What changed
The Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026 (Notification FEMA 23(R)/2026-RB, 13 January 2026) replace the 2015 export regulations from 1 October 2026. As first notified, they allowed 15 months, or 18 months for rupee-invoiced exports. The amendment of 22 September 2026 (FEMA 23(R)/(1)/2026-RB, published in the Gazette on 24 September 2026) replaced these with 9 months and 12 months before the regulations came into force.
Under Regulation 5, the period runs from the date of shipment for goods, from the date of invoice for services (software counts as a service), and from the date of sale for goods sent to a warehouse outside India. Project exports follow the contract terms. The AD bank can extend the period on the exporter’s request if the reasons for the delay are satisfactory. The regulations do not set a separate period for SEZ units or EOUs.
The Export Declaration Form (EDF) is the declaration for both goods and services. For goods shipped through an EDI port it is treated as part of the shipping bill. For services, one EDF can cover all invoices of a month and is filed within 30 days after the end of that month. The amendment also keeps exporters on RBI’s caution list as on 30 September 2026 under the existing order, and lets AD banks deal with transactions begun before 1 October 2026 that earlier needed RBI approval.
Who is affected
Exporters of goods, services and software, and their AD banks.
Effective dates
| Item | Date or period |
|---|---|
| Principal regulations notified | 13 January 2026 |
| Amendment notified | 22 September 2026 (Gazette, 24 September 2026) |
| Regulations in force | 1 October 2026 |
| Goods and services invoiced in foreign currency | 9 months from shipment or invoice |
| Exports invoiced or settled in Indian rupees | 12 months |
| EDF for services | Within 30 days after the end of the month of invoice |
What to do now
- Sort open export invoices by date: exports before 1 October 2026 stay under the 2015 regulations, later ones fall under the 2026 regulations.
- Show the realisation deadline (9 or 12 months) against each invoice in the receivables ledger.
- Where a buyer is late, ask the AD bank for an extension before the period runs out.
- Set up the monthly EDF for services so it is filed within 30 days of the month end.
Penalty or consequence if missed
Not realising export value within the period, without an extension from the AD bank, is a contravention of FEMA. Under Section 13 of FEMA the penalty can be up to three times the sum involved where it can be quantified, or up to ₹2 lakh where it cannot, and up to ₹5,000 a day if the contravention continues. Exporters with long-pending bills can also be placed on RBI’s caution list, after which each shipment needs extra conditions from the bank.
Official source
- FEMA 23(R)/2026-RB, principal regulations (PDF)
- Regulations as amended up to 22 September 2026 (RBI)
Effective: From 1 Oct 2026 · Note published · Last reviewed
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This note summarises a public notification for general information. It is not professional advice and does not cover every condition or exception, and the rule can change again by a later notification. Read the notification itself before acting on it, or consult a qualified professional on your own facts.