Direct answer: For exports within the scope of the 2026 regulations effective from 1 October 2026, the amended ordinary realisation and repatriation period is nine months, with a twelve-month proviso for goods and services invoiced or/and settled in Indian rupees. The starting date depends on the export type. An exporter’s extension request does not by itself extend the period; the Authorised Dealer must allow it on the stated grounds.
This article applies the Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026, as amended up to 22 September 2026, checked on 23 October 2026. All illustrations concern exports on or after 1 October 2026. Earlier transactions and existing bank permissions require a separate transition review; do not retrospectively overwrite their deadline records from this worksheet.
Use the September amendment, not the original January periods
The 22 September 2026 amendment, Notification FEMA 23(R)/(1)/2026-RB substituted nine months for the original fifteen-month periods and twelve months for the original eighteen-month INR period, with effect from 1 October 2026. A downloaded January version or an old ERP rule can therefore produce an incorrect due date. The RBI directions issued on 16 January 2026 also state the 1 October commencement. Keep the effective text and amendment with the deadline-control specification.
| Export category | Regulation 5 starting point | Period or governing basis |
|---|---|---|
| Goods not exported to an overseas warehouse | Shipment date | Nine months ordinarily; twelve months under the INR proviso. |
| Services, including software for these regulations | Invoice date | Nine months ordinarily; twelve months under the INR proviso. |
| Goods exported to an overseas warehouse | Date of sale from the warehouse | Nine months ordinarily; twelve months under the INR proviso. |
| Project exports | Underlying contractual payment terms | Regulation 5(1)(c); identify project status and terms. Apply any relevant INR proviso carefully. |
The proviso uses invoiced or/and settled in Indian rupees. A finance system displaying a foreign-currency invoice in its INR reporting column is not evidence of an INR invoice or settlement. Retain the contract, actual invoice denomination and settlement route. Where a project export also raises an INR-proviso issue, obtain a documented AD assessment of the applicable timeline rather than assuming the ordinary project terms automatically settle that overlap.
Keep value, time and closure decisions in separate fields
Regulation 5 concerns the full export value, or a reduced value permitted under Regulation 6, and includes qualifying set-off under Regulation 7. A commercial credit note, bad-debt provision or internal management write-off does not itself prove that the regulatory amount or bank record has been reduced. Record the AD’s decision and the resulting value to be realised.
The AD may, on a request citing reasons for delay, allow an extension if satisfied with those reasons. Retain the allowed new date, amount and scope. A customer’s revised promise, an outstanding email request or an internal dashboard comment is not the bank’s extension decision. Request relief promptly and maintain follow-up evidence; this article does not promise approval or a uniform additional number of months.
Regulation 4 requires the AD to satisfy itself about transaction genuineness and to close or update the relevant EDPMS entry with the receipt. A credit in the bank account should therefore be matched to the invoice or shipping bill and the monitoring record. Partial receipts should reduce the outstanding value without deleting the residual obligation. Record an approved set-off or reduction distinctly from cash repatriation.
Do not confuse the due date with the prolonged-overdue consequence
Under Regulation 13, if export proceeds remain unrealised beyond one year from the due date or AD-allowed extended period, further exports are to be undertaken only against full advance or an irrevocable letter of credit. This is an additional consequence, not a one-year grace period for ordinary realisation. The September amendment also preserves the governing order for exporters on the Caution List as at 30 September 2026 until removal; those cases need their own order-based review.
Design two alerts: an approaching realisation due date and a separate Regulation 13 escalation. Do not suppress the first merely because the second has not arrived. Link the receivables owner, treasury team and export desk so an unresolved overdue item does not remain a finance-only comment while new open-account exports continue.
For illustration, calendar-month dates below use the corresponding date in the resulting month. These are not bank holiday concessions or contractual extensions. An actual case needs its shipment, invoice or warehouse-sale evidence, applicable transitional position and the AD’s documented treatment.
Worked illustrations
These illustrations use fictional facts and expressly stated assumptions. Amounts are Indian rupees unless a different currency or unit is specified. They are independent examples, not findings about any actual client.
Illustrative example 1: Shipment date controls an ordinary goods export
A foreign-currency goods invoice is dated 10 October 2026 and shipment occurs on 15 October 2026. The goods are not exported to an overseas warehouse. Nine calendar months from shipment gives 15 July 2027. Using the invoice would incorrectly produce 10 July 2027.
Illustrative example 2: Service invoice date controls
A foreign-currency service invoice is raised on 31 October 2026. Nine calendar months gives 31 July 2027. A later declaration submission or a later customer acceptance entry is not substituted for the invoice anchor in this example. Declaration compliance must be monitored separately.
Illustrative example 3: Warehouse sale uses its own anchor
Goods are shipped to an overseas warehouse on 1 October 2026 and sold from that warehouse on 20 January 2027. Assume the ordinary foreign-currency rule applies. Nine months from the warehouse sale gives 20 October 2027. Do not use 1 July 2027 merely by adding nine months to the shipment.
