Exporters get nine months to bring export proceeds home from 1 October 2026: RBI amends the new FEMA export-import regulations, notified with fifteen, before they take effect
RBI has amended regulation 5(1) of the Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026 before they took effect. The period to realise and repatriate export value is nine months instead of fifteen, and twelve months instead of eighteen where the export is invoiced or settled in rupees. The amendment is in force from 1 October 2026.
Key facts
- In force
- 1 October 2026
- Who it affects
- Exporters of goods and services (including software), merchanting traders, importers with pre-October cases, Authorised Dealer banks
- What it is
- Rule change
- Section
- FEMA & RBI
- Published
- 25 September 2026
In 30 seconds
- Notification No. FEMA 23(R)/(1)/2026-RB is dated 22 September 2026 and was published in the Official Gazette on 24 September 2026.
- Regulation 5(1) fixes the period within which an exporter must realise and repatriate the full export value of goods and services.
- For goods, the nine months run from the date of shipment; for services, from the date of invoice; for goods sent to a warehouse outside India, from the date of sale from the warehouse.
- Where the export is invoiced or/and settled in Indian Rupees, the period is twelve months (the regulations as notified in January said eighteen).
- Project exports are unchanged: realisation as per the payment terms of the contract.
- Exporters on the Caution List as on 30 September 2026 remain governed by the RBI orders that put them there until they are removed from the list.
- New regulation 20: Authorised Dealers will handle pre-1 October 2026 export, import and merchanting trade transactions that earlier needed RBI approval.
हिंदी में सार
RBI ने FEMA के नए Export and Import of Goods and Services Regulations, 2026 के regulation 5(1) में बदलाव किया है: निर्यात की रकम भारत लाने की समय-सीमा अब पंद्रह की जगह नौ महीने है, और रुपये में इनवॉइस या सेटलमेंट वाले निर्यात के लिए अठारह की जगह बारह महीने। यह 1 अक्टूबर 2026 से लागू है। 30 सितंबर 2026 को Caution List में मौजूद निर्यातकों पर पुराने आदेश ही लागू रहेंगे, और 1 अक्टूबर से पहले के जिन मामलों में RBI की मंज़ूरी लगती थी, उन्हें अब Authorised Dealer बैंक देखेंगे।
Before and now
Fifteen months; eighteen months where the export is invoiced or settled in Indian Rupees — as the regulations were notified on 13 January 2026.
Nine months; twelve months where the export is invoiced or settled in Indian Rupees — in force from 1 October 2026.
What has changed
The Reserve Bank of India notified the Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026 on 13 January 2026 (Notification No. FEMA 23(R)/2026-RB). Those regulations supersede the Foreign Exchange Management (Export of Goods & Services) Regulations, 2015 and come into force from 1 October 2026.
By Notification No. FEMA 23(R)/(1)/2026-RB dated 22 September 2026, RBI has amended them. The amendment also comes into force from 1 October 2026 — the same day as the principal regulations. It makes three changes.
1. Shorter time to realise export proceeds
Regulation 5(1) says the amount representing the full export value of goods and services (or the reduced value allowed under regulation 6) must be realised and repatriated by the exporter within a specified period. Realisation includes set-off under regulation 7. The amendment replaces the words “fifteen months” with “nine months” in clauses (a) and (b), and “eighteen months” with “twelve months” in the first proviso.
| Type of export | Period runs from | As notified in January 2026 | From 1 October 2026 |
|---|---|---|---|
| Goods (other than goods exported to a warehouse outside India) | Date of shipment | Fifteen months | Nine months |
| Services | Date of invoice | Fifteen months | Nine months |
| Goods exported to a warehouse outside India | Date of sale of the goods from the warehouse | Fifteen months | Nine months |
| Exports invoiced or/and settled in Indian Rupees | Shipment, invoice or sale from the warehouse, as above | Eighteen months | Twelve months |
| Project exports | As per the payment terms of the contract — not amended | ||
The second proviso to regulation 5(1) is not touched: an Authorised Dealer may, on a request from the exporter citing reasons for the delay, allow more time beyond the specified period if it is satisfied with the reasons. Under regulation 5(2), Authorised Dealers must have systems to monitor and follow up with exporters.
2. Caution-listed exporters
Regulation 13 provides that if export proceeds remain unrealised beyond one year from the due date of realisation (or the extended period allowed by an Authorised Dealer), the exporter can make further exports only against full advance or an irrevocable Letter of Credit.
A proviso is now added. Exporters who are in 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 Caution List.
3. Old cases move to banks
A new regulation 20 gives Authorised Dealers the power to handle transactions relating to export and import of goods and services, and merchanting trade, undertaken before 1 October 2026 which until now required RBI approval under the 2015 regulations and the Master Directions on Export and on Import of Goods and Services.
What exporters should do
- Work to the nine-month (or twelve-month, for rupee-invoiced or rupee-settled exports) period under the new regulations, counted from shipment, invoice or sale from the overseas warehouse as the case may be.
- If realisation will be delayed, apply to your Authorised Dealer bank for an extension, citing the reasons.
- If you are on the Caution List as on 30 September 2026, the RBI order that placed you there continues to apply.
- For a pre-1 October 2026 transaction that earlier needed RBI approval, approach your Authorised Dealer.
Questions and answers
What is the time limit to realise export proceeds under the new FEMA regulations?
Under regulation 5(1) of the Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026, as amended, it is nine months — from the date of shipment for goods, from the date of invoice for services, and from the date of sale from the warehouse for goods exported to a warehouse outside India.
Is the period different for exports invoiced in rupees?
Yes. Where the export of goods and services is invoiced or/and settled in Indian Rupees, the period for realisation and repatriation is twelve months. The regulations as notified in January 2026 said eighteen months.
Can the nine-month period be extended?
Yes. The second proviso to regulation 5(1) lets the Authorised Dealer, on a request from the exporter citing reasons for the delay, allow extension of time beyond the specified period if it is satisfied with the reasons.
What happens to exporters already on the RBI Caution List?
Exporters in the Caution List as on 30 September 2026, under orders issued under regulation 16 of the 2015 regulations, continue to be governed by those orders until they are removed from the list.
Who will now deal with old cases that needed RBI approval?
New regulation 20 says Authorised Dealers shall handle export, import and merchanting trade transactions undertaken before 1 October 2026 which earlier required RBI approval under the 2015 regulations and the Master Directions on export and import.
Published 25 September 2026. Updated 6 October 2026. This report is for general information and is not professional advice. Read the source document before acting on it.