RBI and FEMA

RBI's 15-Month Export Realisation Rule Was Reversed: What Goods Exporters Face from October 1

Author:: Editorial team, serviceexportguide.com
Verified by:: Editorial team
Published: 31 October 2026
Last modified: 31 October 2026
Reading time: 7 min read

Short answer

The FEMA (Export and Import of Goods and Services) Regulations, 2026 came into force on 1 October 2026.¹ Goods must be realised within nine months from the date of shipment.¹² The 15-month period that applied from 14 November 2025 was reversed from 5 June 2026.³⁴ At EDI ports, the EDF is deemed part of the shipping bill.¹

Applies to	Rules involved	Platforms compared	Last verified
Exporters of goods from India, including exports to warehouses abroad¹	FEMA Export and Import Regulations 2026 regulations 3, 4, 5, 6, 10 and 13, as amended by FEMA 23(R)/(1)/2026-RB; RBI Circular No. 20¹²⁵	Not applicable: this page covers the realisation rule, not payment platforms	31 October 2026

Many guides and news reports describe a "new 15-month export realisation rule" for goods exporters starting on 1 October 2026. That rule does not apply. The FEMA (Export and Import of Goods and Services) Regulations, 2026, as notified in January 2026, did set fifteen months, but an amendment dated 22 September 2026 substituted nine months before the Regulations came into force on 1 October 2026.¹² Under the old 2015 Regulations, a 15-month period applied from 14 November 2025 until it was reduced back to nine months from 5 June 2026.³⁴ This page explains what goods exporters actually face from 1 October 2026. Service exporters should read the export realisation period for services.

How do the 15-month and nine-month realisation rules compare for goods exporters?

The 15-month realisation rule for goods applied only from 14 November 2025 to 5 June 2026 under the 2015 Regulations; from 1 October 2026 the 2026 Regulations set nine months from shipment, or twelve months for rupee exports.¹²³⁴

Period	Instrument	Realisation period for goods	Best for	Source
Before 14 November 2025	2015 Regulations, regulation 9	Nine months from date of export	Checking older shipments	³
14 November 2025 to 4 June 2026	FEMA 23(R)/(7)/2025-RB dated 13 November 2025	Fifteen months	Shipments made while it applied	³
5 June 2026 to 30 September 2026	FEMA 23(R)/(8)/2026-RB dated 5 June 2026	Back to nine months	Shipments from June to September 2026	⁴
2026 Regulations as first notified, January 2026	FEMA 23(R)/2026-RB	Fifteen months (eighteen for rupee exports), replaced before taking effect	Explaining older news reports	¹²
From 1 October 2026	FEMA 23(R)/2026-RB as amended by FEMA 23(R)/(1)/2026-RB	Nine months from shipment; nine months from sale for warehouse exports; twelve months if invoiced or settled in rupees	All shipments from 1 October 2026	¹²

Clock start: for goods, the period runs from the date of shipment; for goods sent to a warehouse abroad, from the date of sale from the warehouse.¹
Project exports: the period follows the payment terms of the contract.¹

The export realisation deadline calculator works out the due date for a given start date.

Which RBI and GST rules apply to goods exporters?

The rules that apply to goods exporters from 1 October 2026 are the declaration, receipt, realisation and EDPMS provisions of the FEMA Export and Import Regulations, 2026, the IEC requirement in the Foreign Trade Policy, and zero-rating under GST.¹⁹¹¹

