FEMA export realisation stays at 9 months — 15-month relaxation reversed before 1 October 2026.

RBI's 22 September 2026 amendment pulled back the planned 15/18-month relaxation before it ever took effect — the export realisation period stays at 9 months (12 for rupee trade) from 1 October, with the clock now running from shipment, invoice or sale date depending on the export type.

If you were planning around a 15-month export-realisation window from 1 October 2026, that plan is now wrong. RBI reversed it before it ever took effect. The period stays at 9 months — it does not rise to 15.

What changed, and when

On 13 January 2026, RBI notified the Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026 — a full rewrite of India's decades-old trade regulations, effective 1 October 2026. Among other changes, it set the realisation-and-repatriation period for export proceeds at 15 months from the invoice date for services (18 months for exports invoiced and settled in INR).

Then, on 5 June 2026, RBI issued a First Amendment (Notification No. FEMA 23(R)/(8)/2026-RB) that reverted the old 2015 Export Regulations to a 9-month window for exports invoiced between 5 June and 30 September 2026 — a stopgap before the new 2026 Regulations were due to take over with the 15/18-month figures.

That stopgap never ended. On 22 September 2026, days before the new regime was due to commence, RBI issued a further amendment (reported as FEMA 23(R)/(1)/2026-RB, Gazetted 24 September) that rewrote the incoming 2026 Regulations themselves — replacing "fifteen months" with "nine months" and "eighteen months" with "twelve months" before they ever applied to a single invoice. The 15/18-month figures in the original January notification were never actually used.

Net effect, as of 1 October 2026: every export, regardless of which side of the cutover its invoice falls on, carries a 9-month realisation deadline (12 months for exports invoiced and settled in INR). The clock-start point does change under the new regime, though — it now runs from the date of shipment for goods, the date of invoice for services, and the date of sale for goods already sent to an overseas warehouse, rather than uniformly from the invoice date.

Who this actually affects

This matters most to GCCs, IT/BPO service exporters, and outsourcing businesses invoicing overseas clients on a recurring basis. The practical relief here is that there is no cutover to manage — an invoice dated in September and one dated in November both sit on the same 9-month (or 12-month, for INR trade) clock. What does need re-checking is the clock-start date, which has moved off a single invoice-date convention for goods and overseas-warehouse sales.

What to check now

• Stop planning around a 15-month window — it was superseded before commencement and was never operative for any real invoice.
• Re-tag outstanding export invoices by the correct trigger date for their category — shipment date for goods, invoice date for services, sale date for goods routed through an overseas warehouse — not a single uniform invoice date.
• Confirm your AD bank's EDF/softex filings reflect the 9-month (or 12-month, INR) deadline across the 1 October cutover, since there is no longer a transition window to reconcile.

How Advisory Monks Consulting helps

Our Global Outsourcing & Virtual CFO and GCC India Setup practices handle exactly this kind of cross-border receivables and FEMA-reporting reconciliation for outsourcing businesses and GCCs — mapping which invoices sit under which realisation window, and keeping AD-bank filings aligned as the rules shift under you mid-year.

This article summarises publicly reported RBI notifications as of 9 October 2026 and is not a substitute for reviewing the official Gazette notification or professional advice specific to your facts.

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