La RBI réduit à neuf mois la période de réalisation des exportations en vertu de la FEMA

The Reserve Bank of India, through Notification No. FEMA 23(R)/(8)/2026-RB dated June 5, 2026, has amended the Foreign Exchange Management (Export of Goods and Services) Regulations, 2015 (Principal Regulations) to reduce the time allowed for realisation and repatriation of export proceeds from fifteen months to nine months. The amendment will take effect upon publication in the Official Gazette.

What Changed

Regulation 9 of the Principal Regulations, which governs the time period for realisation and repatriation of export proceeds, has been amended in two places:

• Sub-regulation (1): The words “fifteen months” are substituted with “nine months.”
• Sub-regulation (2), clause (a): The words “fifteen months” are substituted with “nine months.”

This effectively compresses the window for exporters to bring back export proceeds into India from the earlier 15 months to just 9 months from the date of export. No other provisions in Regulation 9 or elsewhere in the Principal Regulations have been altered.

Who Is Affected

• Exporters of goods and services (including software, consultancy, and other services) who are required to realise and repatriate export proceeds in accordance with FEMA.
• Authorised Dealer banks (AD Category I banks) that handle export documents, track realisation, and report overdue proceeds to the RBI.
• Compliance teams in export-oriented businesses and fintech platforms facilitating cross-border trade payments must update their internal timelines, reporting systems, and customer agreements to reflect the 9-month cap.

Compliance Timeline

The amendment comes into force on the date of publication in the Official Gazette. As of June 5, 2026 (circular date), exporters should treat the 9-month period as applicable from that date. The circular does not specify a transition period; given past practice, exports already outstanding as of the effective date will likely follow the earlier 15-month regime only if the export was made before the amendment’s effective date. Compliance teams should verify with their authorised dealer banks.

Operational Impact

Exporters must now accelerate collection cycles, renegotiate credit terms with foreign buyers, and monitor ageing receivables more tightly. AD banks will need to update their internal systems to flag overdue proceeds at 9 months (instead of 15) and report non-compliance to the RBI under the existing framework. Failure to comply may result in penalties under FEMA, 1999, including potential adjudication proceedings.

All affected entities should review the full text of Notification No. FEMA 23(R)/(8)/2026-RB and coordinate with their legal and forex compliance teams to implement the tighter deadline immediately.

Source: Foreign Exchange Management (Export of Goods and Services) (First Amendment) Regulations, 2026
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