Rule	Best for (who it applies to)	Plain meaning	Source
Regulation 2(1)(f)	Goods exporters in the Domestic Tariff Area or an SEZ	The specified authority for goods is the Commissioner of Customs in the DTA and the SEZ Development Commissioner in an SEZ	¹
Regulation 3(1) and 3(3)	Every goods exporter	Furnish an EDF at export; at EDI ports it is deemed submitted as part of the shipping bill, and at non-EDI ports the authority forwards the authenticated EDF to the AD bank	¹
Regulation 4(2)	Exporters receiving proceeds	The AD bank credits proceeds after checking the transaction is genuine and updates EDPMS; entries up to ₹10 lakh may be closed on the exporter's declaration	¹
Regulation 5	Every goods exporter	Nine months from shipment, or from sale out of a warehouse abroad; twelve months for rupee exports; the AD bank can extend	¹²
Regulation 6	Exporters paid short	The AD bank can allow a reduction in export value, on declaration alone up to ₹10 lakh	¹
Regulation 10(1)	Exporters taking advances	Route an advance through the same AD bank, unless the change is intimated to both banks	¹
Regulation 13	Exporters with long-overdue proceeds	Unrealised for over one year past the due date means further exports only against full advance or an irrevocable letter of credit	¹
FTP 2023, paragraph 2.05	Every goods exporter	No export of goods without an IEC unless exempted; the IEC equals the PAN	⁹
IGST Act, section 16	GST-registered exporters	Exports are zero-rated and can be made under bond or LUT without IGST	¹¹¹²

For example, a Tiruppur garment exporter: ships to a Rotterdam buyer on 15 October 2026 on 90-day credit. The proceeds are due by 15 July 2027, so the 90-day term sits well inside the period.¹
For example, a Moradabad brassware seller: sends stock to a US fulfilment warehouse in November 2026. Each unit's nine months start when it is sold from the warehouse.¹

The what changed in the 2026 FEMA export rules page compares the old and new texts.

Which purpose code applies to goods exporters?

Goods export receipts are reported under the P01 group, such as P0101 for negotiated bills, P0102 for bills realised on collection and P0103 for advances.⁸ RBI introduced the current receipt codes through A.P. (DIR Series) Circular No. 84 of 29 February 2012.⁷

Code	Best for (transaction type)	Official RBI description	Source
P0101	Bills negotiated, purchased or discounted by the bank	Value of export bills negotiated / purchased/discounted etc. (covered under GR/PP/SOFTEX/EC copy of shipping bills etc.) Other than Nepal and Bhutan	⁸
P0102	Bills sent on collection, full value	Realisation of export bills (in respect of goods) sent on collection (full invoice value) Other than Nepal and Bhutan	⁸
P0103	Advance payment before shipment	Advance receipts against export contracts, which will be covered later by GR/PP/SOFTEX/SDF other than Nepal and Bhutan	⁸
P0108	Merchanting trade	Goods sold under merchanting / Receipt against export leg of merchanting trade*	⁸
P0109	Exports to Nepal and Bhutan	Export realisation on account of exports to Nepal and Bhutan, if any	⁸

These descriptions are from HDFC Bank's reproduction of the RBI list.⁸ Your bank records the code on the inward remittance, so tell it which shipment each payment covers.

What does a goods exporter need to do differently from October 1?

From 1 October 2026, a goods exporter needs to track each shipment against a nine-month deadline, route advances through one bank and keep EDPMS entries closed; the declaration itself still travels with the shipping bill at EDI ports.¹

Diary nine months from each shipping bill: treat any article quoting fifteen months as out of date.¹²
Ask about older shipments: get your bank's written view on shipments made while the 15-month period applied.¹³
Chase payment early: request an extension from your AD bank before the nine months end if a buyer is late.¹
Close small entries: for shipping bills up to ₹10 lakh, ask whether the bank will close EDPMS entries on your declaration.¹
Keep advances with one bank: route advance receipts through the same AD bank or tell both banks about a change.¹

What documents follow each export shipment?

Each goods shipment should leave a shipping bill carrying the EDF, an EDPMS entry at your bank, a bank advice or FIRC for the receipt and a self-certified e-BRC.¹¹⁰

Document	Best for	What it is	Who issues it	Source
IEC	Every goods exporter	Importer-Exporter Code, same as PAN, updated online every year in April to June	DGFT, generated online	⁹
Shipping bill with EDF	Each consignment	EDF deemed part of the shipping bill at EDI ports; forwarded to the AD bank from non-EDI ports	Exporter files with Customs	¹
EDPMS entry	Tracking realisation	The AD bank enters the EDF within five working days and marks it off once the value is realised	AD bank	¹
e-BRC	GST refunds and export incentives	Self-generated by the exporter on the DGFT portal from the bank's IRM data	Exporter, on the DGFT portal	¹⁰
LUT	Exporting without IGST	FORM GST RFD-11, filed for each financial year	Exporter, on the GST portal	¹²

See what is EDPMS for how banks track open entries.

