RBI Amends FEMA Export-Import Regulations: Export Realisation Timeline Cut to 9 Months, New Powers for Authorised Dealers from October 1, 2026

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Dated: 25.09.2026

RBI Amends FEMA Export-Import Regulations: Export Realisation Timeline Cut to 9 Months, New Powers for Authorised Dealers from October 1, 2026

The Reserve Bank of India (RBI) has notified the Foreign Exchange Management (Export and Import of Goods and Services) (Amendment) Regulations, 2026, introducing important changes to India’s foreign-exchange compliance framework governing exports and imports of goods and services.

The amendment has been issued through Notification No. FEMA 23(R)/(1)/2026-RB dated 22 September 2026 and will come into force from 1 October 2026. It amends the Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026 notified earlier on 13 January 2026.

Statutory Authority

The RBI has issued the amendment in exercise of powers conferred by Sections 7 and 8, Section 10(6), and Section 47(2) of the Foreign Exchange Management Act, 1999 (FEMA).
The amendment makes three particularly significant changes: it shortens the timelines under Regulation 5, provides transitional protection for exporters already on the Caution List, and delegates handling of certain legacy transactions to Authorised Dealers.

Export Timeline Reduced from 15 Months to 9 Months

The most significant compliance change is the amendment to Regulation 5(1).
In clauses (a) and (b), the existing words “fifteen months” have been substituted with “nine months.” Further, in the first proviso, the existing period of “eighteen months” has been replaced with “twelve months.”

The changes can be summarised as follows:

Provision	Earlier period	Revised period from 1 October 2026
Regulation 5(1)(a)	15 months	9 months
Regulation 5(1)(b)	15 months	9 months
First proviso to Regulation 5(1)	18 months	12 months

This represents a substantial compression of the regulatory timelines under Regulation 5. Businesses operating under the FEMA export-import framework should therefore revisit their internal receivables, documentation and foreign-exchange monitoring systems before the amendment takes effect.

Existing Caution-Listed Exporters to Continue Under Earlier Orders

The RBI has also inserted a proviso at the end of Regulation 13 to deal with exporters already appearing on the Caution List.
Under the amendment, exporters who are on the Caution List as on 30 September 2026, pursuant to orders issued by RBI under Regulation 16 of the Foreign Exchange Management (Export of Goods & Services) Regulations, 2015, will continue to be governed by those orders until they are removed from the Caution List.
This is essentially a transitional provision ensuring that the commencement of the new framework does not automatically disturb caution-list orders already operating against exporters.

New Regulation 20: Authorised Dealers Empowered to Handle Legacy Transactions

Another significant development is the insertion of Regulation 20 – “Powers to Authorised Dealers.”

Under the new provision, Authorised Dealers will handle transactions relating to:

export of goods and services;
import of goods and services; and
merchanting trade,

where those transactions were undertaken before 1 October 2026 and had previously required RBI approval under the earlier regulatory framework.

The notification specifically refers to transactions that previously required RBI approval under the Foreign Exchange Management (Export of Goods and Services) Regulations, 2015, the Master Direction – Export of Goods and Services (FED Master Direction No. 16/2015-16 dated 1 January 2016, updated up to 17 July 2026), and the Master Direction – Import of Goods and Services (FED Master Direction No. 17/2016-17 dated 1 January 2016, updated up to 12 January 2026).

This provision is particularly relevant for legacy export, import and merchanting-trade transactions that were initiated before the new regime takes effect.

What Changes from 1 October 2026?

The notification creates a clear regulatory transition point on 1 October 2026. The revised framework can broadly be understood as follows:

Compliance area	Amendment
Effective date	1 October 2026
Regulation 5(1)(a) & (b) timeline	15 months → 9 months
First proviso to Regulation 5(1)	18 months → 12 months
Exporters on Caution List as of 30 September 2026	Continue under existing RBI orders until removed
Pre-1 October 2026 transactions previously requiring RBI approval	To be handled by Authorised Dealers under new Regulation 20
Transactions covered by Regulation 20	Exports, imports and merchanting trade

Compliance Impact for Exporters and Importers

The reduction of the Regulation 5 timelines is likely to require closer monitoring by exporters and other regulated entities. Companies should identify transactions that may be affected by the move from 15 months to 9 months and from 18 months to 12 months, and align their internal compliance calendars accordingly.
Equally important is the new role assigned to Authorised Dealer banks for legacy transactions. Businesses with old or pending export/import matters that previously required direct RBI approval should examine whether their cases can now be handled through their AD bank under Regulation 20.
Exporters already appearing on the Caution List as of 30 September 2026 should also note that the amendment does not automatically remove or supersede their existing status. The relevant RBI order will continue to operate until the exporter is formally removed from the Caution List.

Legal Framework

The amendment forms part of the RBI’s new consolidated Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026, originally notified through Notification No. FEMA 23(R)/2026-RB dated 13 January 2026 and published in the Official Gazette on 15 January 2026.
The September amendment should therefore be read together with those principal regulations rather than as a standalone code.

Key Takeaway

The Foreign Exchange Management (Export and Import of Goods and Services) (Amendment) Regulations, 2026 introduce a materially tighter timeline under Regulation 5 while simultaneously creating transitional mechanisms for existing caution-listed exporters and legacy transactions.

For businesses, the immediate compliance priority is to prepare for the 1 October 2026 commencement date, particularly by reviewing transactions affected by the shortened 9-month and 12-month periods and identifying pending legacy matters that may now be handled through Authorised Dealers instead of requiring the earlier RBI approval route.

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Source: RBI

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