Last reviewed: 22 October 2026. If you read an article this month saying exporters now get 15 months to bring money home, check its date. The January 2026 text did say that, but RBI amended it on 22 September 2026, nine days before it came into force, and the number that actually applies from 1 October 2026 is nine months. This note sets out what the notified text says, how the clock runs for goods, services and rupee-invoiced exports, and what a finance team should change in its follow-up routine.
Which notifications matter
The framework is the Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026, Notification No. FEMA 23(R)/2026-RB dated 13 January 2026. Regulation 1(2) brings it into force on 1 October 2026 and it supersedes the 2015 export regulations and the related Master Directions for transactions from that date. The amendment is Notification No. FEMA 23(R)/(1)/2026-RB dated 22 September 2026, published in the Gazette of India (Extraordinary) on 24 September 2026. We have read the consolidated text on the RBI website, which shows the amendment footnoted into the principal regulations.
The amendment did four things: it replaced "fifteen months" with "nine months" in Regulation 5(1)(a) and (b); it replaced "eighteen months" with "twelve months" in the first proviso; it added a proviso to Regulation 13 for exporters already on the Caution List on 30 September 2026; and it inserted Regulation 20, which lets ADs deal with pre-1 October export, import and merchanting transactions that earlier needed RBI approval.
The realisation clock, case by case
| Type of export | Period | Clock starts | Provision |
|---|---|---|---|
| Goods (not sent to an overseas warehouse) | 9 months | Date of shipment | Reg 5(1)(a) |
| Services, including software | 9 months | Date of invoice | Reg 5(1)(a) |
| Goods sent to a warehouse outside India | 9 months | Date of sale from the warehouse | Reg 5(1)(b) |
| Project exports | As per contract payment terms | Per contract | Reg 5(1)(c) |
| Invoiced and/or settled in INR | 12 months | As above | First proviso, Reg 5(1) |
Two points are easy to miss. First, for services the clock now runs from the invoice date, so a milestone invoice raised in advance of delivery starts the nine months early. Second, for warehouse exports the earlier Master Direction framework, as reported, allowed fifteen months from shipment; the new clause runs nine months from the date of sale out of the warehouse, so stock that sits unsold is not on the realisation clock until it is sold, but the sale date then starts a short one.
Worked examples
Example 1: goods, USD invoice. A Thane engineering exporter ships on 10 November 2026 against a USD invoice. Proceeds are due by 10 August 2027. If the buyer disputes quality and the money is still outstanding in July 2027, the exporter should write to the AD bank with the buyer correspondence and ask for an extension before 10 August, not after. If nothing is realised and no extension is on record, one year past the due date is 10 August 2028; beyond that, Regulation 13 limits fresh exports to full advance or an irrevocable LC.
Example 2: software services. An IT services company invoices a US client on 18 October 2026. Realisation is due by 18 July 2027. The EDF for the month is due within 30 days after the end of October, that is by 30 November 2026, and one EDF can cover all of October's service invoices to different clients. Many small teams miss this because there is no shipping bill to trigger the filing.
Example 3: rupee-invoiced export. A trader ships on 5 December 2026 and invoices the foreign buyer in Indian rupees, settled through a vostro account. The twelve-month proviso applies, so the due date is 5 December 2027. The extra three months apply only when the invoice and settlement are in rupees as the proviso describes; a USD invoice settled in rupees should be confirmed with the bank rather than assumed.
Example 4: value reduction. A buyer deducts a quality claim on an invoice worth ₹7 lakh. Under Regulation 6, an AD may allow a reduced export value where under-realisation is justified, and where the shipping bill or invoice is up to ₹10 lakh the reduction may be permitted on the exporter's declaration. Above ₹10 lakh, expect the bank to ask for documents such as the claim letter, inspection report and credit note.
Other provisions an exporter will use
| Topic | What the Regulations say | Reg |
|---|---|---|
| Export Declaration Form (goods) | EDF showing full export value at export; at EDI ports it is deemed submitted as part of the shipping bill | 3(1) |
| EDF (services) | Within 30 days after the end of the invoice month; one EDF can cover a month's exports to several recipients; AD may extend on a reasoned request | 3(2) |
| EDPMS closure, small value | Up to ₹10 lakh per shipping bill or invoice, entries can be closed on exporter declaration, per transaction or quarterly in bulk | 4(2) |
| Set-off | AD may allow export receivables to be set off against import payables with the same overseas party, or its group or associate companies, within the realisation period or an extension | 7 |
| Third-party payments | AD may permit third-party receipts and payments if satisfied of bona fides | 8 |
| Long-outstanding dues | More than a year past due: further exports only against full advance or irrevocable LC | 13 |
What changes in practice for a finance team
- Re-set the ageing report. Most export ageing sheets were built around a nine-month, twelve-month or fifteen-month assumption from whichever article the team last read. Rebuild it with the due date in a column, computed by type of export, so that overdue items stand out at month-end.