Illustrative example 4: INR proviso changes the period
Assume a qualifying service export is invoiced in INR on 10 November 2026 and falls within the twelve-month proviso. The corresponding deadline is 10 November 2027, rather than 10 August 2027 under a nine-month calculation. A foreign-currency invoice merely translated into INR for bookkeeping would not establish these assumed facts.
Illustrative example 5: Project-export instalments follow the applicable contract
Assume a qualifying foreign-currency project export has a supported USD 100,000 payment schedule: 40% due on 30 September 2027 and 60% on 31 March 2028. The instalments are USD 40,000 and USD 60,000. Subject to the governing project terms and AD monitoring, retain those contractual dates rather than replacing both with a generic nine-month invoice clock.
Illustrative example 6: An allowed extension changes the prolonged-overdue reference
An ordinary export was due on 15 July 2027. Assume the AD validly allows an extension to 15 October 2027 and proceeds remain unrealised. The one-year anniversary of the extended date is 15 October 2028; 16 October 2028 is beyond one year for the Regulation 13 analysis. The ordinary extended due date remains 15 October 2027: the later date is not an additional permitted collection period.
Illustrative example 7: Partial receipt and approved reduction do not reset time
An export value is USD 100,000 and matched receipts total USD 60,000. The initial balance is USD 40,000. Assume the AD separately permits a USD 10,000 reduction under Regulation 6: the revised target is USD 90,000 and the remaining amount is USD 30,000. The value decision does not itself establish a new realisation deadline; verify any extension separately.
Ten-step verification table
| Step | Verification | Evidence to retain |
|---|---|---|
| 1 | Identify the transaction cohort and applicable effective regulations. | Export date, transition note and applicable permissions. |
| 2 | Classify goods, services, overseas warehouse or project export. | Contract and transaction-classification memorandum. |
| 3 | Identify the statutory date anchor. | Shipment evidence, service invoice or warehouse-sale record. |
| 4 | Test the INR proviso using actual denomination and settlement facts. | Invoice, contract and bank settlement instructions. |
| 5 | Calculate and independently check the applicable due date. | Calendar-month calculation or supported project schedule. |
| 6 | Reconcile full value, receipts and outstanding amount. | Currency-wise invoice and remittance matching. |
| 7 | Identify authorised reductions or set-offs separately. | AD decision and revised value reconciliation. |
| 8 | Request extensions with reasons and record only allowed dates as extensions. | Application, supporting facts and AD response. |
| 9 | Track Regulation 13 and any continuing Caution List order. | Due-date ageing and export-control escalation record. |
| 10 | Confirm AD monitoring-system update and retain the evidence trail. | EDPMS or bank confirmation and closure reconciliation. |
Sixteen practitioner FAQs
1. Is the ordinary period still fifteen months?
Not under the amended 2026 rule effective from 1 October 2026 addressed here. The September amendment substitutes nine months.
2. Is the INR period eighteen months?
The effective amendment substitutes twelve months. Check the invoice or settlement facts and the correct starting date.
3. Does every export use its invoice date?
No. Ordinary goods use shipment, services use invoice, and overseas-warehouse goods use the date of sale from that warehouse.
4. Does software count as a service here?
The regulations expressly include software within services for their purposes. Identify the corresponding declaration and monitoring requirements separately.
5. Does INR presentation in the ledger qualify for twelve months?
No. Bookkeeping translation alone does not establish invoicing or settlement in INR under the proviso.
6. How are project exports timed?
Regulation 5(1)(c) refers to contractual payment terms. Confirm project status, actual terms and any interaction with the INR proviso with the AD.
7. Does an extension application stop the clock?
Do not assume so. Record an extended date only when the AD has allowed the extension on the relevant facts.
8. Can a buyer’s revised payment promise replace the deadline?
It is supporting commercial evidence, not by itself an AD-allowed regulatory extension.
9. Does a partial receipt close the whole invoice?
Only the matched amount is realised. Reconcile the residual value and any separate permitted reduction, set-off or other bank treatment.
10. Does an internal bad-debt entry reduce the FEMA value?
Not by itself. Establish the applicable regulatory decision and bank record under Regulation 6 or other relevant authority.
11. Can an approved reduction automatically extend time?
No. Value reduction and time extension are separate decisions and should be recorded separately.
12. Is the Regulation 13 year a collection grace period?
No. The ordinary or allowed extended deadline remains operative. Regulation 13 addresses further exports after prolonged non-realisation.
13. What is the prescribed future-export safeguard under Regulation 13?
Where its condition applies, further exports are only against full advance or an irrevocable letter of credit. Review the exporter’s actual overdue position.
14. What about an exporter already on the Caution List?
The amendment preserves the governing order for those on the list as at 30 September 2026 until removal. Read that order separately.
15. Is bank-account credit sufficient closure evidence?
Match the receipt and confirm the AD’s update or closure of the monitoring record. Unmatched receipts can leave operational exceptions.
16. Should old invoices be recalculated using this article automatically?
No. The examples concern post-commencement exports. Review earlier transactions, transitional provisions and existing permissions before altering their records.
Conclusion
An effective export register records the legal clock, the correct value and the bank’s allowed relief independently. Apply the amended nine- and twelve-month periods to the correct anchor and escalate overdue exposures before they affect further exports.