RBI's new FEMA Export-Import Regulations 2026: what changed from 1 October.

FEMA 23(R)/2026-RB folds export and import rules into one framework for the first time and widens the Export Declaration Form to services — what actually changed from 1 October 2026.

RBI retired its three-decade-old export rulebook on 1 October 2026. The Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026 — FEMA 23(R)/2026-RB, notified on 13 January 2026 and made effective from the first of this month — supersede the 2015 export regulations and, for the first time, pull import-side directions into the same single instrument. Nothing fundamentally new is being restricted; what has moved is where the paperwork lives, and which transactions finally get a lighter touch.

One rulebook for both sides of the invoice

Until now, exporters worked off the 2015 export regulations while importers followed a scattered set of RBI directions issued over the years, with authorised dealer banks reconciling two frameworks for a single trading relationship. FEMA 23(R)/2026-RB consolidates both into one regulation plus one set of directions — as reported by multiple legal commentators, the most significant rewrite of India's foreign-exchange trade framework in over a decade. Every reference back to the RBI under the new regime is routed through the PRAVAAH portal rather than ad hoc correspondence.

The Export Declaration Form widens to services

The EDF, previously anchored in goods trade, now expressly covers services, including software — the SoftEx-style declaration service exporters used is being folded into the same EDF regime. We set out what the EDF actually requires and who it catches in our EDF primer; that guidance now sits inside this wider 2026 framework rather than a standalone circular.

Small exports get a lighter close-out

Entries in EDPMS and IDPMS — the RBI's systems for tracking whether an export or import has actually been paid for — can now be closed on a declaration basis for values up to ₹10 lakh, instead of requiring full supporting documentation. For a services exporter billing in small, frequent invoices rather than one large shipment, this removes a disproportionate amount of paperwork relative to the money involved.

Set-off and third-party payments, now written into the rules

The new regulations expressly provide for set-off between export and import dues and for third-party receipts and payments — arrangements groups with intercompany flows or marketplace-style collections have long needed but previously had to structure around rather than rely on as a stated rule. Import-payment monitoring is now tied primarily to contractual terms rather than a rigid RBI timeline.

What stayed the same

SEZ units keep their existing arrangement, with the Development Commissioner continuing as the authority for export declarations inside the zone. And the headline realisation period — how long you have to bring export proceeds home — was not loosened to 15–18 months as the January notification first suggested; a 22 September 2026 amendment pulled that back before the new framework ever took effect. We cover that reversal, and the 9-month (12-month for rupee trade) period that actually applies from 1 October, in our note on the realisation-period rollback.

Who should care

Anyone invoicing a foreign client from an Indian entity — a GCC, an India subsidiary of a foreign parent, or a founder exporting SaaS or services — now files under this consolidated regime rather than the 2015 rules, and should confirm with their authorised dealer bank that EDF, EDPMS/IDPMS closure and set-off claims are being processed under the new provisions rather than the superseded ones.

How Advisory Monks Consulting helps

We track which RBI framework actually governs a client's export or import flow — easy to get wrong in a transition year — and set up the EDF, EDPMS/IDPMS and set-off paperwork so a lighter-touch rule is actually used rather than left on the table. Our cross-border tax and FEMA team and GCC desk handle this as part of ongoing export compliance, not a one-off filing.

General information, not advice. Several details here rely on secondary legal commentary rather than the RBI's own consolidated master direction; confirm specifics with your authorised dealer bank before relying on them. Position as reported as at 16 October 2026.

This note is general guidance, not tax or legal advice. Positions depend on your specific facts — speak with a partner before acting.