Export Realisation Timelines Under FEMA: What Indian Exporters Need to Know

Under the RBI's Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026, an Indian exporter must realise and repatriate the full export value within nine months from the date of shipment for goods, or from the date of invoice for services; the period is twelve months where the export is invoiced or settled in Indian Rupees. The Regulations came into force on 1 October 2026. Always confirm the current text and your own position with your Authorised Dealer (AD) bank.

Key facts

• Instrument: Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026 (notification FEMA 23(R)/2026-RB, 13 January 2026), in force from 1 October 2026.
• Period (Regulation 5): nine months from the date of shipment (goods) or from the date of invoice (services); twelve months where goods or services are invoiced or settled in Indian Rupees.
• Amendment: notification FEMA 23(R)/(1)/2026-RB dated 22 September 2026 replaced "fifteen months" with "nine months" and "eighteen months" with "twelve months" in Regulation 5, with effect from 1 October 2026.
• Goods sent to a warehouse outside India: nine months from the date of sale of the goods from the warehouse. Project exports: per the payment terms of the contract.
• Extension: an AD may extend the period on the exporter's request, giving reasons, if the AD is satisfied with them.
• Unrealised exports (Regulation 13): if proceeds remain unrealised for more than one year beyond the due date of realisation or the extended period, further exports are possible only against full advance receipt or an irrevocable Letter of Credit.
• Monitoring: ADs must have systems to monitor exporters and follow up on realisation; export entries are tracked in the RBI's EDPMS.

How is the period counted?

The clock starts at the date of shipment for goods and at the date of invoice for services. For goods that go to a warehouse outside India, it starts at the date of sale from the warehouse. The obligation is to realise and repatriate the full export value, or a reduced value that the Authorised Dealer allows under Regulation 6 if it is satisfied with the reasons the exporter cites (for a shipping bill or invoice up to INR 10 lakh, on the exporter's declaration), including by set-off where the Regulations permit.

What is an export declaration, and where does EDPMS come in?

The exporter declares the export value on an Export Declaration Form (EDF). For goods shipped through an EDI port, the EDF is deemed submitted as part of the shipping bill. For services, the EDF is due within 30 days after the end of the month in which the invoice is raised. The AD records the export in the Export Data Processing and Monitoring System (EDPMS), updates the entry when the exporter's account is credited and marks it off once realisation is confirmed. For a shipping bill or invoice up to INR 10 lakh, the Regulations allow the entry to be closed on the exporter's declaration of payment status once the AD is satisfied the transaction is genuine.

What if the buyer has not paid within the period?

An exporter who cannot realise the proceeds in time can ask the AD for an extension, setting out the reasons for the delay. The AD decides whether it is satisfied with those reasons. The Regulations also address situations such as set-off of export receivables against import payables (only through an AD and only with the same overseas party or its group or associate companies) and third-party receipts and payments (only where the AD permits). Under Regulation 13, where export proceeds remain unrealised for more than one year beyond the due date of realisation or the extended period, the exporter may make further exports only against receipt of full advance payment or an irrevocable Letter of Credit. Speak to your AD early rather than at the deadline.

How does factoring relate to this deadline?

The realisation obligation sits with the exporter and does not change because an invoice has been sold to a finance provider. The Regulations require an AD's internal policy to cover export factoring, but they do not describe the factoring arrangement itself. If you are considering factoring, discuss with your AD bank and your finance provider how the receipt of proceeds, including any third-party receipt, will be reported and closed. See export factoring in India.

Why does the period matter commercially?

It is a legal ceiling, not a commercial payment term. Your credit terms with a buyer are a commercial agreement between you and the buyer, and the shorter the gap between shipment and receipt, the less working capital you need. See how to get paid faster on open-account exports.

Frequently asked questions

What is the FEMA time limit for realising export proceeds?

Nine months from the date of shipment (goods) or the date of invoice (services), and twelve months for exports invoiced or settled in Indian Rupees, under Regulation 5 of the RBI's 2026 Regulations as amended on 22 September 2026.

When did the current period start to apply?

The Regulations, and the amendment to Regulation 5, are in force from 1 October 2026.

Can the period be extended?

Yes, an Authorised Dealer can extend it on the exporter's request, with reasons, if the AD is satisfied with them.

What is EDPMS?

The Export Data Processing and Monitoring System, the RBI system in which Authorised Dealers record export transactions and their realisation.

Does selling an invoice to a factor cancel my obligation?

No. The obligation remains with the exporter. Coordinate with your AD bank on how proceeds are received and reported.

Sources

• RBI, Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026 (FEMA 23(R)/2026-RB), amended up to 22 September 2026: rbi.org.in.
• RBI, notification FEMA 23(R)/(1)/2026-RB dated 22 September 2026: rbi.org.in.
• RBI, press release of 16 January 2026 on the Regulations: rbi.org.in.