Which RBI circulars and regulations apply to service exporters in 2026?

RBI rewrote its export rulebook in 2026. Searches for "RBI circulars for exporters" still turn up lists built around the old Master Direction and dozens of circulars from 2000 to 2025, most of which stopped applying on 1 October 2026.³ This page lists what a service exporter (freelancer, agency, IT or SaaS company) needs to know about as of October 2026, grouped by topic.

For a dated timeline of changes, see RBI and DGFT changes for exporters.

What are the RBI circulars and regulations for service exporters?

The RBI circulars and regulations for service exporters are FEMA regulations, which bind exporters directly, and A.P. (DIR Series) circulars, which direct banks on how to handle export transactions.¹³

• Regulations: RBI issues regulations under section 47 of FEMA as notifications (numbered "FEMA ..."), and these bind exporters directly.¹
• Directions: RBI issues directions to Authorised Dealer (AD) banks as "A.P. (DIR Series)" circulars under sections 10(4) and 11(1) of FEMA; these tell banks how to handle your transactions.³
• Master Directions: consolidate such directions on one topic.

The difference between the instruments is who each one binds.

Who do the RBI export circulars and regulations apply to?

The RBI export regulations apply to every exporter, and the A.P. (DIR Series) circulars apply to the AD banks and payment aggregators that handle exporters' money.¹³⁶

Each row may also be touched by the separate rules on receipt channels, foreign currency accounts and purpose codes below.

How does a service exporter keep up with RBI changes?

A service exporter keeps up with RBI changes through three habits:¹

1. Amended-up-to date: bookmark the 2026 Regulations page and check its "amended up to" date; RBI updates the consolidated text when it amends the regulations.¹
2. Bank policy: read your AD bank's published export policy, which regulation 19 requires it to disclose on its website.¹
3. Outdated guides: treat any guide that cites the "Master Direction on Export of Goods and Services" as out of date for transactions from 1 October 2026.³

RBI publishes FEMA notifications and A.P. (DIR Series) circulars on its Notifications pages.¹

Which RBI rule says what for service exporters?

Two instruments form the core rulebook for service exporters from 1 October 2026, and four more cover receipt channels, accounts, aggregators and purpose codes.¹³ The dates below are from RBI's notification pages.¹²³

RBI's press release of 16 January 2026 describes the regulations as "primarily principle based" and intended to promote ease of doing business for small exporters and importers.⁹

Which RBI rules govern how export payment is received?

The FEMA (Manner of Receipt and Payment) Regulations, 2023 govern how export payment is received; regulation 4(1) of the 2026 Regulations points to them.⁴¹ For clients outside the Asian Clearing Union they allow receipts in Indian rupees or any foreign currency, through an authorised bank or authorised person.⁴

For rupee settlement through Special Rupee Vostro Accounts, A.P. (DIR Series) Circular No. 08 dated 5 August 2025 lets AD banks open such accounts for overseas correspondent banks without RBI approval.⁸ See Special Rupee Vostro accounts.

Which RBI rules govern where export earnings can be held?

The FEMA (Foreign Currency Accounts by a person resident in India) Regulations, 2015 govern where export earnings can sit.⁵

• Accounts abroad: regulation 5(CA), as substituted by FEMA 10(R)(7)/2025-RB dated 6 October 2025, lets an exporter hold a foreign currency account with a bank outside India, including in an International Financial Services Centre, for export proceeds.⁵
• Use of funds: funds must be used for imports or repatriated by the end of the next month, or three months for an IFSC bank.⁵
• EEFC account: these regulations also cover the EEFC account in India.⁵ See EEFC account benefits.

Which RBI rules cover cross-border payment aggregators?

RBI's Master Direction on Regulation of Payment Aggregator dated 15 September 2025 covers cross-border payment aggregators (PA-CBs). It sets a maximum of ₹25 lakh per inward or outward transaction and requires a PA-CB to give the exporter's AD bank the documents needed to close the export entry.⁶ See RBI PA-CB guidelines.

Which RBI circular sets purpose codes?

Purpose codes for classifying foreign exchange transactions come from RBI's FETERS reporting guidelines, revised by A.P. (DIR Series) Circular No. 84 dated 29 February 2012 with effect from April 2012.⁷ Regulation 18(2) of the 2026 Regulations still requires AD banks to report all foreign trade transactions in FETERS.¹ See purpose codes for freelancers.

What happens if a service exporter relies on superseded RBI circulars?

A service exporter who relies on superseded circulars works from rules that stopped applying on 1 October 2026: Circular No. 20's annex lists 96 export circulars and 71 import circulars superseded from that date, along with the two Master Directions.³ Those a service exporter is most likely to see cited include:

• SOFTEX simplification: A.P. (DIR Series) Circular No. 80 dated 15 February 2012 and No. 47 dated 23 October 2012.³
• Bulk SOFTEX filing: A.P. (DIR Series) Circular No. 27 dated 5 November 2015.³
• EDPMS introduction: A.P. (DIR Series) Circulars No. 101 and No. 109 of February 2014.³
• Third-party payments: A.P. (DIR Series) Circular No. 70 dated 8 November 2013 and No. 100 dated 4 February 2014.³
• e-BRCs through EDPMS: A.P. (DIR Series) Circular No. 04 dated 15 September 2017.³
• Small EDPMS entries: A.P. (DIR Series) Circular No. 12 dated 1 October 2025 on closing EDPMS entries of ₹10 lakh or less on the exporter's declaration.³¹⁰

The substance of several of these, such as declaration-based closure of small entries and third-party receipts, now sits in the 2026 Regulations themselves.¹

What are the common mistakes with RBI circulars for exporters?

The common mistakes are citing the old Master Direction, following SOFTEX circulars for new software exports, and reading an old consolidated text of the regulations.¹³

• Old Master Direction: quoting the Master Direction on Export of Goods and Services for transactions from 1 October 2026.³
• SOFTEX for software: the 2026 Regulations use the EDF for software exports too.¹
• Stale text: missing the 22 September 2026 amendment that changed the realisation period.²
• Ignoring the bank policy: regulation 19 requires each AD bank to publish its export policy on its website.¹

For how these rules apply to your own transactions, confirm with your bank or a chartered accountant.