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
/(8)/2026-RB
2026
→ 9 Months
& 9(2)(a)
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, as amended by Notification FEMA 23(R)/(1)/2026-RB dated September 22, 2026, now prescribes a 9-month realisation period (12 months where export proceeds are invoiced and/or settled in INR) 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 9 months / 12 months for INR, 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:
🔍 Section 2 — The Exact Change: Regulation 9 Then vs Now
2.1 — Regulation 9(1) — General Realisation Period (All Exporters)
2.2 — Regulation 9(2)(a) — SEZ / Status Holder / EOU / EHTP / STP / BTP Exporters
🔗 Official RBI References
Use these for citing the legal position in opinions, board notes or policy memos:
- 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).
- 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.
- FEMA 23(R)/2026-RB – Export & Import Regulations, 2026: New consolidated regulations effective 01 October 2026, as amended by Notification FEMA 23(R)/(1)/2026-RB dated September 22, 2026, prescribing a 9‑month realisation period (12 months where exports are invoiced and/or settled in INR) and a 9‑month period from date of sale for warehoused exports.
- FEMA 23(R)/(1)/2026-RB – Amendment to 2026 Regulations: Notified September 22, 2026 (effective October 01, 2026); amends the FEMA (Export and Import of Goods and Services) Regulations, 2026 to prescribe the 9‑month / 12‑month (INR) realisation framework, adds a Caution List proviso to Regulation 13 and inserts new Regulation 20 for specified pre‑1‑October‑2026 transactions.
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
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)
(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:
🚀 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
📊 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 (as amended September 22, 2026) prescribe 9 months (12 months for INR-invoiced/settled exports).
🏢 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 (as amended September 22, 2026) will bring a uniform 9-month period (12 months for INR).
📦 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 (as amended September 22, 2026), it becomes 9 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 (9 months standard; 12 months for INR).
📅 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 (9 months, as amended 22 Sep 2026)
❓ Section 9 — Frequently Asked Questions
✅ Section 10 — Action Checklist for Exporters & AD Banks
- ✅ 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
- ✅ Do NOT retrospectively change deadlines for exports made between November 14, 2025 and June 04, 2026 — those exports retain the 15-month realisation window
- ✅ 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
- ✅ 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
- ✅ 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
- ✅ Prepare for October 01, 2026: The new FEMA (Export and Import of Goods and Services) Regulations, 2026 (Notification FEMA 23(R)/2026-RB, as amended by Notification FEMA 23(R)/(1)/2026-RB dated September 22, 2026) take effect from October 01, 2026. Train your export compliance team on the new 9-month (12-month for INR-invoiced/settled exports) realisation periods, set-off provisions, and enhanced AD bank SOP requirements
- ✅ 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 9-month clock will run from date of sale at warehouse (more favourable)
- ✅ 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
Source Note (updated 11 October 2026): The post‑1‑October‑2026 position in this article is updated for RBI Notification FEMA 23(R)/(1)/2026-RB dated September 22, 2026 (effective October 01, 2026), which amended the FEMA (Export and Import of Goods and Services) Regulations, 2026 to prescribe a 9‑month realisation period (12 months where export proceeds are invoiced and/or settled in INR; 9 months from date of sale for warehoused exports). The same notification also added a Caution List proviso to Regulation 13 and inserted a new Regulation 20 enabling Authorised Dealers to handle specified pre‑1‑October‑2026 transactions that earlier required RBI approval. Read our detailed analysis: RBI FEMA 23(R) Export‑Import Amendment Regulations 2026 (September 2026).
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.
