FEMA export realisation: 9 months now, 15 from 1 October 2026.

A mid-year RBI amendment quietly pulled the export-realisation window back to 9 months through 30 September — before the new FEMA 2026 regulations push it to 15 (or 18) months from 1 October.

If you've been told two different answers to "how long do I have to realise export proceeds," you've likely been reading about two different rules that are both technically in force right now. That's not an error on anyone's part — RBI genuinely changed the window twice within the same year, and the two changes take effect on different dates.

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), up from the earlier norm.

Then, on 5 June 2026, RBI issued the Foreign Exchange Management (Export of Goods and Services) (First Amendment) Regulations, 2026 (Notification No. FEMA 23(R)/(8)/2026-RB) — but this one amended the old 2015 Export Regulations, not the new 2026 ones. As reported by multiple law-firm trackers, it substituted "nine months" for "fifteen months" in Regulation 9, reverting the realisation period back to 9 months for exports invoiced between 5 June and 30 September 2026 — the gap period before the new 2026 Regulations take over.

Net effect: right now, an export invoice dated anywhere from 5 June through 30 September 2026 carries a 9-month realisation deadline. An export invoiced from 1 October 2026 onward gets 15 months (18 for INR-denominated exports) under the new regulations. Same exporter, same client, different deadline — depending purely on which side of 1 October the invoice falls.

Who this actually affects

This matters most to GCCs, IT/BPO service exporters, and outsourcing businesses invoicing overseas clients on a recurring basis — exactly the businesses that carry export receivables across financial-year boundaries as a matter of course. A services company invoicing a US or UK client in August 2026 is working against a 9-month clock (roughly May 2027); the same company invoicing the same client in October is working against a 15-month clock (roughly January 2028). Getting the applicable deadline wrong on even a handful of invoices creates a real FEMA compliance-reporting gap with your AD bank, not just a bookkeeping inconvenience.

What to check now

• Tag every outstanding export invoice by its invoice date, not its shipment or delivery date — the realisation clock and the applicable regulation both key off invoice date.
• For invoices dated before 30 September 2026, confirm your AD bank's EDF/softex filing reflects the 9-month deadline, not an assumed 15-month one.
• Build the 1 October cutover into your receivables ageing review now, so invoices straddling the transition don't get missed at quarter-end.

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 31 August 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.