RBI cuts export realisation period to nine months from 1 October 2026

What has changed

On 22 September 2026 the Reserve Bank of India issued Notification No. FEMA 23(R)/(1)/2026-RB, amending the Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026. The principal regulations were notified on 13 January 2026 (Notification No. FEMA 23(R)/2026-RB) and come into force on 1 October 2026, the same date as the amendment. From that date they supersede the Foreign Exchange Management (Export of Goods & Services) Regulations, 2015, except for things done or omitted before the supersession.

The amendment makes three changes:

• Shorter realisation period (Regulation 5(1)). The period for realising and repatriating the full export value is cut from fifteen months to nine months, counted from the date of shipment for goods, from the date of invoice for services, and from the date of sale for goods exported to a warehouse outside India.
• Rupee-invoiced exports. Where exports are invoiced and/or settled in Indian Rupees, the period is cut from eighteen months to twelve months.
• Transition provisions. A proviso to Regulation 13 says exporters on the RBI’s Caution List as on 30 September 2026, under orders issued under Regulation 16 of the 2015 Regulations, stay governed by those orders until they are removed from the list. A new Regulation 20 lets Authorised Dealer (AD) banks handle transactions undertaken before 1 October 2026 that earlier needed RBI approval.

The amendment was published in the Official Gazette on 24 September 2026.

Why it matters

The January 2026 regulations had allowed fifteen months (eighteen for rupee trade). With this amendment, the new framework starts on 1 October 2026 with the shorter nine-month period instead. Any business planning collections on the longer period set out in January will need to adjust.

The new regulations also consolidate rules that used to sit in several places. Their headings cover the declaration of exports, reduction in export value, set-off of export receivables against import payables, third-party receipts and payments, time limits for import payments, merchanting trade transactions, trade invoiced and settled in rupees, reporting, and an internal policy and standard operating procedure for AD banks.

Under Regulation 13, if export proceeds remain unrealised for more than one year beyond the due date (or any extension an AD bank has allowed), the exporter may make further exports only against full advance payment or an irrevocable letter of credit. The shorter realisation period brings that due date forward.

Who is affected

• Exporters of goods and services, including software and IT-enabled services companies that invoice overseas clients
• Businesses exporting through overseas warehouses or invoicing in Indian Rupees
• Merchanting traders and companies that set off export receivables against import payables
• AD banks, which will apply the new regulations and their own internal policies from 1 October 2026
• Payment aggregators handling cross-border export collections, which depend on how quickly exporters realise proceeds

What businesses should do now

1. Review open receivables. List export invoices and shipping bills that will be outstanding on or after 1 October 2026, and check which realisation period applies to each with your AD bank.
2. Revisit credit terms. Contracts that give overseas buyers long credit periods may need to change so that proceeds can be realised within nine months (twelve for rupee trade).
3. Use the extension route early. The regulations let an AD bank extend the period when an exporter asks and gives reasons for the delay. Apply before the deadline, with supporting documents.
4. Check Caution List exposure. Exporters on the Caution List should confirm their status with their bank, as existing orders continue to apply.
5. Update internal controls. Finance teams should align receivable follow-up, set-off and reduction procedures with the new regulation numbers and time limits. A FEMA compliance review can help identify gaps.

Businesses that find past delays or reporting lapses may consider regularisation. FEMA compounding is one route for contraventions that can be compounded. Exporters that collect through payment aggregators should also check their collection flows against the cross-border payment aggregator framework.

Expertvuw’s team can help you assess how the new export-import regulations affect your receivables and internal processes. Any professional certification or representation required is handled by independent licensed professionals.

Sources

• RBI – 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
• RBI – 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 – Notification No. FEMA 23(R)/2015-RB dated 12 January 2016, Foreign Exchange Management (Export of Goods & Services) Regulations, 2015 (superseded from 1 October 2026)