In a move that has caught many exporters and trade finance professionals off-guard, the Reserve Bank of India issued Notification No. FEMA 23(R)/(8)/2026-RB dated June 05, 2026, notifying the Foreign Exchange Management (Export of Goods and Services) (First Amendment) Regulations, 2026 and making a pointed two-line surgical amendment to the Foreign Exchange Management (Export of Goods & Services) Regulations, 2015. The change? The export proceeds realisation and repatriation period — which was extended to fifteen months by the November 2025 amendment — has been reverted back to nine months under both the general realisation window (Regulation 9(1)) and the Special Economic Zone / Status Holder / EOU / EHTP / STP / BTP category window (Regulation 9(2)(a)).
This reversal is not a random policy flip — it is a deliberate regulatory housekeeping step linked to the landmark FEMA 23(R)/2026-RB dated January 13, 2026, which notified the comprehensive new Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026, set to supersede the 2015 Regulations entirely from October 01, 2026. The June 2026 amendment essentially re-aligns the sunset period of the 2015 Regulations with the incoming 2026 framework, while removing a temporary extension that was granted in 2025. Understanding the full context of this amendment is critical for every Indian exporter, authorised dealer bank, and trade compliance professional.
⚡ Notification at a Glance
FEMA 23(R)
/(8)/2026-RB
Notification Number
June 05,
2026
Date & Effective From
15 Months
→ 9 Months
Core Change
Reg. 9(1)
& 9(2)(a)
Regulations Amended
Rohit P. Das
Regional Director, RBI
Oct 01, 2026
New 2026 Regs Effective
⚠️ Critical Context: Why Is 15 Months Being Rolled Back to 9 Months?
The November 2025 amendment (FEMA 23(R)/(7)/2025-RB) extended the realisation period from 9 months to 15 months. However, the new comprehensive FEMA (Export and Import of Goods and Services) Regulations, 2026 (Notification FEMA 23(R)/2026-RB dated January 13, 2026), effective October 01, 2026, restores a 15-month period under its own framework. The June 2026 amendment reverts the interim 15-month extension so that the transition from the 2015 Regulations (at 9 months) to the 2026 Regulations (at 15 months, effective October 2026) is clean and governed by a single unified framework — avoiding a period of overlapping or conflicting timelines.
📜 Section 1 — The Amendment History: How We Got Here
Understanding the June 2026 amendment requires tracing the evolution of Regulation 9 of FEMA 23(R)/2015-RB:
January 12, 2016 — FEMA 23(R)/2015-RB (Original)
Export Realisation Period: 9 Months
Original 2015 Regulations established the baseline realisation and repatriation period of 9 months from the date of export for goods, software, and services. Warehoused goods: 15 months from date of shipment.
March 31, 2020 — FEMA 23(R)/(3)/2020-RB
COVID Relief: Warehouse Export Period Clarified
Inserted reference to "said period" for warehoused goods and authorised dealer/RBI power to extend timelines for sufficient and reasonable cause.
November 13, 2025 — FEMA 23(R)/(7)/2025-RB
Major Extension: 9 Months → 15 Months
In Regulation 9(1) and 9(2)(a), substituted "nine months" with "fifteen months" for export realisation and repatriation. Also extended advance payment shipment window from 1 year to 3 years under Regulation 15.
January 13, 2026 — FEMA 23(R)/2026-RB
New Comprehensive Regulations Notified (Effective October 01, 2026)
RBI notified the new FEMA (Export and Import of Goods and Services) Regulations, 2026 — superseding the entire 2015 Regulations. Sets 15 months as the new standard realisation period with INR exports at 18 months. Effective October 01, 2026.
June 05, 2026 — FEMA 23(R)/(8)/2026-RB 👈 THIS AMENDMENT
Reversal: 15 Months → 9 Months (Under 2015 Regs Only)
In Regulation 9(1) and 9(2)(a), substitutes "fifteen months" back to "nine months". Cleans up the interim 2025 extension before the 2026 Regulations take over from October 01, 2026 with their own 15-month framework.