What changes in 2026 for goods exporters?

The main changes in 2026 for goods exporters are the new FEMA export rules in force from 1 October 2026, the nine-month realisation period, and RBI Circular No. 20 replacing the old Master Direction and export circulars.¹²⁵

New FEMA export rules: the Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026 came into force on 1 October 2026 and replaced the 2015 Regulations.¹
Nine months from shipment: the realisation period for goods is nine months from shipment, after the 15-month period was reversed.¹²⁴
One directions circular: RBI A.P. (DIR Series) Circular No. 20 of 16 January 2026 gives banks the directions under the 2026 Regulations from 1 October 2026.⁵⁶
Caution list carry-over: exporters on RBI's caution list on 30 September 2026 stay under those orders until removed.¹
Income-tax Act, 2025: in force from 1 April 2026; tax year 2026-27 runs from 1 April 2026 to 31 March 2027.¹³

How the transition applies to shipments made before 1 October 2026 is a question for your AD bank, so get its answer in writing and check GST and tax points with a chartered accountant.¹

How did we verify this?

We checked this page against the sources below on 31 October 2026. Read our methodology or report an error.

Frequently asked questions

Is the RBI 15-month export realisation period for goods effective from October 1, 2026?+

No. The 2026 Regulations as first notified said fifteen months, but FEMA 23(R)/(1)/2026-RB dated 22 September 2026 substituted nine months before the rules took effect on 1 October 2026.¹² Goods exported from that date must be realised within nine months from the date of shipment.¹

When did the export realisation period go back from 15 months to 9 months?+

FEMA 23(R)/(7)/2025-RB of 13 November 2025 extended the period to fifteen months under the 2015 Regulations.³ FEMA 23(R)/(8)/2026-RB dated 5 June 2026 reduced it back to nine months.⁴ The 2026 Regulations keep nine months from 1 October 2026.¹² Older articles quoting fifteen months describe that earlier, temporary period.

What does the Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026 change for goods exporters?+

The 2026 Regulations replaced the 2015 export regulations on 1 October 2026 and cover exports and imports in one set of rules.¹ For goods, the EDF goes to the Commissioner of Customs in the Domestic Tariff Area, and realisation is due within nine months from shipment.¹²

Which realisation period applies to goods shipped while the 15-month rule was in force?+

The 2026 Regulations supersede the 2015 rules except for things done before that supersession, and they do not spell out which period applies to each older shipment.¹ Ask your AD bank in writing which period it is applying to shipments made between November 2025 and June 2026.

How long do I have to realise goods sent to an Amazon or overseas warehouse?+

For goods exported to a warehouse outside India, regulation 5(1)(b) gives nine months from the date of sale of the goods from the warehouse.¹ If the export is invoiced or settled in Indian rupees, the period is twelve months.¹² Each unit sold from the warehouse therefore starts its own nine-month clock, so keep sales reports that show the date of each sale.

Can my bank extend the nine-month export realisation period for goods?+

Yes. Under regulation 5 of the 2026 Regulations, your AD bank can extend the realisation period if it is satisfied with your reasons.¹ Under regulation 6, it can also allow a reduction in export value, on declaration alone for shipping bills or invoices up to ₹10 lakh.¹

What happens if goods export proceeds are unrealised for more than a year after the due date?+

Regulation 13 says further exports can then be made only against full advance payment or an irrevocable letter of credit.¹ Exporters already on RBI's caution list on 30 September 2026 stay under those orders until removed.¹ Your AD bank tracks overdue proceeds through open EDPMS entries, which it marks off only after the export value is realised.¹

This page is general information for Indian service exporters, not tax or legal advice. Rules change and outcomes depend on your facts, so confirm with a chartered accountant before acting.

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