VKVikash Khanal

Export realisation is nine months again

The FEMA Export and Import Regulations 2026 took effect on 1 October with a last-minute change. Here is what moved, and what to fix in your trackers this week.

Published 2 October 2026

The short version

  • A single set of regulations now governs both exports and imports, replacing the 2015 export regulations, both Master Directions and a long list of circulars.
  • Export proceeds must be realised within nine months: from shipment for goods, from invoice for services, from the date of sale for goods sent to an overseas warehouse.
  • Exports invoiced or settled in rupees get twelve months.
  • Import payments follow the contract. The fixed six-month window is gone for new transactions.
  • EDPMS and IDPMS entries up to ₹10 lakh can be closed on your own declaration.

Why fifteen became nine

In November 2025 the RBI stretched the export realisation period from nine months to fifteen to ease pressure on exporters. The consolidated 2026 Regulations, notified on 13 January 2026, kept fifteen months and offered eighteen for rupee-invoiced exports.

The policy then reversed. A June 2026 amendment to the old 2015 regulations brought the period back to nine months from 5 June, and on 22 September 2026, nine days before the new regime started, the RBI amended the 2026 Regulations too: fifteen became nine and eighteen became twelve. Several summaries written between January and September still quote the longer periods, so check which text you are reading.

Imports: the contract is now the clock

For imports from 1 October, the AD bank follows up on each IDPMS entry against the payment period in the underlying contract and can extend it on a reasoned request. That makes the contract terms a compliance document. If your purchase orders say "payment on receipt of goods" or leave terms blank, fix the template now; the bank will read whatever is there.

What else changed

  • Set-off. Export receivables can be set off against import payables with the same overseas party or its group companies, within the realisation period.
  • Third-party payments. Now recognised in the regulations, subject to the AD bank being satisfied the transaction is genuine. Keep the paper trail linking the payer to the invoice.
  • Services. Service and software exporters declare on an Export Declaration Form within 30 days from the end of the month of the invoice, replacing the SOFTEX route for software.
  • Overdue exports. If proceeds stay unrealised a year past the due date, further exports need full advance payment or an irrevocable LC.
  • Old cases. A new Regulation 20 lets AD banks handle older export, import and merchanting cases that used to need RBI approval.

What to do this week

  1. Split open EDPMS and IDPMS entries into pre- and post-1 October lots. They age under different rules.
  2. Reset any tracker or ERP field that still says 15 months for new exports.
  3. Check purchase-order and import contract templates for a stated payment period.
  4. List entries under ₹10 lakh and close them in one quarterly declaration.
  5. Ask your AD bank for its new FEMA policy or checklist. Banks now run their own SOPs, and practice will differ between them.

The FEMA due-date calculator applies these rules by transaction date, and its batch tracker ages a whole list of shipping bills and bills of entry at once.

Sources

FEMA 23(R)/2026-RB dated 13 January 2026; FEMA 23(R)/(1)/2026-RB dated 22 September 2026 (Gazette, 24 September 2026); FEMA 23(R)/(8)/2026-RB dated 5 June 2026; FEMA 23(R)/(7)/2025-RB dated 13 November 2025. Read the notifications on rbi.org.in before relying on this summary.