🔍 Section 2 — The Exact Change: Regulation 9 Then vs Now
2.1 — Regulation 9(1) — General Realisation Period (All Exporters)
❌ After Nov 2025 Amendment (Now Reversed)
The amount representing the full export value of goods / software / services exported shall be realised and repatriated to India within fifteen months from the date of export…
FEMA 23(R)/(7)/2025-RB — November 2025
✅ Current Position (Post June 2026 Amendment)
The amount representing the full export value of goods / software / services exported shall be realised and repatriated to India within nine months from the date of export…
FEMA 23(R)/(8)/2026-RB — June 05, 2026
2.2 — Regulation 9(2)(a) — SEZ / Status Holder / EOU / EHTP / STP / BTP Exporters
❌ After Nov 2025 Amendment (Now Reversed)
…the amount representing the full export value of goods or software shall be realised and repatriated to India within fifteen months from the date of export.
Applied equally to SEZ units, EOUs, STP, EHTP, BTP, Status Holders
✅ Current Position (Post June 2026 Amendment)
…the amount representing the full export value of goods or software shall be realised and repatriated to India within nine months from the date of export.
Reverted for all these special category exporters
🔗 Official RBI References
Use these for citing the legal position in opinions, board notes or policy memos:
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FEMA 23(R)/(8)/2026-RB – First Amendment 2026:
Amends Regulation 9 of the Foreign Exchange Management (Export of Goods and Services) Regulations, 2015 by substituting the words “fifteen months” with “nine months” in sub‑regulation (1) and clause (a) of sub‑regulation (2), effective from the date of publication in the Official Gazette (05 June 2026).
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FEMA 23(R)/(7)/2025-RB – Second Amendment 2025:
Earlier extended the export proceeds realisation period from 9 months to 15 months and increased the shipment window against advance payments from 1 year to 3 years under Regulation 15.
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FEMA 23(R)/2026-RB – Export & Import Regulations, 2026:
New consolidated regulations effective 01 October 2026 prescribing a 15‑month realisation period (18 months where exports are invoiced/settled in INR) and a 15‑month period from date of sale for warehoused exports.
Always download the latest RBI notification PDFs from official or trusted databases when drafting contracts, bank circulars or internal SOPs.
📋 Section 3 — Complete Realisation Period Comparison: All Phases
📌 Important Note on Advance Payment Window
The June 2026 amendment only touches Regulation 9(1) and 9(2)(a) — the export realisation periods. The amendment to Regulation 15 made in November 2025 (extending the advance payment shipment window from 1 year to 3 years) is NOT reversed by this amendment. The 3-year advance payment window remains in force under the 2015 Regulations until October 01, 2026 when the new 2026 Regulations take over.
📄 Section 4 — Regulation 9 — Full Current Text (Post June 2026)
REGULATION 9 — PERIOD WITHIN WHICH EXPORT VALUE OF GOODS / SOFTWARE / SERVICES TO BE REALISED
(1) The amount representing the full export value of goods / software / services exported shall be realised and repatriated to India within nine months or within such period as may be specified by the Reserve Bank, in consultation with the Government, from time to time, from the date of export, provided
(a) that where the goods are exported to a warehouse established outside India with the permission of the Reserve Bank, the amount representing the full export value of goods exported shall be paid to the authorised dealer as soon as it is realised and in any case within nine months or within such period as may be specified by the Reserve Bank, in consultation with the Government, from time to time from the date of shipment of goods;
(b) further that the Reserve Bank, or subject to the directions issued by that Bank in this behalf, the authorised dealer may, for a sufficient and reasonable cause shown, extend the said period.
(2)(a) Where the export of goods / software / services has been made by Units in Special Economic Zones (SEZ) / Status Holder exporter / Export Oriented Units (EOUs) and units in Electronics Hardware Technology Parks (EHTPs), Software Technology Parks (STPs) and Bio-Technology Parks (BTPs) as defined in the Foreign Trade Policy in force, then notwithstanding anything contained in sub-regulation (1), the amount representing the full export value of goods or software shall be realised and repatriated to India within nine months or within such period as may be specified by the Reserve Bank, in consultation with the Government, from time to time, from the date of export.
