Expert opinion · FEMA reporting

A FEMA checklist for 2026: imports, exports and other cross-border payments

Short answer. From 1 October 2026, declare each export, realise it within nine months or twelve in rupees, and pay each import within the contract. The AD bank closes the EDPMS or IDPMS entry. Services exports go on the monthly EDF. A services payment abroad needs its purpose code and, where tax applies, Form 145 or Form 146. FDI, overseas investment and ECB have their own returns.

This is a working list, not a filing you submit. Each line is a rule in the current regulations or a return that has its own guide. Where a number is the bank's policy rather than the regulation, the line says so.

CA Abhay JaiswalChartered Accountant · FEMA, RBI reporting and cross-border tax 8 min read Updated Last reviewed
Exports
  1. DeclareShipping bill or EDFServices within 30 days of month end
  2. RealiseNine or twelve monthsExtend before the due date
  3. CloseBank marks EDPMS offUp to ₹10 lakh on a declaration
Imports and other payments
  1. ContractPay within that periodThe bank may extend
  2. MatchBill of Entry to the remittanceOnly the bank closes IDPMS
  3. ServicesPurpose code and Form 145Where the payment is chargeable
Exports and Imports and other payments

Key points

  • Goods exports are declared with the shipping bill at an EDI port. Services exports, software included, go on an Export Declaration Form within 30 days of the month end, with the exceptions in regulation 3(2).
  • Realise and repatriate within nine months, or twelve when invoiced or settled in rupees, unless the bank extends the period.
  • Pay imports within the contract period. Do not treat six months as a figure the 2026 regulations state.
  • Entries up to ₹10 lakh may be closed on a declaration. Above that, the bank needs the match, the reduction or the extension.
  • If you hold FDI or overseas investment, or you have an ECB, the trade checklist does not replace FC-GPR, the FLA return, the APR or Form ECB 2.

Exports

  • Every goods export carries the full value on the Export Declaration Form. At an EDI port the shipping bill is that declaration. Check the AD code before it is filed, because the EDPMS entry opens with the bank named on the bill.
  • Every services export invoiced on or after 1 October 2026 is declared within 30 days from the end of the invoice month, or on or before payment for services other than software. One form may cover the month. The monthly EDF guide has the authority: AD bank, STPI for software, or the SEZ Development Commissioner.
  • Realise the full value within nine months of shipment or, for services, of the invoice, and within twelve months when the invoice is in rupees or the settlement is in rupees. Project exports follow the contract. Ask for an extension before the period ends.
  • If less will be realised, ask the bank for a reduction. Up to ₹10 lakh, the reduction may be a declaration. The older percentage write-off ceilings are not restated in the 2026 regulations.
  • If proceeds are still unrealised more than a year after the due date or the extension, further exports are only against a full advance or an irrevocable letter of credit. See the caution-list guide for the separate case of someone already listed on 30 September 2026.

Imports

  • Pay within the period in the contract. Regulation 9 does not state a universal six months. Get any extension from the bank before that period ends, with the reasons.
  • Give the bank the Bill of Entry, or the courier bill, so it can mark the IDPMS entry off. Only the bank closes it.
  • An advance uses the same bank as the later payments, unless you tell both banks. No advance for gold or silver. If the goods do not come, repatriate the advance inside the contract period or the extension. The import timelines guide sets out what a failed advance does to the next one.
  • Entries up to ₹10 lakh may be closed on your declaration, sent quarterly if the bank takes them that way.

Other cross-border payments

  • A merchanting trade keeps the two legs within six months, unless the bank extends that gap, and the documents go to the bank.
  • Every outward payment carries an RBI purpose code. A settlement of an import invoice is S0102 and an advance against an export contract is P0103. Goods imports use Form A1. Services and other payments use Form A2, and a chargeable payment for services needs Form 145 or Form 146 as the tax rules require. Those are income-tax forms, not FEMA forms. The Form 145 guide is the one to use, and the decision is yours and your chartered accountant's.
  • Set-off and third-party payments are allowed only when the bank is satisfied. Do not net them off in your books and leave the bank's entry open.

Returns that are not part of the trade entry

The checklist above does not file these. Each has its own clock:

  • Foreign investment into the company: FC-GPR or FC-TRS on the FIRMS portal, and the annual FLA return on FLAIR. See the FIRMS and FLA guide.
  • Investment in a company abroad: Form FC before the remittance, then the annual performance report. See the ODI guide.
  • A borrowing from outside India: a loan registration number before drawdown, then Form ECB 2. See the ECB guide.

Create a free workspace on the FxLayer platform to keep the trade half of this list: open bills, the monthly EDF and the letters the bank asks for. The platform does not file FC-GPR, the APR or Form ECB 2, and it does not advise on which return applies. That judgment stays with you and your chartered accountant.

Questions

No. It is a list of the things the regulations and the related returns require. The shipping bill, the EDF, the bank's reporting and the separate returns are what actually get submitted.
Yes. The monthly EDF, the realisation period on the invoice, the purpose code on money coming in, and Form 145 or Form 146 on money going out for services. Goods-only lines do not apply.
In the 2026 regulations or in a direction issued after them. Circular No. 20 of 16 January 2026 superseded the export and import Master Directions from 1 October 2026. If the current text is silent, ask the AD bank and keep its answer.

Sources

This article is general information on Indian foreign exchange and tax rules as they stood on the date shown. It is not legal or tax advice. Rules and limits change; confirm the current position with your AD bank, the relevant RBI Master Direction or your adviser before acting.

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