FEMA Export-Import Regulations 2026: Exporter Checklist | HRA

Legal basis: Section 47, Foreign Exchange Management Act, 1999 — Notification No. FEMA 23(R)/2026-RB — Effective: 1 October 2026. Source: RBI circular. Last reviewed by CA Harun Raaj: September 2026.

RBI notified the Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026 on 13 January 2026, and the clock is now running: the regulations take effect on 1 October 2026, replacing over 167 A.P. (DIR Series) circulars on export and import that had accumulated since 2000. Every Indian exporter, importer, and their Authorised Dealer (AD) bank needs to review current compliance processes against this single new instrument before the switch-over date.

What Is This Regulation?

FEMA (Export and Import of Goods and Services) Regulations, 2026 consolidates the entire foreign exchange compliance framework for cross-border trade under one regulation. It replaces the FEM (Export of Goods & Services) Regulations, 2015, the FEM (Import of Goods & Services) Regulations, 2015, and roughly 167 A.P. (DIR Series) circulars on export and import issued since 2000.

Key point: From 1 October 2026, a single notification — FEMA 23(R)/2026-RB — governs all export-import forex compliance, and the earlier 9-month realisation timeline is replaced with longer periods.

Key Changes That Take Effect on 1 October 2026

1. Export Declaration Form (EDF) Now Mandatory for Services

EDF is now mandatory for all service exports. Exporters must submit it within 30 days from the end of the month of invoicing. Multiple service invoices to the same counterparty may be combined into one EDF.

Action required: Service exporters who have never filed EDF must set up the filing process with their AD bank immediately.

2. Extended Export Proceeds Realisation Periods

Transaction Type	Realization Period
Export of goods	15 months from date of shipment
Export of services	15 months from date of invoice
INR-settled exports	18 months from date of invoice

The previous 9-month realisation period no longer applies.

3. Authorised Dealers Get Expanded Discretion

AD banks can now close export realisation entries up to ₹10 lakh based on the exporter's declaration alone, including bulk quarterly closures.

4. Commercial Set-Off Permitted

Exporters can now offset export receivables against import payables from the same counterparty, subject to the applicable realisation periods — a general permission replacing the earlier requirement for specific RBI approval.

5. Specified Authority Definitions Clarified

Authorities are now categorised by transaction type (goods, services, software) and jurisdiction (DTA or SEZ), removing ambiguity present in the 2015 regulations.

Who Is Affected?

All Indian exporters of goods and services, importers, Authorised Dealer banks, software service exporters (IT/ITES), SEZ units, and companies with offsetting cross-border payables and receivables need to review their processes.

What You Must Do Before 1 October 2026

Review the EDF filing process with your AD bank — mandatory for all service exporters from 1 October.
Update export contracts to reflect the new 15-month realisation period where relevant.
Assess commercial set-off opportunities with overseas counterparties who are both buyers and suppliers.
Confirm AD bank procedures for the ₹10 lakh declaration-based closure.
Review pending realisation outstandings to understand current status under old versus new timelines.

Illustrative Example

A Bengaluru-based IT services company invoiced a Singapore entity USD 50,000 in July 2026. Under the previous framework, export proceeds had to be realised within 9 months. Under FEMA 23(R)/2026-RB, effective 1 October 2026, the realisation period extends to 15 months from the invoice date. The same company, which also imports software licences from the Singapore entity, can now offset the export receivable against the import payable — a commercial set-off that previously required specific RBI approval.

I'm CA Harun Raaj, Visakhapatnam. If your export contracts, EDF filings, or realisation timelines need review before 1 October 2026, reach out and let's work through it together.

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Frequently Asked Questions

When do the FEMA Export and Import of Goods and Services Regulations 2026 take effect?

The regulations, notified under Section 47 of FEMA 1999 as Notification No. FEMA 23(R)/2026-RB on 13 January 2026, take effect from 1 October 2026. From that date they replace the FEM (Export of Goods & Services) Regulations 2015, the FEM (Import of Goods & Services) Regulations 2015, and around 167 A.P. (DIR Series) circulars.

Is the Export Declaration Form mandatory for service exports now?

Yes, under the new framework EDF is mandatory for all service exports. Exporters must submit it within 30 days from the end of the month of invoicing, and multiple invoices to the same counterparty can be combined into one EDF.

What is the new export proceeds realisation period under FEMA 23(R)/2026-RB?

Export of goods and export of services must be realised within 15 months of the date of shipment or invoice respectively, while INR-settled exports get 18 months from the date of invoice. This replaces the earlier 9-month realisation period.

Can I still set off export receivables against import payables to the same overseas party?

Yes. FEMA 23(R)/2026-RB introduces a general permission for commercial set-off between export receivables and import payables from the same counterparty, subject to the applicable realisation periods. Earlier this required specific RBI approval.

What discretion do Authorised Dealer banks have to close export entries?

AD banks can now close export realisation entries up to ₹10 lakh based solely on the exporter's declaration, including bulk quarterly closures, under the new regulations.

Do the 167 legacy A.P. (DIR Series) circulars still apply after 1 October 2026?

No. FEMA 23(R)/2026-RB consolidates and replaces the FEM (Export of Goods & Services) Regulations 2015, the FEM (Import of Goods & Services) Regulations 2015, and roughly 167 A.P. (DIR Series) circulars issued since 2000.

Do these regulations affect import payments as well as exports?

Yes. The 2026 regulations consolidate both export and import compliance under FEMA into a single instrument, so importers should also review their processes with their AD bank ahead of 1 October 2026.

What should exporters do before the 1 October 2026 deadline?

Review the EDF filing process with your AD bank, update export contracts for the new 15-month realisation period, assess set-off opportunities with counterparties who are also suppliers, and check pending realisation outstandings against old versus new timelines.

Topics:FEMA export import regulations 2026export declaration form EDF mandatoryFEMA 23(R)/2026-RBexport proceeds realisation periodRBI export complianceAuthorised Dealer bank compliancecommercial set-off FEMA

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