🔒 Section 5 — What Remains Unchanged in the 2015 Regulations
The June 2026 amendment is highly targeted — only two substitutions in Regulation 9. All other provisions of FEMA 23(R)/2015-RB remain intact until October 01, 2026:
Regulation 3
Export declaration (EDF / SOFTEX) requirements — unchanged. All exporters must still furnish declarations at Customs/STPI as applicable.
Regulation 4
Exemptions from filing declarations (trade samples, gifts up to ₹5 lakh, personal effects, re-exports, etc.) — all unchanged.
Regulation 9 — AD Extension Power
The Authorised Dealer / RBI power to extend the 9-month period for "sufficient and reasonable cause" — remains in force. Banks can still grant extensions case-by-case.
Regulation 10
Submission of export documents to AD bank within 21 days from date of export — unchanged. AD bank may accept late submissions for reasons beyond exporter's control.
Regulation 12
Restrictions on payment terms — proceeds must be received in specified manner; payment must not be delayed beyond the specified period (now 9 months again); proceeds must represent full export value.
Regulation 15 (Advance Payments)
3-year shipment window retained (extended by Nov 2025 amendment). Exporters receiving advance payments still have 3 years to ship. No remittance for refund after 3 years without RBI approval.
Regulation 17 (Project Exports)
Project exports and deferred payment / turnkey / civil construction arrangements must still obtain prior approval of EXIM Bank / authorised dealer — unchanged.
SOFTEX / EDF Forms
Declaration forms EDF (duplicate, for non-EDI ports) and SOFTEX (triplicate, for software exports) remain in the Schedule — no change.
🚀 Section 6 — What Changes on October 01, 2026: The New Framework
The 2015 Regulations (including this June 2026 amendment) will be superseded in their entirety by the new FEMA (Export and Import of Goods and Services) Regulations, 2026 on October 01, 2026. Here is a snapshot of what changes under the new framework:
🗓️ October 01, 2026 Onwards — Key Changes Under FEMA 23(R)/2026-RB
Realisation Period
15 months from date of shipment (goods) / invoice (services). For INR-invoiced exports: 18 months. Warehouse exports: 15 months from date of sale at warehouse.
Import Integration
The 2026 Regulations consolidate both export AND import of goods and services into a single unified framework for the first time — replacing both the 2015 export regulations and related import-side directions.
Set-Off & Third Party
AD Banks can permit set-off of export receivables against import payables with the same overseas counterparty or group/associate companies — within the prescribed realisation period.
Small Invoice Relief
For exports up to ₹10 lakh per invoice/shipping bill, AD Banks may permit reduction or non-realisation based on a simple exporter declaration — big relief for SMEs and first-time exporters.
If export proceeds remain unrealised for more than 1 year beyond due date, further exports allowed only against full advance payment or irrevocable LC — strengthened enforcement.
AD Bank SOPs
AD Banks mandated to have Standard Operating Procedures (SOPs) covering approvals, documentation, timelines, and grievance redressal. Enhanced EDPMS / IDPMS reporting obligations.
📊 Section 7 — Impact Analysis: Who Is Affected & How
🏭 General Exporters (Goods / Software / Services)
For exports made between November 14, 2025 and June 04, 2026, you had a 15-month realisation window. For exports made on or after June 05, 2026 (until September 30, 2026), the period reverts to 9 months. From October 01, 2026 onwards, the new 2026 Regulations restore 15 months.
🏢 SEZ Units / EOUs / STP / EHTP / BTP
These special category exporters also lose the 15-month window for exports made from June 05, 2026. Their realisation window under Reg. 9(2)(a) reverts to 9 months for the period June 05 – September 30, 2026. The Oct 2026 Regulations will bring a uniform 15-month period.
📦 Exporters to Overseas Warehouses
Under the original 2015 Regulations, warehouse export proceeds were due within 15 months from date of shipment. The June 2026 amendment reduces this to 9 months from shipment for the interim period. Under Oct 2026 Regulations, it becomes 15 months from date of sale at warehouse — a more exporter-friendly measure.
