RBI Keeps Export Realisation Period at Nine Months as New FEMA Export-Import Rules Start October 1

The Reserve Bank of India has shortened the time exporters will get to realise and repatriate export proceeds under the new Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026. It did so before those regulations have even come into force. Through Notification No. FEMA 23(R)/(1)/2026-RB dated 22 September 2026, RBI replaced "fifteen months" with "nine months" for goods and services, and "eighteen months" with "twelve months" for exports invoiced or settled in Indian rupees. The 2026 Regulations take over from the 2015 export regulations on 1 October 2026. Shipments and service invoices from that date will therefore carry a nine-month deadline, not the fifteen months written into the regulations when they were notified in January.

The amendment was published in the Official Gazette on 24 September and listed by RBI on 25 September. It also adds a transition rule for exporters on RBI's Caution List and a new regulation that hands banks the older export, import and merchanting cases that used to need RBI approval. The amended text, with footnotes recording each substitution, appears in RBI's updated text of the Export and Import of Goods and Services Regulations, 2026.

Realisation periods that apply from 1 October 2026

Regulation 5, as amended, requires the full export value (or a reduced value allowed under Regulation 6) to be realised, including by set-off under Regulation 7, and repatriated within these periods:

• nine months from the date of shipment for goods, and from the date of invoice for services;
• nine months from the date of sale from the warehouse, for goods exported to a warehouse outside India;
• the payment terms of the contract, for project exports;
• twelve months, where the export is invoiced or settled in Indian rupees.

The authorised dealer (AD) bank can still extend the period when the exporter applies and explains the delay. Regulation 5 sets no outer limit for such extensions, so the bank's own policy and its view of the reasons given will decide how much more time is allowed.

How the deadline has moved between nine and fifteen months since November 2025

The September amendment is the fourth change to this deadline in less than a year:

1. 13 November 2025: Notification No. FEMA 23(R)/(7)/2025-RB amended Regulation 9 of the Foreign Exchange Management (Export of Goods and Services) Regulations, 2015, raising the realisation period from nine months to fifteen months. It also replaced "one year" with "three years" in Regulation 15. The background is set out in this Mondaq note on RBI's November 2025 extension of export timelines.
2. 13 January 2026: RBI notified the 2026 Regulations (FEMA 23(R)/2026-RB) with effect from 1 October 2026, keeping fifteen months as the standard period and allowing eighteen months for rupee exports.
3. 5 June 2026: the First Amendment Regulations, 2026 to the 2015 export regulations (FEMA 23(R)/(8)/2026-RB) took the period under the 2015 framework back to nine months, as also reported in EY's alert on the June revision.
4. 22 September 2026: the present amendment brings the 2026 Regulations into line with that nine-month position before they start.

In practice, the nine-month period that exporters have worked with since June carries on into the new framework. Businesses that had planned receivable cycles, customer credit terms or bank extension requests on the basis that fifteen months would return on 1 October will need to revisit those plans.

Which shipments stay under the 2015 regulations

The 2026 Regulations supersede the 2015 export regulations "except in respect of things done or omitted to be done before such supersession". A reasonable reading is that exports shipped or invoiced before 1 October 2026 continue to be tested against the 2015 regulations as they stood at the time. The September notification does not include a transition table. Exporters with open shipments from the November 2025 to June 2026 window, when fifteen months applied, should confirm with their AD bank which due date it is using for each entry.

Caution List exporters stay under their existing RBI orders

Regulation 13 of the 2026 Regulations deals with proceeds that remain unrealised for more than one year from the due date, or from the extended date allowed by the AD bank. In that case the exporter may make further exports only against full advance payment or an irrevocable letter of credit. A new proviso deals with exporters in the Caution List as on 30 September 2026 under RBI orders issued under Regulation 16 of the 2015 regulations. They will continue to be governed by those orders until they are removed from the list. Caution-listed exporters therefore do not get a fresh start when the new regulations begin.

Banks take over older cases that needed RBI approval

New Regulation 20 provides that AD banks "shall handle transactions related to the export and import of goods and services, as well as merchanting trade, undertaken prior to October 01, 2026, which hitherto required approval of the Reserve Bank of India". According to the text of the September amendment reproduced by TaxGuru, this covers approvals required under the 2015 regulations and the Master Directions on export and import. Exporters and importers with old extension, write-off or closure matters will therefore deal with their AD bank under the new regime. The notification does not say what happens to applications already pending with RBI on 30 September.

Points for exporters, finance teams and their advisers before 1 October

• Check that payment terms on new export contracts and invoices fit within nine months, or twelve months where the export is invoiced or settled in rupees.
• For services, the nine months run from the invoice date, so billing delays and collection follow-up both affect compliance.
• Reconcile open export entries in EDPMS with the AD bank. Under Regulation 18, banks must enter export declaration details in EDPMS within five working days of receiving them, and unrealised entries are what the bank follows up.
• Where more time will be needed, apply to the AD bank before the due date with documented reasons, since an extension depends on the bank being satisfied.
• Merchanting trade remains subject to a six-month limit between the outward and inward remittance legs under Regulation 16.

Export receipts are current account transactions, the category explained in current account versus capital account transactions under FEMA, and the realisation deadline is the main control FEMA applies to them. Where a deadline has already been missed, the transaction has to be regularised first. The contravention may then be taken to RBI for compounding, a process set out in how FEMA compounding works and how to apply to RBI.

Official source: View the official source document