RBI sets nine-month export realisation period in new FEMA export-import rules
Key points
- RBI has cut the period for realising and repatriating export proceeds under the new export-import regulations from fifteen months to nine months.
- Exporters of goods, software and services are affected; for exports invoiced or settled in rupees, the period falls from eighteen months to twelve.
- The amendment, dated 22 September 2026, took effect on 1 October 2026, the date the new regulations came into force.
The Reserve Bank of India (RBI) has amended the Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026 just before they took effect, shortening the time exporters have to bring home export proceeds. Under Notification No. FEMA 23(R)/(1)/2026-RB dated 22 September 2026, the realisation period is nine months instead of fifteen. The amendment came into force on 1 October 2026, the same date as the new regulations.
What has changed
The principal regulations were notified on 13 January 2026 (Notification No. FEMA 23(R)/2026-RB) and supersede the Foreign Exchange Management (Export of Goods & Services) Regulations, 2015. Regulation 5 sets the period within which the full export value must be realised, including by set-off, and repatriated. The amendment changes it as follows:
| Type of export | As notified in January 2026 | As amended |
|---|---|---|
| Goods (other than goods sent to a warehouse outside India), from the date of shipment; services, from the date of invoice | Fifteen months | Nine months |
| Goods exported to a warehouse outside India, from the date of sale from the warehouse | Fifteen months | Nine months |
| Exports invoiced or settled in Indian rupees | Eighteen months | Twelve months |
Under the principal regulations, project exports follow the payment terms of the contract, and banks (Authorised Dealers) may extend the period if an exporter gives reasons for the delay and the bank is satisfied with them.
The amendment makes two other changes:
- Caution List: Exporters on the Caution List as on 30 September 2026, under orders issued by RBI under Regulation 16 of the 2015 regulations, will continue to be governed by those orders until they are removed from the list.
- Older transactions: A new Regulation 20 says banks shall handle export, import and merchanting trade transactions undertaken before 1 October 2026 that until now required RBI approval under the 2015 regulations, the Master Direction – Export of Goods and Services and the Master Direction – Import of Goods and Services.
Who is affected
The shorter period affects all exporters of goods and services, and the regulations treat software as a service. That includes startups and IT firms billing overseas clients. Banks that monitor export receivables are also affected. Exporters, importers and merchanting traders with transactions from before 1 October 2026 that needed RBI approval will now deal with their bank instead.
What this means for businesses
In practice, this means:
- Exporters who planned around the fifteen-month period announced in January should work to nine months, or twelve months for rupee invoicing. Credit terms with overseas customers may need another look.
- Under Regulation 13 of the principal regulations, an exporter whose proceeds remain unrealised for more than one year beyond the due date, or any extended date, can export further only against full advance payment or an irrevocable letter of credit. A shorter realisation period brings that due date forward.
- Where a payment is likely to be late, exporters can ask their bank for an extension, giving reasons.
- The notification does not separately say how the nine-month period applies to shipments or invoices dated before 1 October 2026. Exporters with older receivables should confirm the position with their bank or adviser.
Key dates
- 13 January 2026: principal regulations notified.
- 22 September 2026: amendment notified; published in the Official Gazette on 24 September 2026.
- 30 September 2026: cut-off date for the Caution List provision.
- 1 October 2026: new regulations and the amendment in force.
This update was written with AI from the official source above and automatically fact-checked against it before publishing. It is general information, not professional advice. Check the source, or talk to a Chartered Accountant, before acting on it.