FEMA 2026: export payment deadlines for Indian businesses

An unpaid invoice is also an open compliance entry

For an Indian business exporting goods or services, an unpaid invoice is not only a cash-flow problem. It also stays open in the export monitoring system (EDPMS) that its authorised dealer bank must follow up.

The bank is required to put systems in place to monitor exports and follow up with the exporter until the proceeds are realised.

What changed on 1 October 2026

The Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026 were notified by the Reserve Bank of India on 13 January 2026. They replace the 2015 export regulations from 1 October 2026.

As notified in January, they allowed fifteen months to realise export proceeds, and eighteen months for rupee exports. An amendment of 22 September 2026 cut those to nine and twelve months before the new rules took effect.

The old 2015 regulations had already been amended in June 2026 to bring their period back from fifteen months to nine. So for most exporters the headline period stays at nine months.

Which date starts the clock

Regulation 5(1) sets the period by type of export:

Type of export	Period	The clock starts on
Goods, other than goods sent to a warehouse abroad	Nine months	The date of shipment
Services, including software	Nine months	The date of invoice
Goods exported to a warehouse outside India	Nine months	The date the goods are sold from the warehouse
Project exports	As the contract provides	The payment terms of the contract
Any of the above, invoiced or settled in Indian rupees	Twelve months	The same date as for that type of export

A single spreadsheet column labelled "export date" is not enough. The finance team needs to know the type of export and the event that starts its period.

An example for service exporters

Suppose an Indian software company raises a service invoice on 2 October 2026, in US dollars. The nine months run from the invoice date, so the period ends in early July 2027.

It does not run from the date the customer approves the invoice, or from the date the bank receives documents.

Commercial terms still eat into that period. A 90-day credit term, a disputed invoice line or a customer's routine delay can use up a large part of the nine months before anyone escalates.

Service exporters have a second date to watch. Under regulation 3(2), the Export Declaration Form (EDF) for services must be filed within 30 days from the end of the month in which the invoice is raised.

One EDF can cover all of a month's service exports. Exporters of services other than software may instead file it on or before the date payment is received.

What the bank can extend, reduce or set off

Missing the deadline is not automatically fatal, but every relief is a decision of the authorised dealer bank, made on reasons the exporter gives.

Relief	Regulation	What it requires
Extension of the realisation period	5(1), second proviso	A request citing the reasons for delay, and the bank being satisfied with them
Reduction of the export value	6	A request citing the reasons for under-realisation or non-realisation; up to ₹10 lakh per shipping bill or invoice, a declaration from the exporter is enough
Set-off against import payables	7	Payables to the same overseas buyer or supplier, or their group companies, within the realisation period or extended period
Closing small EDPMS entries	4(2), proviso	For shipping bills or invoices up to ₹10 lakh, a declaration from the exporter, which can be filed quarterly in bulk

An extension should not be assumed just because a customer has not paid. Speak to the bank early, with the invoice, the export type, the payment history and the reason for delay.

What happens if proceeds stay unrealised

Under regulation 13, if export proceeds remain unrealised for more than one year after the due date, or any extended date, the exporter may make further exports only against full advance payment or an irrevocable letter of credit.

Exporters who were on the Reserve Bank's Caution List on 30 September 2026 remain governed by the Bank's existing order until they are removed from the list.

Older export entries

The 2026 regulations replace the 2015 regulations "except in respect of things done or omitted to be done" before that date. Exports made before 1 October 2026 should not be assumed to move onto the new rules automatically.

The September amendment also lets authorised dealers deal with transactions made before 1 October 2026 that previously needed the Reserve Bank's approval (new regulation 20). Confirm the treatment of each older entry with the bank.

A finance-team review

Classify each receivable. Mark it as a goods export, service export, warehouse sale or project export.
Fix the start date. Record the shipment, invoice or warehouse sale date, or the contract terms for a project.
Note the currency. Rupee-invoiced or rupee-settled exports get twelve months; the others get nine.
Track terms and disputes. Record the credit period, part-payments and any disputed lines against the deadline.
Reconcile with the bank. Check each open EDPMS entry and, for services, that the EDF was filed on time.
Ask before the period ends. Request any extension, reduction or set-off from the authorised dealer bank, with reasons and documents.

Frequently asked questions

What is the export realisation period under FEMA from 1 October 2026?

Nine months for goods and services, and twelve months where the export is invoiced or settled in Indian rupees. Project exports follow the contract's payment terms.

When does the period start for a software or SaaS export?

On the date of the invoice. The EDF for the export must also be filed within 30 days from the end of the month in which the invoice was raised.

Can the deadline be extended?

Yes, by the authorised dealer bank, on a request from the exporter citing reasons for the delay, if the bank is satisfied with them. An extension is not automatic.

What if the overseas customer never pays?

The exporter can ask the bank to allow a reduction in the export value, citing reasons. Up to ₹10 lakh per shipping bill or invoice, a declaration from the exporter is enough.

Do the new periods apply to exports made before 1 October 2026?

Not automatically. The new regulations save things done before they replaced the 2015 regulations. Confirm the treatment of older entries with the authorised dealer bank.

The takeaway

The rule is short: nine months, or twelve for rupee exports. The work is in knowing, for every open receivable, which event started the clock and when it runs out.

Map each entry now, and speak to the bank while there is still time to give reasons.

If you are setting up an Indian entity to export, see our guide to setting up a business in India. To review an export receivables process, contact Saya & Associates.

This article provides general information as at 1 October 2026. The applicable deadline depends on the export type, the currency, the relevant date and the bank's treatment of the transaction. It is not legal or foreign exchange advice.