FEMA Export Realisation Period 2026: Why Your Deadline Is 9 Months Now and 15 Months From October 1, 2026

Quick Summary: The Export Realisation Deadline in 2026

The window keeps moving. The period to realise and repatriate export proceeds has gone from 9 months, up to 15 months, back down to 9 months, and will return to 15 months from October 1, 2026.
Right now (exports on or after June 5, 2026): the deadline is 9 months from the date of export, restored by the Foreign Exchange Management (Export of Goods and Services) (First Amendment) Regulations, 2026, Notification No. FEMA 23(R)/(8)/2026-RB dated June 5, 2026.
From October 1, 2026: a fresh code, the Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026 (Notification No. FEMA 23(R)/2026-RB dated January 13, 2026) takes over with a 15-month window (18 months where the export is invoiced or settled in Indian Rupees).
Who is affected: every exporter of goods and services, including SEZ, EOU, EHTP, STP and BTP units and Status Holder exporters, plus the AD banks and CAs who certify their realisation.
Action: the deadline that applies depends on the date of export of each shipment. Map every open shipment to the correct window before you certify realisation or apply for an extension.

Why the Export Realisation Period Changed Three Times in Eight Months

For a busy exporter, few FEMA numbers matter more than the realisation window, the outer time limit within which you must bring in and repatriate the full value of an export. Miss it without an approved extension and you are in contravention of FEMA, exposed to compounding and to your bank flagging the entry in the EDPMS system. Over the last eight months the number has moved more than it had in years, and getting it wrong on a single large invoice is expensive.

Here is the sequence, and why each step happened.

The base rule was 9 months. Under the Foreign Exchange Management (Export of Goods and Services) Regulations, 2015, Regulation 9 fixed realisation at nine months from the date of export.
November 2025: raised to 15 months. To relieve exporters facing global demand and shipping stress, RBI notified the (Second Amendment) Regulations, 2025, Notification No. FEMA 23(R)/(7)/2025-RB dated November 13, 2025, extending realisation to 15 months. The same relief package also stretched the advance-payment shipment window and covered SEZ, EOU and Status Holder exporters.
June 2025 amendment reverses it to 9 months. Through the (First Amendment) Regulations, 2026, Notification No. FEMA 23(R)/(8)/2026-RB dated June 5, 2026, RBI substituted the words “fifteen months” with “nine months” in Regulation 9(1) and clause (a) of Regulation 9(2), restoring the 9-month window.
October 1, 2026: a brand-new code with 15 months. The consolidated Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026 (FEMA 23(R)/2026-RB dated January 13, 2026) comes into force and again sets 15 months (18 for rupee-invoiced exports), this time as part of a full rewrite of the export-import framework.

The net effect is a short 9-month trough between June and September 2026, sitting between two 15-month regimes.

Which Deadline Applies to My Shipment? A Date-of-Export Map

The single most important point: the applicable window is fixed by when the export took place, not by today’s date. Use this map for each open shipment.

Date of export	Realisation window	Governing instrument
On or after October 1, 2026	15 months (18 months if invoiced or settled in INR)	FEMA (Export and Import of Goods and Services) Regulations, 2026 (FEMA 23(R)/2026-RB)
June 5, 2026 to September 30, 2026	9 months	First Amendment Regulations, 2026 (FEMA 23(R)/(8)/2026-RB)
Roughly November 14, 2025 to June 4, 2026	15 months	Second Amendment Regulations, 2025 (FEMA 23(R)/(7)/2025-RB)
Before the November 2025 extension	9 months	Regulation 9, 2015 Regulations

Because the exact cut-over dates carry compliance consequences, confirm each date band against the RBI notifications before you rely on it for a specific invoice, especially shipments near the June 4 to June 5, 2026 boundary and the September 30 to October 1, 2026 boundary.

What the October 1, 2026 Regulations Change Beyond the Number

The new 2026 code is not only about restoring 15 months. It is a consolidation of the export-import rules with several practical easements that exporters and importers should build into their processes now:

Realisation linked to date of sale for warehouse exports. For goods sent to an overseas warehouse, the clock is intended to run from the date of sale rather than the date of shipment, giving genuine warehousing models more room.
Simplified closure for small entries. For transactions up to Rs 10 lakh, monitoring-system entries may be closed on the exporter or importer declaration rather than full documentation.
Bulk quarterly closure. Exporters and importers can submit closure declarations on a quarterly, consolidated basis for multiple transactions.
AD bank autonomy. Authorised Dealer banks get clearer authority to grant extensions and to permit set-off and reduction in export value based on the bona fide nature of the underlying transaction, backed by documented internal standard operating procedures.

