|
FEMA Compliance Changes for Export of Goods and Service from 01/10/2026
by
STVAT Consulting
Reserve Bank of India (RBI) has notified on 22/09/2026 the Foreign Exchange Management (Export and Import of Goods and Services) (Amendment) Regulations, 2026 which is effective from 1 October 2026.
The amendment to Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026 broadly relate to reduced export realization timelines, treatment of exporters on the caution list and delegation of powers to Authorised dealer.
Brief details of amendments Regulation wise is as follows:
Regulation 5 - Time Period for Realization of Exports
Export proceeds for goods and services must be realized within 9 months. Exports invoiced and/or settled in INR must be realized within 12 months
Compliance Change – Regulation 5
|
Particulars |
Earlier |
Amended |
|
Goods export realization
|
15 months |
9 months
|
Recommended Rate
|
Service export realization |
15 months |
9 months |
|
INR invoiced/settled export realization |
18 months |
12 months |
Regulation 13 - Unrealised Exports
Regulation 13 required exporters whose export proceeds remained unrealized beyond the permissible period to export only against Full advance payment or Irrevocable Letter of Credit
Compliance Change – Regulation 13
 Clarifies transitional treatment of existing Caution List exporters
No automatic migration to the new regime
Earlier restrictions continue till removal from Caution List.
Regulation 20 - Powers to Authorized Dealers
This new Regulation delegates more powers to Authorised Dealers of certaion matters that earlier required RBI Approval
Regulation 3. Declaration of exports
Common Export Declaration Form (EDF) framework is specified for software exports and export of services; Software is specifically included in the definition of services, with STPI recognized as a specified authority.
Small value invoices (up to ₹10 lakh) get simplified EDPMS closure process through declaration.
Other Service Exports like Call Centre, BPO, Consulting, ITES etc. are now required to furnish an EDF.
Compliance Impact for Call Centres
|
Particulars |
Earlier FEMA requirement |
New FEMA requirement |
|
Export declaration
|
No comprehensive EDF system |
EDF mandatory
|
Recommended Rate
|
Monitoring |
Mainly banking records |
EDF + EDPMS monitoring |
|
Realisation period |
Older FEMA timelines |
9 months |
|
Small invoices |
Limited relief |
Simplified closure up to ₹10 lakh |
While the amended regulation recognizes STPI as a specified authority for software exports it does not explicitly state that SOFTEX is discontinued. The regulation only mandates EDF filing for software exports and other export of services.
Accordingly, exporters should verify bank/STPI operating procedures during transition, but from a FEMA regulatory perspective the new declaration mechanism is EDF
The most significant compliance shift for software companies, call centres, ITES entities and Global Capability Centres ( GCCs)is that export transactions are now brought into a common EDF → EDPMS → export realization monitoring framework.
Export of Goods
While the export declaration through EDF continues, the framework is simplified.
Compliance Impact for Goods Exporters
|
Compliance Area |
Earlier |
After Amendment |
|
Realisation timeline
|
15 months |
9 months
|
Recommended Rate
|
INR export timeline |
18 months |
12 months |
|
Small-value closure |
More documentation |
Declaration-based |
|
Set-off |
Restricted |
Wider flexibility |
|
Third-party receipts |
Limited guidance |
Expressly permitted |
|
RBI approvals |
More cases with RBI |
AD bank empowered |
Click to View FEMA Export – Import Amendment Regulations, 2026 dated 22/09/2026
Click to View FEMA Export – Import Regulations 2026 dated 13/01/2026 as Amended up to September 22, 2026
Date : 07/10/2026
|
