# The FEMA export and import regulations, 2026: what changed on 1 October By CA Abhay Jaiswal · Updated 2026-10-18 · Source: https://fxlayerhq.com/insights/fema-export-import-regulations-2026 Expert opinion · Exports **Short answer.** The Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026 took effect on 1 October 2026 and replaced the 2015 export regulations and the export and import Master Directions. An amendment of 22 September 2026 set realisation at nine months, or twelve when the export is invoiced or settled in rupees. Import payments follow the contract. The authorised dealer may extend either period. One notification now covers goods, services and software, for money coming in and money going out. The dates that matter are the ones in the regulations themselves, not the periods people remember from the old Master Directions. ## Key points - Notification FEMA 23(R)/2026-RB of 13 January 2026 came into force on 1 October 2026 and superseded the 2015 export regulations. - A.P. (DIR Series) Circular No. 20 of 16 January 2026 superseded the export and import Master Directions from the same date. - Full export value is realised within nine months, or twelve months when invoiced or settled in rupees. The January text had said fifteen and eighteen; the 22 September 2026 amendment changed those figures before the regulations began. - Import payment is followed up within the period in the contract. The regulations do not set one period for every import. - If export proceeds stay unrealised for more than a year after the due date or an extension, further exports are only against a full advance or an irrevocable letter of credit. ## What was replaced Notification FEMA 23(R)/2026-RB of 13 January 2026 is the [Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026](https://www.rbi.org.in/Scripts/BS_FemaNotifications.aspx?Id=13277). It came into force on 1 October 2026 and superseded the Foreign Exchange Management (Export of Goods and Services) Regulations, 2015, except for things already done or left undone. A.P. (DIR Series) Circular No. 20 of 16 January 2026, effective the same day, tells authorised dealers to follow FEMA and the Foreign Trade Policy, and says the Master Direction on export of goods and services and the Master Direction on import of goods and services stand superseded, together with the circulars listed in its annex. The practical point: a period, a percentage or a form that lived only in those Master Directions is not a current rule unless the 2026 regulations or a later direction repeat it. Where this guide cannot find a figure in the current text, it says so. ## Who declares an export, and when An exporter of goods gives the specified authority an [Export Declaration Form](https://fxlayerhq.com/insights/monthly-edf-for-services) for the full export value at the time of export. At an EDI port the [shipping bill](https://fxlayerhq.com/insights/what-is-edpms) is treated as that declaration. A traveller moving personal effects is not an exporter for these regulations. An exporter of services files the same form within 30 days from the end of the month in which the invoice was raised. One form may cover every service export of that month. An exporter of services other than software may instead file on or before the day the payment arrives. The authorised dealer may extend the filing period if the reasons are reasonable. Software is defined in the regulations, and the explanation says services include software. The specified authority is the [AD bank](https://fxlayerhq.com/insights/role-of-the-ad-bank) for services other than software, the AD bank or STPI for software, and the Development Commissioner for a unit in a Special Economic Zone. The [monthly EDF guide](https://fxlayerhq.com/insights/monthly-edf-for-services) covers who files the services declaration and what the regulations do not yet specify about its file format. ## Realising export proceeds Regulation 5, as amended by [FEMA 23(R)/(1)/2026-RB](https://rbi.org.in/Scripts/BS_FemaNotifications.aspx?Id=13714) of 22 September 2026, requires the full export value to be realised and repatriated within nine months from the date of shipment for goods, and from the date of invoice for services. Goods sold from a warehouse outside India are counted from the date of sale. Project exports follow the contract. Where the export is invoiced or settled in rupees, the period is twelve months. The footnotes to the consolidated text say the January version had read fifteen months, and eighteen months for rupees, and that the September amendment substituted the shorter periods before the regulations took effect. The authorised dealer may extend the period if it is satisfied with the reasons. It must have systems to follow up. A reduction in the value, including a case where nothing will be realised, may be allowed when the bank is satisfied of the reasons; where the shipping bill or invoice is up to ₹10 lakh, the reduction may rest on the exporter's declaration. Set-off against import payables of the same overseas party, or of its overseas group or associate companies, may be allowed inside the [realisation period](https://fxlayerhq.com/insights/export-realisation-timelines) or an extension. Third-party receipts and payments may be permitted when the