FEMA Export Realisation Period From October 1, 2026: Nine Months Stays, the Clock Moves to Invoice and Sale Dates (RBI Amendment of 22 September 2026)

Quick Summary

From 1 October 2026, export realisation is governed by the Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026 (Notification No. FEMA 23(R)/2026-RB dated 13 January 2026). They supersede the FEM (Export of Goods & Services) Regulations, 2015.
RBI’s amendment of 22 September 2026 (Notification No. FEMA 23(R)/(1)/2026-RB, published in the Gazette on 24 September 2026) replaces “fifteen months” with “nine months” and “eighteen months” with “twelve months” in regulation 5(1), before the Regulations commence.
The FEMA export realisation period from 1 October 2026 is nine months from the date of shipment for goods and from the date of invoice for services. For goods sent to a warehouse outside India, it is nine months from the date of sale from the warehouse.
Where an export is invoiced and/or settled in Indian Rupees, the period is twelve months. Project exports follow the payment terms of the contract.
Your Authorised Dealer (AD) bank may extend the period on the exporter’s request if satisfied with the reasons. Exports unrealised for more than one year beyond the due date restrict further exports to full advance or an irrevocable letter of credit.

Exporters and their CAs have had two different numbers for the FEMA export realisation period from 1 October 2026. The new principal Regulations notified in January 2026 said fifteen months (eighteen for rupee-invoiced exports). On 22 September 2026 the Reserve Bank of India amended them before they came into force: the period is nine months, and twelve months for exports invoiced or settled in rupees. What does change on 1 October is the starting point of the clock for services and for warehouse exports, plus several procedures that move to the AD bank. This note sets out the rule as it reads from 1 October 2026.

What did RBI’s 22 September 2026 amendment change?

The Foreign Exchange Management (Export and Import of Goods and Services) (Amendment) Regulations, 2026 come into force from 1 October 2026, the same day as the principal Regulations. They make four changes:

Regulation 5(1)(a) and (b): “fifteen months” is replaced by “nine months”.
First proviso to regulation 5(1): “eighteen months” is replaced by “twelve months” for exports invoiced and/or settled in Indian Rupees.
Proviso to regulation 13: exporters on the Caution List as on 30 September 2026, under orders issued by RBI under regulation 16 of the 2015 Regulations, continue to be governed by that order until removed from the list.
New regulation 20: AD banks handle transactions for export and import of goods and services, and merchanting trade, undertaken before 1 October 2026 that needed RBI approval under the 2015 Regulations and the Master Directions on Export and on Import of Goods and Services.

The fifteen-month figure in the January text, which our 3 July explainer on the new export Regulations described, therefore never takes effect.

What is the export realisation period from 1 October 2026?

Regulation 5(1), as amended, requires the full export value (or the reduced value allowed under regulation 6) to be realised and repatriated, including by set-off under regulation 7, within:

Type of export	Period	Clock starts from
Goods (other than goods exported to a warehouse outside India)	Nine months	Date of shipment
Services (including software)	Nine months	Date of invoice
Goods exported to a warehouse outside India	Nine months	Date of sale of the goods from the warehouse
Project exports	As per the payment terms of the contract	As per the contract
Any of the above invoiced and/or settled in Indian Rupees	Twelve months	Date of shipment (goods), date of invoice (services), date of sale (warehouse goods)

The second proviso to regulation 5(1) lets the AD bank, on the exporter’s request citing reasons for the delay, allow an extension beyond the specified period if it is satisfied with the reasons.

How is this different from the rule until 30 September 2026?

Until 30 September 2026, the Master Direction on Export of Goods and Services (updated as on 17 July 2026) sets the period at nine months “from the date of export”, and fifteen months from the date of shipment for goods exported to a warehouse established outside India.

