RBI's new export-import regulations took effect on 1 October 2026: what changed for exporters

The new Regulations came into force on 1 October 2026 (regulation 1(2)). They replace the 2015 export regulations, "except in respect of things done or omitted to be done before such supersession". The text does not say which period governs a shipment made before 1 October, so if you have one still unpaid, ask your bank which period it applies.

Most of the attention goes to one number, and it moved before the Regulations started. The January 2026 text gave exporters fifteen months to bring goods payments home, and eighteen where the sale was in rupees. An amendment dated 22 September 2026 (notification FEMA 23(R)/(1)/2026-RB, published in the Gazette on 24 September) replaced those with nine and twelve. Anyone who read the January notification and planned around fifteen months is working from the wrong figure.

The realisation clock#

Regulation 5(1) sets how long you have to receive the full export value and bring it into India. The start point depends on what you sold.

• Goods: nine months from the date of shipment.
• Goods sent to a warehouse outside India: nine months from the date the goods are sold out of that warehouse.
• Services, software included: nine months from the date of the invoice.
• Project exports: as per the payment terms of the contract.

If the export is invoiced or settled in rupees, the period is twelve months instead, counted from the same start points. The text says "invoiced or/and settled", so either one is enough.

Your Authorised Dealer can extend the period if you ask and give reasons it accepts. Regulation 5 states no cap on the extension. The bank must also put systems in place to follow up with you on realising proceeds within the period (regulation 5(2)).

When the full amount will not arrive#

Buyers deduct, short-pay and sometimes do not pay. Regulation 6 lets your bank agree to a lower export value, with reasons, covering both a short payment and no payment at all.

For an export of up to ₹10 lakh per shipping bill (goods) or per invoice (services), your own declaration is enough. Above that, the bank has to be satisfied by the reasons you give.

Regulation 4 has a matching relief for closing the entry in EDPMS, the system that tracks whether the money for each shipment came back. Where the shipping bill or invoice is up to ₹10 lakh, the entry can be closed on your declaration that payment was realised in full or otherwise. You may also give that declaration to your bank quarterly, for bulk closure. The mechanics of an entry that stays open are in why a shipping bill stays open in EDPMS.

Services: the Export Declaration Form#

An exporter of goods files the Export Declaration Form (EDF) as part of the shipping bill at an electronic port (regulation 3(1)). Services exporters file it themselves.

Under regulation 3(2), you must furnish the EDF within 30 days from the end of the month in which you raised the invoice. Four details sit around that deadline.

• If you exported to several recipients in a month, one EDF can cover them all.
• For services other than software, you may submit the EDF on or before the day payment is received.
• Your bank can extend the period if you ask and give reasons.
• Software is treated as a service for these Regulations (regulation 2(1)).

An invoice raised on 12 October 2026 falls in a month that ends on 31 October, so 30 days from the end of that month is 30 November. Work out the date once per month, from the month-end, not from the invoice day.

A year unpaid changes what you can ship#

Regulation 13 is the sharpest consequence in the text. If export proceeds stay unrealised for more than one year beyond the due date, or beyond any extension your bank allowed, you can export further only against full advance payment or an irrevocable letter of credit.

The year is counted from the due date of realisation, not from shipment. An extension from your bank moves that due date, so it also delays the point where regulation 13 applies.

Exporters already on the Caution List on 30 September 2026 are covered by a transitional proviso. They continue to be governed by the Reserve Bank's order under the 2015 regulations until they are removed from the list.

The Regulations also say, in regulation 19(3), that a bank shall not charge an exporter any charge or penalty for a regulatory delay or violation by the exporter. Read it as a limit on what the bank may levy, not as a waiver of the deadlines above.

Imports, briefly#

If you also import, regulation 9 puts your bank in charge of following up on payment within the period in the underlying contract. It may extend that period on your request, with reasons.

What to do on Monday#

1. Find the date nine months out for every goods shipment from 1 October. Use nine months from shipment, not fifteen. For rupee-settled sales use twelve. For a shipment made earlier and still unpaid, ask your bank which period applies.
2. List services invoices from the last two months and check each has an EDF filed, or a date by which it must be.
3. Ask your bank for its published policy. Regulation 19(4) requires an Authorised Dealer to disclose its policy and the main features of its procedure on its website, and regulation 19(1)(b) requires that policy to cover extending the realisation period. Read what documents and charges it asks for before you need an extension.
4. Request extensions early, with reasons, in writing. The Regulations let the bank allow one only if it is satisfied by the reasons given.
5. Flag anything close to one year past its due date. That is the point where regulation 13 restricts your next exports.
6. Gather your small shipments. EDPMS entries up to ₹10 lakh (or its foreign-currency equivalent) can be closed on your declaration, singly or as a quarterly bulk declaration (regulation 4). A reduction in realised value of that size is a separate per-case declaration (regulation 6).

Where to check#

The full text, with the footnotes that record the 22 September substitution, is on the Reserve Bank's site (link below). Read regulations 3, 5, 6 and 13 in full before you rely on this summary for a specific shipment.