The Reserve Bank of India (“RBI”) vide circular dated September 22, 2026, has through powers conferred by Section 7, Section 8, sub-section (6) of Section 10 and sub-section (2) of Section 47 of the Foreign Exchange Management Act, 1999 (42 of 1999), notified Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026 (“2026 Regulations”). The amendment Regulations will come into force on October 01, 2026.
Amendments
I. The principal change is a reduction in the period for realisation and repatriation of export proceeds. The period prescribed under Regulation 5(1) of the 2026 Regulations has been reduced from 15 months to 9 months, while the special period prescribed in the first proviso has been reduced from 18 (eighteen) months to 12 (twelve) months.
II. The amendment also introduces a new Regulation 20, under which Authorised Dealer (“AD”) banks are empowered to handle certain pre-October 01, 2026, export, import and merchanting trade transactions which, under the earlier regulatory framework, would have required RBI approval.
Implications
The change is particularly noteworthy because the 2026 Regulations had contemplated a significant extension of the export realisation period compared with the traditional nine-month framework. The amendment therefore represents a substantial policy adjustment immediately before commencement of the new regulations. In practical terms, exporters that had structured their receivables and customer payment arrangements around a 15-month window will need to reassess those arrangements. The nine-month period also means that businesses should not treat the October 01, 2026, transition as providing an additional 15 (fifteen) month window for outstanding export receivables.
The Amendment Regulations also reduce the period specified in the first proviso to Regulation 5(1) from 18 months to 12 months. This is important because the 18 month period was intended to provide additional time in specified circumstances under the new framework. Following the amendment, the corresponding period will now be 12 months. Further, AD banks are given a clear mandate over legacy approval cases. The practical priorities are to update systems and contracts now and to rely on the AD bank's extension power where business needs require longer terms.
Please find below key amendments at glance effective from October 01, 2026:
|
Particulars |
Position under 2026 Regulations |
Position from 1 October 2026 |
|---|---|---|
|
General export realisation period |
15 months |
9 months |
|
Special/extended realisation period under first proviso to Regulation 5(1) |
18 months |
12 months |
|
Transactions covered by the transitional AD bank |
Certain pre-October 01, 2026 transactions could require RBI approval under the legacy framework |
AD Banks may handle specified pre-October 01, 2026 export, import and merchanting trade transactions which previously required RBI approval. |
Please find attached a copy of the Amendment here.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
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