Export	Up to 30 September 2026 (Master Direction)	From 1 October 2026 (2026 Regulations, as amended)
Goods	Nine months from the date of export	Nine months from the date of shipment
Services	Nine months from the date of export	Nine months from the date of invoice
Goods to a warehouse outside India	Fifteen months from the date of shipment	Nine months from the date of sale from the warehouse

For a warehouse exporter the change is structural: the clock no longer runs from shipment, but it is nine months from each sale rather than fifteen. For a services exporter, the invoice date now fixes the deadline, so invoicing practice (monthly billing, milestone invoices) directly sets the realisation calendar.

The 2026 Regulations supersede the 2015 Regulations “except in respect of things done or omitted to be done before such supersession”. They contain no separate transition rule for a warehouse shipment made before 1 October 2026; confirm the applicable date for such open entries with your AD bank.

What other rules in the 2026 Regulations should exporters know?

Export declaration for services (regulation 3(2)): the EDF must be furnished to the specified authority within 30 days from the end of the month in which the invoice is raised. One EDF may cover all exports to one or more recipients in a month; exporters of services other than software may submit it on or before the date of receipt of payment; the AD bank may extend the time on a reasoned request.
EDPMS closure for small invoices (regulation 4(2)): where the shipping bill or invoice is up to Rs 10 lakh (or its foreign-currency equivalent), the EDPMS entry may be closed on the exporter’s declaration that payment has been realised, in full or otherwise; the declaration may also be given quarterly for bulk closure.
Reduction in export value (regulation 6): the AD bank may allow reduction on a reasoned request; up to Rs 10 lakh per shipping bill or invoice, it may be permitted on the exporter’s declaration.
Set-off (regulation 7): export receivables may be set off against import payables with the same overseas buyer or supplier, or their overseas group or associate companies, within the realisation period.
Third-party receipts (regulation 8): the AD bank may permit them if satisfied with the bona fides.
Unrealised exports (regulation 13): if proceeds remain unrealised for more than one year beyond the due date (or the extended period), further exports may be made only against full advance or an irrevocable letter of credit.
AD bank policy (regulation 19): each AD bank must have an internal policy and SOP covering at least documents, timelines and charges, extensions of the realisation period, adjustment for under-, over- and non-realisation, advances, delegation of approvals and factoring, disclose its main features on its website, and must not levy charges or penalty on an exporter for a regulatory delay or violation by the exporter.

What should exporters and their CAs do before 1 October 2026?

Re-map open receivables using the table above: services by invoice date, goods by shipment date, warehouse goods by date of sale.
Update receivable ageing reports for rupee-invoiced exports to the twelve-month period.
Keep EDF timelines for services in the monthly close: 30 days from the end of the invoice month.
Read your AD bank’s published policy under regulation 19 for its extension and adjustment process, since the extension under regulation 5(1) is granted by the bank.
Check Caution List status if any past RBI order under regulation 16 of the 2015 Regulations applies; it continues until removal.

Exporters settling in rupees through vostro accounts may also find our note on RBI’s consolidated rulebook for Special Rupee Vostro Accounts useful.

Sources

Source: Reserve Bank of India, Notification No. FEMA 23(R)/(1)/2026-RB dated 22 September 2026, Foreign Exchange Management (Export and Import of Goods and Services) (Amendment) Regulations, 2026, published in the Gazette of India, Extraordinary, Part III, Section 4 on 24 September 2026, rbi.org.in.
Source: Reserve Bank of India, Notification No. FEMA 23(R)/2026-RB dated 13 January 2026, Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026 (amended up to 22 September 2026), rbi.org.in.
Source: Reserve Bank of India, Master Direction: Export of Goods and Services, FED Master Direction No. 16/2015-16 (updated as on 17 July 2026), rbi.org.in.

Unsure how the new clock applies to your receivables?

If you have warehouse exports, milestone-billed services or rupee-invoiced contracts in progress, get expert guidance from Tax Update India. Schedule a quick call to walk through your open EDPMS entries.

Disclaimer: This article is for general information only and reflects the RBI instruments cited above as on 29 September 2026. It is not legal advice. Please consult a qualified professional before acting on it.

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CA Adityavikram Banka

Founder & Director at A S Banka Advisors Private Limited

The author is Founder of A. S. Banka Advisors Private Limited & Partner at Dhiraj & Dheeraj.

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