds of the surveyed exporters and lenders (64%) rated U.S. Exim as either ‘far less competitive’ or ‘slightly less competitive’ than its peers, a figure that has remained consistently above 60% since the agency’s reauthorization in 2019. Between 2015 and 2019, political opposition had rendered the bank functionally inactive, as it lacked a board quorum and could not approve transactions exceeding $10 million.
Domestic Content Rules a Major Obstacle
A central concern is U.S. Exim’s requirement that 85% of the export contract content be produced in the United States. While the China and Transformational Exports Program (CTEP) allows some flexibility, potentially lowering the requirement to 51%—72% of respondents said the content policy still negatively impacts the bank’s competitiveness, up from 64% the previous year.
By contrast, rival ECAs such as those in Europe and Asia have adopted more flexible domestic content policies, some as low as 20–30%. Some, like Germany’s Euler Hermes, evaluate broader factors like job creation, tax contributions, and local training efforts under products like ‘flex&cover.’

Other ECAs are also more proactive, engaging with project sponsors early in the process and using flexible letters of interest to secure a ‘first mover’ advantage, without imposing strict requirements upfront. Countries such as Switzerland, Poland, the UK, and Canada have implemented matchmaking systems to connect exporters with potential projects.
Staffing Shortages and Political Uncertainty
The report also highlights operational inefficiencies at U.S. Exim, particularly a slow and unpredictable deal approval process caused by staffing shortages and a lack of technical expertise. Bank respondents expressed frustration with delays and insufficient communication, which undermine lenders’ ability to provide reliable timelines to their clients.
Shipping requirements also remain a point of criticism, especially mandates to use U.S.-flagged vessels for large transactions. In addition, concerns were raised about the effects of political instability on the agency’s long-term viability. U.S. Exim requires periodic reauthorization by Congress, the next one due by December 31, 2026, while most of its international peers operate without such constraints.
“Exporters and lenders noted unease from clients reconsidering applying for future Exim support,” the report says, citing the multiyear nature of many international projects and the importance of continuity in ECA partnerships.
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