In force from 1 October 2026
The 2026 regulations commenced on 1 October 2026 as amended by FEMA 23(R)/(1)/2026-RB of 22 September 2026, which cut the realisation period from fifteen months to nine, and from eighteen to twelve where the export is invoiced in rupees.
On 13 January 2026 the Reserve Bank notified the Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026, one consolidated set of rules for the export and import of goods, software and services. They come into force on 1 October 2026 and supersede the 2015 export regulations, the separate Master Directions on export and on import, the 2014 instructions on project and service exports, the 2020 merchanting trade guidelines, and the 167 circulars listed in the annexure to the new directions.
What changed, and when it bites
Most coverage of the new regulations reads them as a simplification exercise, and in structure they are: one regulation replaces several. The change that will actually catch a business is not in the new regulations as first notified. It sits in the amendments made while the new regulations were waiting to commence: two to the old regulations, and one of 22 September 2026 to the new ones before they began. Between them they have moved the realisation deadline three times without most exporters noticing.
The realisation deadline three cohorts are on, not one
The standard period to realise and repatriate export proceeds has not held still. It was nine months for years under the 2015 regulations. On 13 November 2025 the Reserve Bank extended it to fifteen months. On 5 June 2026 it reversed that, restoring nine months. The new regulations, as notified in January, set fifteen months, eighteen where the invoice is settled in rupees. On 22 September 2026, before they commenced, the Reserve Bank amended Regulation 5(1) to nine months and twelve months. Three shipment dates therefore carry three different deadlines.
| Goods shipped or services invoiced | Realisation deadline | Governing instrument |
|---|
| 13 November 2025 to 4 June 2026 | 15 months | 2015 regulations, as extended by the Second Amendment of 13 November 2025 |
| 5 June 2026 to 30 September 2026 | 9 months | 2015 regulations, as restored by the First Amendment of 5 June 2026 |
| 1 October 2026 onward | 9 months (12 if invoiced in rupees) | the 2026 regulations, as amended on 22 September 2026 |
An exporter who shipped in July or August 2026 assuming the familiar fifteen month window still applies has misjudged the deadline by six months. That cohort's proceeds fall due as early as April 2027, ahead of shipments made in the months before it. Anyone who planned on fifteen months returning from 1 October should re-plan: it does not, except that exports invoiced in rupees get twelve.
The new filing services exporters have never had
The Export Declaration Form continues for goods, filed at the time of export and deemed part of the shipping bill at ports on Electronic Data Interchange. Exporters of services, including software exporters who currently file SOFTEX, must from 1 October file the Export Declaration Form within 30 days of the end of the month in which the invoice is raised. For a services business that has never filed a declaration of this kind, this is a new monthly obligation, not a renamed old one.
The regulations drop the Reserve Bank's formal caution listing process. In its place, an exporter whose receivables remain unrealised more than a year past the due date, including any extension the bank has granted, may make further exports only against full advance payment or a confirmed irrevocable letter of credit. Nothing is reviewed and nothing is discretionary. The restriction follows automatically from the date already on the ledger. An exporter already on the caution list on 30 September 2026 stays under that order until the Reserve Bank removes it, under a proviso to Regulation 13 inserted by the September amendment.
Importers lose the fixed payment window
Import payments no longer follow a fixed period measured from shipment. The regulations tie the payment date to what the underlying contract itself specifies, with the authorised dealer able to extend it on request. A business whose import contracts are silent on payment timing, or were drafted around the earlier fixed period, should have that clause reviewed before the first import cleared after 1 October.
A ten lakh rupee limit on self certified closure
An authorised dealer may close or reduce an export value entry worth up to Rs 10 lakh per shipping bill or invoice on the exporter's own declaration, without a fresh application to the Reserve Bank. Above that figure the earlier route, supported by evidence rather than a declaration, continues to apply.
What to do first
- Pull every shipping bill and services invoice dated 5 June 2026 or later and calendar its deadline individually: nine months, whether shipped before or after 1 October, and twelve months from 1 October where the invoice is in rupees. Do not apply one date to the whole book.
- If services or software are exported, decide now who will file the Export Declaration Form each month from October, and set a recurring reminder for the 30 day window.
- Review live import contracts for a payment clause. Where none exists, agree one with the supplier before the first shipment clears after 1 October.
- Check the receivables ledger for anything unrealised beyond a year. That account now falls under the advance or letter of credit restriction without any further notice from the bank.
