RBI Curtails Export Proceeds Realisation Period To Nine Months: FEMA 23(R) Amendment Explained

The Reserve Bank of India has issued the Foreign Exchange Management (Export of Goods and Services) (First Amendment) Regulations, 2026, which significantly tightens the time allowed to realise and repatriate export proceeds into India.

Through this amendment, Regulation 9 of the Foreign Exchange Management (Export of Goods and Services) Regulations, 2015 has been modified to reduce the export realisation period from fifteen months to nine months.

This change directly impacts all exporters who are required, under FEMA, to bring export earnings back into India within a prescribed time frame.

Statutory Power Under FEMA

The amendment has been notified by the Reserve Bank of India in exercise of powers conferred by:

  • Section 7 of the Foreign Exchange Management Act, 1999
  • Section 8 of the Foreign Exchange Management Act, 1999
  • Section 47(2) of the Foreign Exchange Management Act, 1999

These provisions collectively empower RBI to frame and amend regulations relating to export of goods and services and realization of foreign exchange.

The base framework to which this amendment relates is:

  • Foreign Exchange Management (Export of Goods & Services) Regulations, 2015
    • Notified as Notification No. FEMA 23(R)/2015-RB dated January 12, 2016
    • Commonly referred to as the Principal Regulations

Notification Details

Key particulars of the latest amendment are as follows:

  • Title: Foreign Exchange Management (Export of Goods and Services) (First Amendment) Regulations, 2026
  • Notification No.: F. No. FEMA 23(R)/(8)/2026-RB
  • Issuing Authority: Reserve Bank of India (Foreign Exchange Department), Central Office
  • Place and Date: Mumbai, 5th June, 2026
  • Effective Date: From the date of publication in the Official Gazette

Important: The amended time limit applies prospectively from the date of publication in the Official Gazette and is not linked to the internal date of the RBI notification alone.

What Has Changed In Regulation 9?

Earlier Position Under Regulation 9

Under the Principal Regulations, Regulation 9 laid down the time period within which export proceeds had to be:

  1. Realised (i.e., actually received from the overseas buyer), and
  2. Repatriated to India (i.e., brought into India in an authorised manner)

Originally, the time limit prescribed in:

  • Regulation 9(1)
  • Regulation 9(2)(a)

was “fifteen months” from the date of export.

Revised Position After 2026 Amendment

The First Amendment Regulations, 2026 expressly substitute the time limit as under:

  1. In Regulation 9(1):

    • The expression “fifteen months” is replaced with “nine months”

  2. In Regulation 9(2)(a):

    • Again, the expression “fifteen months” is replaced with “nine months”

As a result, the new standard period for realisation and repatriation of export earnings is now nine months from the date of export, unless any specific relaxation or special dispensation is granted under FEMA by RBI or the Central Government.

Key Takeaway: Exporters must now ensure that all export receivables (subject to permitted exceptions) are realised and brought into India within nine months from the date of export, instead of the earlier fifteen-month window.

Impact On Exporters And Authorised Dealers

Core Compliance Obligation

Every assessee engaged in export of goods or services must now align commercial and banking arrangements to conform to the nine-month realisation requirement. This includes: