Export proceeds: nine months to realise and repatriate under the new FEMA export regulations from 1 October 2026

The Reserve Bank of India's Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026 (Notification No. FEMA 23(R)/2026-RB dated 13 January 2026) came into force on 1 October 2026, in supersession of the Foreign Exchange Management (Export of Goods & Services) Regulations, 2015.

Before they came into force, the RBI amended them by Notification No. FEMA 23(R)/(1)/2026-RB dated 22 September 2026, also in force from 1 October 2026. In regulation 5(1), "fifteen months" became "nine months", and in the proviso for rupee-invoiced exports "eighteen months" became "twelve months".

As amended, regulation 5(1) requires the full export value of goods and services to be realised and repatriated within nine months from the date of shipment for goods (other than goods exported to a warehouse outside India) and from the date of invoice for services; within nine months from the date of sale for goods exported to a warehouse outside India; and, for project exports, as per the payment terms of the contract.

Where the export is invoiced or settled in Indian rupees, the period is twelve months. The Authorised Dealer may, on a request from the exporter citing reasons for the delay, allow an extension beyond the specified period if satisfied with the reasons.

The amendment also provides that exporters on the RBI Caution List as on 30 September 2026 continue to be governed by the Caution List order until they are removed from it, and that Authorised Dealers will handle export, import and merchanting-trade transactions undertaken before 1 October 2026 that earlier needed RBI approval.

Regulation 13 keeps the consequence of long non-realisation: if proceeds remain unrealised for more than one year beyond the due date or any extended period, further exports may be made only against full advance or an irrevocable letter of credit.