bank is satisfied the transaction is genuine. The regulations do not restate the older percentage ceilings for a write-off. Those lived in directions that Circular No. 20 superseded. Ask the bank what its own policy, which regulation 19 requires it to publish, still asks for. The [realisation-period guide](https://fxlayerhq.com/insights/export-realisation-timelines) walks through extensions on a single Shipping Bill. ## Imports, advances and merchanting Regulation 9 tells the bank to follow up so that the importer pays within the period in the underlying contract, and allows the bank to extend that period. There is no single statutory number of months in this regulation. Regulation 10 lets the bank permit an import advance after it is satisfied the advance is genuine, and lets the bank set its own threshold above which a standby letter of credit or a guarantee is required. No advance is permitted for the import of gold or silver. If the import does not happen within the contract period or an extension, the advance is brought back; if it is not, any later advance needs an unconditional, irrevocable standby letter of credit or a guarantee of the kind regulation 12 describes. The advance and the later payments go through the same bank unless the importer tells both banks of a change. Interest, if any, on an export advance or on a delayed import payment must not exceed the all-in-cost ceiling of trade credit under the borrowing and lending regulations. The 2026 text does not restate a single deadline for shipping goods against an export advance. Confirm that window with the bank. A merchanting trade keeps the gap between the outward and inward remittance, either way, within six months, unless the bank extends it. Both legs are documented, and the bank closes or updates EDPMS and IDPMS as the money moves. The [import timelines guide](https://fxlayerhq.com/insights/import-payment-timelines) and the [merchanting guide](https://fxlayerhq.com/insights/merchanting-trade-transactions) take those two cases further. ## What the bank reports, and what happens if exports stay unpaid The bank enters a services EDF in EDPMS within five working days of receiving it, and marks an export off only after the value has been realised. An import is marked off after the payment has been made. Entries of up to ₹10 lakh may be closed on a declaration, including a quarterly declaration for many entries at once. The bank's policy and the main points of its procedure go on its website, and it may not levy a charge or penalty for a regulatory delay by the customer. Regulation 13 is the new consequence of exports that stay unpaid: if proceeds remain unrealised beyond one year from the due date, or from an extension the bank allowed, further exports are undertaken only against a full advance or an irrevocable letter of credit. Exporters who were already on the caution list on 30 September 2026 stay under the old order until they are removed. That list, and what the superseded circulars used to do, is in the [caution-list guide](https://fxlayerhq.com/insights/edpms-caution-list). Transactions from before 1 October 2026 that used to need the Reserve Bank's approval are handled by the authorised dealer under regulation 20, which the September amendment added. On the FxLayer platform, each Shipping Bill, Bill of Entry and services invoice keeps the date the regulations use, and the monthly EDF is produced from the invoices already on the record. The platform does not file with the bank or with RBI. You send the papers, and the bank closes the entry. ## Questions **When did the 2026 export and import regulations start?** On 1 October 2026. They were notified on 13 January 2026 and amended on 22 September 2026, and both the regulations and A.P. (DIR Series) Circular No. 20 take effect from 1 October 2026. **Is the realisation period fifteen months or nine?** Nine months, or twelve when the export is invoiced or settled in rupees. The January text said fifteen and eighteen. The amendment of 22 September 2026 substituted nine and twelve before the regulations came into force. **Did the Master Directions on export and import survive?** No. Circular No. 20 of 16 January 2026 says both Master Directions, and the circulars in its annex, stand superseded from 1 October 2026. A rule that existed only in those directions has to be read in the 2026 regulations or in a later direction. **Do services exports still use SOFTEX?** No. Services, and the regulations say services include software, are declared on the Export Declaration Form. Software may still go to STPI, which the regulations name as a specified authority for software. ## Sources - [RBI Notification No. FEMA 23(R)/2026-RB of 13 January 2026: Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026](https://www.rbi.org.in/Scripts/BS_FemaNotifications.aspx?Id=13277) - [RBI Notification No. FEMA 23(R)/(1)/2026-RB of 22 September 2026: the amendment regulations](https://rbi.org.in/Scripts/BS_FemaNotifications.aspx?Id=13714) - [RBI A.P. (DIR Series) Circular No. 20 of 16 January 2026: Export and Import of Goods and Services (the old Master Directions superseded from 1 October 2026)](https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=13278&Mode=0) 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.