India's FEMA 2026 export rules take effect with a nine-month realisation period

What changed

The Reserve Bank of India (RBI) notified the Foreign Exchange Management (Export and Import of Goods and Services) Regulations 2026, Notification FEMA 23(R)/2026-RB, on 13 January 2026, with effect from 1 October 2026. According to Lakshmikumaran and Sridharan, they replace the 2015 export regulations, the master directions on exports and imports and 167 circulars.

As first notified, the regulations gave exporters 15 months from shipment to realise payment for goods, or 18 months for exports invoiced or settled in Indian rupees. An amendment, Notification FEMA 23(R)/(1)/2026-RB dated 22 September 2026 and published in the Gazette on 24 September, cut these periods before they took effect. The RBI text now reads:

• 9 months from the date of shipment for goods,
• 9 months from the date of sale for goods exported to a warehouse outside India,
• 12 months from shipment for exports invoiced or settled in rupees.

King Stubb and Kasiva reports that the amendment came into force on 1 October 2026, with transitional rules for some transactions started before that date. A second amendment of 2 November 2026 changed other provisions, not these periods.

Other rules in the RBI text that touch overseas buyers:

• For goods shipped through an electronic customs port, the export declaration form is deemed filed as part of the shipping bill.
• The exporter's bank credits the receipt only after satisfying itself that the transaction is genuine, and it closes or updates the entry in its export data system (EDPMS) at the same time.
• The bank may allow receipts from a party other than the buyer if satisfied that the transaction is genuine.
• Export receivables can be set off against import payables with the same overseas buyer or supplier, or their group companies, within the realisation period.
• Advances must run through the same bank as the related export, unless both banks are informed.
• Where proceeds stay unrealised for more than a year after the due date, further exports can need full advance payment or an irrevocable letter of credit.

Who it affects

Every Indian exporter of goods, including medicine exporters, and therefore every overseas hospital, importer, distributor, CRO or NGO that pays an Indian supplier.

What it means for buyers

Long open-account terms are harder for Indian exporters to accept, because unpaid invoices must be explained to their bank after 9 months. Expect advance payment for named-patient and small orders, and letters of credit or short credit terms for larger ones. Invoicing in rupees allows 12 months, but it moves the currency risk to the buyer.

Payments should be easy to match to an invoice. When a ministry, donor, parent company or patient's family pays instead of the consignee, the exporter's bank will want to see why.

What to do now

1. Agree payment terms that settle within 9 months of shipment, or 12 months if you choose rupee invoicing.
2. Quote the proforma or commercial invoice number on every remittance.
3. Tell the exporter before payment if a third party will pay, and give its name, address and relationship to you.
4. Avoid part payments without a clear reference, since unmatched receipts delay the closure of the export record.

For payment options and documents, see how to pay for an international medicine order.