- Move the service-export trigger to the invoice date. Set a reminder at month-end to file the consolidated EDF within 30 days, and a second reminder at month six of the realisation period to start the extension conversation.
- Keep an extension file ready. The bank decides on satisfactory reasons, so keep buyer emails, dispute notes, purchase order amendments and proof of follow-up in one folder per invoice.
- Know your bank's policy. The Regulations require ADs to frame their own policy and procedures, so documents, charges and turnaround time can differ between banks. Ask your relationship manager for the written policy.
- Watch the Caution List. Exporters already on it on 30 September 2026 remain under the earlier order until removed. Check status if you ever had a long-pending bill.
- Align the tax side. Realisation timing connects to GST zero-rating conditions and export incentive claims. Review those on the dedicated pages, GST on export of services and export incentive schemes, and confirm the interaction for your own facts.
Checklist before 31 December 2026
- List every export invoice raised since 1 October 2026 with its due date under Regulation 5(1).
- Separate rupee-invoiced exports and confirm the bank treats them under the twelve-month proviso.
- Confirm service-export EDFs for October and November are filed or scheduled.
- Flag open pre-October invoices and ask the bank which period it is tracking.
- Check that EDPMS entries for small-value shipments are closed, using the declaration route where it applies.
- Review buyers with balances older than six months and write for extensions where a dispute is live.
Common mistakes
- Relying on a 15-month or 18-month figure from an article that pre-dates the 22 September amendment.
- Counting service-export time from the date the service is completed rather than the invoice date.
- Asking for an extension after the due date has passed, when the bank has less room to say yes.
- Treating a ₹10 lakh declaration as available for any amount; it is a per-shipping-bill or per-invoice ceiling.
- Assuming every bank will accept the same documents. Policies are bank-specific.
Frequently asked questions
What is the export realisation period from 1 October 2026?
Under Regulation 5(1) of the Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026, as amended on 22 September 2026, export proceeds must be realised within nine months of shipment for goods, nine months from the invoice date for services, and nine months from the date of sale for goods sent to an overseas warehouse. Exports invoiced or settled in Indian rupees get twelve months. Project exports follow the contract payment terms.
Does the 15-month period in the January 2026 notification apply?
No. The January 2026 text had fifteen months and eighteen months for rupee exports, but the amendment notified on 22 September 2026 (FEMA 23(R)/(1)/2026-RB) replaced them with nine and twelve months before the Regulations came into force on 1 October 2026. Articles that still quote 15 or 18 months are describing the superseded text.
Can my bank extend the realisation period?
Yes. The proviso to Regulation 5(1) lets an Authorised Dealer bank extend the period on the exporter's request where it finds the reasons satisfactory. Make the request in writing before the period expires and keep the buyer correspondence on file.
What happens if export proceeds stay unrealised?
Under Regulation 13, if proceeds remain unrealised for more than one year beyond the due date or the extended date, the exporter can undertake further exports only against full advance payment or an irrevocable Letter of Credit. Regulation 6 also lets the bank allow a reduced export value where under-realisation or non-realisation is justified.
When must the Export Declaration Form be filed for services?
Under Regulation 3(2), the EDF for service exports is due within 30 days after the end of the month in which the invoice is raised, and one EDF can cover all service exports of that month. For goods, the EDF is part of the shipping bill at EDI ports.
What about shipments made before 1 October 2026?
The 2026 Regulations supersede the 2015 Regulations except for things done or omitted before the supersession, and Regulation 20 empowers Authorised Dealers to handle earlier transactions that previously needed RBI approval. For open pre-October entries, confirm with your bank which period it is tracking before relying on either date.
We support exporters with accounting, FEMA documentation support and receivable ageing set-ups. Matters that need a bank decision or an authorised dealer sign-off stay with your bank.
CA support for exportersFEMA and foreign accountingTalk to us
This note is general information based on RBI Notification Nos. FEMA 23(R)/2026-RB (13 January 2026) and FEMA 23(R)/(1)/2026-RB (22 September 2026), read on the RBI website on 22 October 2026. It is not advice on a specific transaction. Authorised Dealer banks apply their own policies within the Regulations, so confirm the position for your facts with your bank and your professional adviser.