🏦 Authorised Dealer Banks
Banks must update their EDPMS (Export Data Processing and Monitoring System) due-date settings for new export shipments from June 05, 2026 — from 15 months back to 9 months. Track three sets of exporters: (a) pre-Nov 2025 exports at 9 months, (b) Nov 2025–Jun 2026 exports at 15 months, (c) post-Jun 2026 exports at 9 months.
💰 Exporters with Advance Payments
Unaffected by this amendment. The 3-year shipment window under Regulation 15 (introduced in November 2025) remains intact. Exporters who received advance payments can still ship within 3 years. Refund of unutilised advances after 3 years still requires prior RBI approval.
⚖️ FEMA Compliance Officers / CFOs
Update compliance calendars to reflect three distinct realisation deadlines depending on date of export. For exports between Nov 14, 2025 and Jun 04, 2026 — 15 months applies. From Jun 05, 2026 to Sep 30, 2026 — 9 months applies. From Oct 01, 2026 — new 2026 Regulations govern.
📅 Realisation Timeline Cheat Sheet (By Date of Export)
💡 Section 8 — Practical Illustrations: Computing Your Realisation Deadline
🔴 = Exports under the reverted 9-month window | 🟢 = Exports under new 2026 Regulations (15 months)
❓ Section 9 — Frequently Asked Questions
Q1. I exported goods on January 15, 2026 — does the 15-month or 9-month period apply to me?
?
The 15-month period applies to your export. The November 2025 amendment (FEMA 23(R)/(7)/2025-RB, effective November 14, 2025) substituted "nine months" with "fifteen months." Since your export date (January 15, 2026) falls after November 14, 2025, and before the June 2026 amendment (effective June 05, 2026), the 15-month window applies. Your realisation deadline would be April 15, 2027. The June 2026 reversal applies only to exports made on or after June 05, 2026.
Q2. Why did RBI first extend to 15 months in November 2025 and then reverse it back to 9 months in June 2026?
?
The November 2025 extension to 15 months was a forward-looking change aligning the 2015 Regulations with the incoming new framework. However, the comprehensive new FEMA (Export and Import of Goods and Services) Regulations, 2026 (notified January 13, 2026, effective October 01, 2026) provides its own complete realisation framework — including 15 months for standard exports and 18 months for INR-denominated exports. To avoid confusion or a dual regime for exports made between June–September 2026 (which would technically fall under both frameworks), the June 2026 amendment reverts the 2015 Regulations to their baseline (9 months) for the final transition period. Think of it as a clean handover: the 2015 Regulations end their run at 9 months, and the 2026 Regulations begin at 15 months on October 01, 2026.
Q3. My AD bank granted me an extension beyond 9 months for pending export proceeds. Is my extension still valid?
?
Yes. Regulation 9(1)(b) — the power of the Reserve Bank or the Authorised Dealer to extend the realisation period for "sufficient and reasonable cause" — remains fully intact and is not affected by this amendment. If your AD bank has already granted an extension on a case-by-case basis (in accordance with RBI Master Directions on Exports), that extension continues to be valid for the specific export transaction it covers.
Q4. I am a software exporter (STP unit). Does the 9-month period now apply to my software exports too?
?
Yes, for software exported on or after June 05, 2026. Under Regulation 9(2)(a), Software Technology Park (STP) units are included in the special category (alongside SEZ units, EOUs, EHTP, BTP, and Status Holders). The June 2026 amendment also substitutes "fifteen months" with "nine months" in Regulation 9(2)(a). So for STP-unit software exports made from June 05, 2026 onwards (until September 30, 2026), the realisation period is 9 months from the date of export (date of invoice for software). From October 01, 2026, the 2026 Regulations will apply with a 15-month period.
Q5. I received advance payment from a foreign buyer in April 2026. Do I need to ship within 9 months?
?
No. The 9-month reversal affects only the export proceeds realisation period (Regulation 9) — i.e., how long after the date of export you have to receive and repatriate payment. The advance payment shipment window under Regulation 15 is governed separately and was extended from 1 year to 3 years by the November 2025 amendment. The June 2026 amendment does not touch Regulation 15. So if you received advance payment in April 2026, you still have 3 years from the date of receipt (i.e., until April 2029) to ship the goods, provided the export agreement permits such a timeline.
