The Reserve Bank of India (“RBI”), by Notification No. FEMA 23(R)/(1)/2026-RB dated September 22, 2026, has amended the Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026 (the “2026 Regulations”). The amendment came into force on October 1, 2026, together with the 2026 Regulations.
The amendment carries forward the nine-month realisation period restored under the Foreign Exchange Management (Export of Goods & Services) Regulations, 2015 (the “2015 Regulations”) on June 5, 2026, as one of five measures announced to attract foreign capital.
Key changes to the 2026 Regulations:
- Realisation period (Regulation 5(1)): Except for project exports, which follow the payment terms of the contract, export proceeds must be realised and repatriated within nine months instead of the fifteen months originally notified. The period runs from the date of shipment (goods other than those exported to a warehouse outside India), the date of invoice (services), or the date of sale from the warehouse (goods exported to a warehouse outside India). Where exports are invoiced or settled in Indian Rupees, the period is twelve months instead of eighteen.
- Caution-listed exporters (proviso to Regulation 13): Exporters on the RBI’s Caution List as on September 30, 2026, continue to be governed by the orders issued by the RBI under Regulation 16 of the 2015 Regulations until they are removed from the list.
- Powers to Authorised Dealers (new Regulation 20): Authorised Dealers (“ADs”) will handle export, import and merchanting trade transactions that previously required RBI approval under the 2015 Regulations and the Master Directions on export and import of goods and services, where undertaken before October 1, 2026.
In practice, the nine-month period applicable to most exports since June 2026 continues, with ADs able to allow extensions on request under the second proviso to Regulation 5(1). Apart from a general saving clause, the 2026 Regulations do not expressly state which period governs exports made before October 1, 2026. View the full notification HERE.