These are meaningful for cash-flow and compliance workload, but they take effect only from October 1, 2026. Until then, the 2015 Regulations, as currently amended to 9 months, remain the operative code.

Practical Implications for Exporters, MSMEs and Their Advisers

For MSME and mid-market exporters: the 9-month trough is the immediate risk. If you shipped in June to September 2026 and your buyer is on longer credit terms, you may hit the realisation limit sooner than you expected under the earlier 15-month rule. Review your receivables ageing against a 9-month FEMA clock, not a 15-month one.

For exporters with large or long-cycle contracts: if realisation will genuinely run past 9 months for a June to September 2026 shipment, engage your AD bank early for an extension rather than letting the entry go overdue in EDPMS. AD banks can grant extensions on a bona fide basis.

For CAs and finance teams: update your FEMA compliance tracker so that each shipment is tagged to the correct window by date of export. A single blanket assumption of 9 months or 15 months across all open shipments will misstate some deadlines. Reconcile EDPMS entries and flag anything approaching its limit.

Compliance Checklist Before You Certify Realisation

List every open export. Extract all shipments with unrealised proceeds and record the date of export for each.
Assign the correct window. Apply 9 or 15 months using the date-of-export map above, and note the currency of invoicing (INR shipments get the longer window under the October 2026 code).
Reconcile with EDPMS. Match your list to the bank and EDPMS records so overdue entries surface before they become contraventions.
File for extensions early. Where realisation will legitimately exceed the applicable window, apply to the AD bank with supporting documents well ahead of the deadline.
Prepare for October 1, 2026. Brief your team on the new closure thresholds, quarterly bulk closure and warehouse date-of-sale rule so you are ready when the 2026 Regulations go live.
Keep the evidence trail. Retain shipping documents, invoices, buyer correspondence and bank realisation certificates so that any set-off, reduction or extension is defensible.

Frequently Asked Questions

What is the export realisation period in India right now, in July 2026?

For exports made on or after June 5, 2026, the realisation and repatriation period is 9 months from the date of export, restored by the First Amendment Regulations, 2026 (FEMA 23(R)/(8)/2026-RB dated June 5, 2026). It moves back to 15 months for exports made on or after October 1, 2026.

Why did RBI cut the window back to 9 months so soon after raising it to 15?

The 15-month period from November 2025 was an interim relief under the 2015 Regulations. The June 2026 amendment realigns the 2015 framework to 9 months for the short period before the new consolidated 2026 Regulations take over on October 1, 2026, which themselves restore 15 months as part of a full rewrite. It is best read as a clean handover between two regimes.

Does the 15-month rule from October 2026 apply to my earlier shipments?

No. The applicable window is fixed by the date of export of each shipment, not by the date you happen to check. A shipment exported in July 2026 is governed by the 9-month window even though the 15-month code exists from October 2026.

What happens if I cannot realise proceeds within the applicable window?

You should apply to your Authorised Dealer bank for an extension before the deadline. AD banks are authorised to grant extensions on a bona fide basis. Letting an entry go overdue without an approved extension is a FEMA contravention and can attract compounding.

Is the 18-month period only for rupee exports?

Under the October 1, 2026 Regulations, the longer 18-month realisation window applies where the export is invoiced or settled in Indian Rupees; other exports get 15 months. Confirm the exact wording against the 2026 Regulations for your specific transaction.

The Bottom Line

The export realisation deadline is not a single number in 2026, it is a moving target keyed to the date of export. Today the operative window is 9 months; from October 1, 2026 it becomes 15 months (18 for INR) under a new, more flexible code. Treat every open shipment individually, tag it to the correct regime, and lean on your AD bank early for extensions. That is how you avoid an avoidable FEMA contravention on money that is simply late, not lost.

Sources referenced: FEMA (Export and Import of Goods and Services) Regulations, 2026, Notification No. FEMA 23(R)/2026-RB dated January 13, 2026, effective October 1, 2026 (rbi.org.in); FEMA (Export of Goods and Services) (First Amendment) Regulations, 2026, Notification No. FEMA 23(R)/(8)/2026-RB dated June 5, 2026; FEMA (Export of Goods and Services) (Second Amendment) Regulations, 2025, Notification No. FEMA 23(R)/(7)/2025-RB dated November 13, 2025. Verify exact effective-window dates against the RBI notifications before relying on them for a specific shipment.

Talk to an Expert on Your FEMA and Cross-Border Compliance

If you export goods or services and need to be sure which realisation window applies to your open shipments, or you are planning for the October 1, 2026 changeover, get a second set of eyes on it. Book a quick call with Tax Update India to review your EDPMS position and extension strategy before a late realisation becomes a contravention.

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