/ FEMA · Exporters · Updated 2026-10-30

FEMA Export Rules From 1 October 2026, nine months to get paid.

New FEMA export and import regulations took effect on 1 October 2026. Exporters of goods and services, including freelancers and IT companies billing foreign clients, must receive payment within nine months (12 months if invoiced in rupees). For services the clock starts on the invoice date, and the Export Declaration Form is filed monthly, within 30 days of the month-end. Many sources still say 15 months; RBI changed that on 22 September 2026.

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Written by CA Durgesh Chavda

Chartered Accountant (ICAI) · Founder, Bharat Quantum Prospera · NRI taxation, US incorporation, transaction due diligence, forensic audit, AEO, cross-border tax · LinkedIn

/ Calculator

Check your deadlines.

Inputs

Dates are calendar dates.

What did you export? Software, IT, consulting, design and other services are all services.

Invoice date (services) / shipment or sale date (goods) The date the clock starts.

Invoiced or settled in Indian rupees? Rupee exports get 12 months instead of 9.

Receive payment by

Realisation period-

EDF due (services)-

Rules-

/ The new realisation periods

Nine months, not fifteen.

The principal Regulations (Notification FEMA 23(R)/2026-RB, 13 January 2026) originally set 15 months. Before they took effect, RBI amended them (Notification FEMA 23(R)/(1)/2026-RB, 22 September 2026) to nine months, and 12 months for rupee exports. Several articles still quote 15 months; that figure never came into force.

Export	Receive proceeds within	Clock starts
Services, including software	9 months	Invoice date
Goods	9 months	Date of shipment
Goods to a warehouse abroad	9 months	Date of sale from the warehouse
Any of the above invoiced or settled in INR	12 months	Same as above
Project exports	As per contract	As per contract

Your AD bank can extend the period on a reasoned request.

/ EDF for service exporters

Now a monthly filing.

Service exporters furnish the Export Declaration Form (EDF) to their AD bank within 30 days from the end of the month in which the invoice is raised.
One EDF can cover all exports to one or more clients in that month.
For services other than software, the EDF can instead be submitted on or before the date the payment is received.
The AD bank can extend the time on a reasoned request.

/ Other changes worth knowing

From the 2026 Regulations.

For exports up to INR 10 lakh per invoice or shipping bill, banks can close EDPMS entries, and allow reduction or non-realisation, on the exporter's declaration.
Export receivables can be set off against import payables with the same overseas party, group companies or associated enterprises.
Third-party receipts and payments are allowed once the AD bank is satisfied the transaction is genuine.
Merchanting trade: both legs within six months.
If proceeds stay unrealised well beyond the permitted period, future exports may need full advance payment or an irrevocable letter of credit.

/ What freelancers and IT exporters should do

Practical checklist.

Put a nine-month payment term (or shorter) in client contracts and chase overdue invoices early.
Diary the EDF date each month and file one consolidated EDF with your bank.
Keep FIRA/FIRC or bank advices for every receipt; you need them for GST export (LUT) and income tax.
Ask your bank for an extension before the nine months end if a client is delayed.
Exports made before 1 October 2026 follow the earlier rules; confirm the position with your AD bank.

Sources: TaxUpdate: 22 September 2026 amendment; TaxGuru: FEMA export-import regulations 2026.

Last updated: 30 October 2026. Confirm against the RBI notifications and your AD bank's SOP before acting.

/ Ready when you are

Exporting services to foreign clients?

Email durgesh@bharatquantumprospera.com or WhatsApp +91 78018 87130. Fixed-scope quote within 48 hours.

Get a firm quote → WhatsApp Durgesh

FAQ

Common questions, answered.

What is the export realisation period from 1 October 2026?

Nine months for goods and services, or 12 months if the export is invoiced or settled in Indian rupees, under the FEMA (Export and Import of Goods and Services) Regulations, 2026 as amended on 22 September 2026.

Is the export realisation period 15 months?

No. The January 2026 Regulations said 15 months, but RBI amended this to nine months (12 months for rupee exports) on 22 September 2026, before the Regulations took effect on 1 October 2026.

When does the nine-month period start for services?

From the invoice date. For goods, it runs from the date of shipment, or from the date of sale for goods sent to a warehouse abroad.

When is the EDF due for export of services?

Within 30 days from the end of the month in which the invoice is raised. One EDF can cover all of that month's exports. Services other than software may submit it on or before the date payment is received.

Does this apply to freelancers?

Yes. Freelancers and consultants who invoice foreign clients are exporting services and should track the nine-month realisation period and EDF requirements with their bank.

Can BQP help with export compliance?

Yes: EDF and EDPMS clean-up, extension requests, GST LUT and refunds, and FIRA reconciliation. Email durgesh@bharatquantumprospera.com or WhatsApp +91 78018 87130. Fixed-scope quote within 48 hours.