Q6. What happens if I exported goods to a warehouse abroad on August 01, 2026? When is the realisation due?
?
Under the 2015 Regulations (as amended in June 2026), Regulation 9(1)(a) provides that proceeds from warehouse exports must be realised within nine months from the date of shipment — so realisation would be due by May 01, 2027. However, note that from October 01, 2026, the new 2026 Regulations take effect. For the warehouse export shipped on August 01, 2026, the 2015 Regulations govern (since the export occurred before October 01, 2026) and the 9-month clock from the shipment date applies. Under the 2026 Regulations (for exports from October 2026), the 15-month window for warehouse exports would run from the date of sale at the warehouse — a more favourable position for exporters.
Q7. As an AD bank, how should we update our EDPMS records?
?
AD banks should maintain three separate realisation deadline buckets in EDPMS: (1) Exports before November 14, 2025: 9 months from export date under original 2015 Regulations. (2) Exports between November 14, 2025 and June 04, 2026: 15 months from export date under the Nov 2025 amendment — these shipments retain the 15-month window; do not change their due dates. (3) Exports from June 05, 2026 to September 30, 2026: 9 months from export date. (4) Exports from October 01, 2026: Governed by new 2026 Regulations (15 months standard; 18 months for INR). AD banks should also wait for updated Master Directions from RBI that typically accompany such regulatory changes.
✅ Section 10 — Action Checklist for Exporters & AD Banks
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Map your export transactions by date: Identify which exports fall in which amendment window — pre-Nov 2025 (9M), Nov 2025–Jun 2026 (15M), or post-Jun 2026 (9M) — and compute realisation deadlines accordingly
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Do NOT retrospectively change deadlines for exports made between November 14, 2025 and June 04, 2026 — those exports retain the 15-month realisation window
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For exports from June 05, 2026: Set EDPMS due dates at 9 months from the date of export (or date of invoice for software). Alert your sales and finance teams immediately
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Advance payment recipients — relax: Your 3-year shipment window under Regulation 15 is unchanged by this amendment. Continue to plan shipments within the 3-year window from the date of advance receipt
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Seek AD bank extension proactively: If any export made from June 2026 onwards is unlikely to realise within 9 months, approach your AD bank early with documentary evidence of delay — the extension power under Regulation 9(1)(b) remains available
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Prepare for October 01, 2026: The new FEMA (Export and Import of Goods and Services) Regulations, 2026 (Notification FEMA 23(R)/2026-RB) take effect from October 01, 2026. Train your export compliance team on the new 15-month (foreign currency) and 18-month (INR) realisation periods, set-off provisions, and enhanced AD bank SOP requirements
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Warehouse exporters: For goods shipped to overseas warehouses between June 05–September 30, 2026, realise within 9 months from date of shipment. From October 01, 2026, the clock will run from date of sale at warehouse (more favourable)
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AD banks — update internal SOPs: Revise EDPMS workflows, override alerts for June 2026 exports, and prepare staff for the new 2026 Regulations framework from October — including enhanced reporting and mandatory SOP requirements under the new framework
Sources: Notification No. FEMA 23(R)/(8)/2026-RB dated June 05, 2026 | Foreign Exchange Management (Export of Goods and Services) (First Amendment) Regulations, 2026 | FEMA 23(R)/2015-RB dated January 12, 2016 (Amended upto June 05, 2026) | FEMA 23(R)/(7)/2025-RB dated November 13, 2025 | FEMA 23(R)/2026-RB dated January 13, 2026 (New Regulations effective October 01, 2026) | Reserve Bank of India — Foreign Exchange Department |
rbi.org.in |
CorpLawUpdates.in
This article is for informational and educational purposes only and does not constitute legal or compliance advice. Verify requirements with current RBI Master Directions and notifications before relying on this content for compliance purposes. For exports with overlapping periods, consult your Authorised Dealer bank.
