Foreign Exchange Management (Export and Import of Goods and Services) (Amendment) Regulations, 2026 (Updates)
1. Notification No. and Date
Notification No. FEMA 23(R)/(1)/2026-RB dated September 22, 2026, published in the Official Gazette of India (Extraordinary) – Part III, Section 4, on September 24, 2026.
2. Subject / Title of Notification
Foreign Exchange Management (Export and Import of Goods and Services) (Amendment) Regulations, 2026 — amending the principal Notification No. FEMA 23(R)/2026-RB dated January 13, 2026.
3. Effective Date
October 1, 2026.
4. Key Amendments
(a) Reduction of Period under Regulation 5(1) – Clauses (a) and (b)
The period specified in clauses (a) and (b) of sub-regulation (1) of Regulation 5 of the principal regulations has been reduced from fifteen months to nine months. Exporters are accordingly required to realise and repatriate export proceeds within the revised period of nine months.
(b) Reduction of Period under First Proviso to Regulation 5(1)
The period stipulated under the first proviso to sub-regulation (1) of Regulation 5 has been reduced from eighteen months to twelve months. This revised timeline of twelve months shall now apply as per the terms of the said proviso.
(c) Treatment of Exporters on the Caution List as on September 30, 2026
A new proviso has been inserted at the end of Regulation 13 of the principal regulations. Exporters who are on the Caution List as on September 30, 2026, pursuant to orders issued by the Reserve Bank under Regulation 16 of the Foreign Exchange Management (Export of Goods & Services) Regulations, 2015, shall continue to be governed by the said order until such time as the exporter is removed from the Caution List.
(d) Powers of Authorised Dealers for Pre-October 1, 2026 Transactions
A new Regulation 20 has been inserted in the principal regulations. Authorised Dealers are now empowered to handle transactions related to the export and import of goods and services, as well as merchanting trade, undertaken prior to October 1, 2026, which hitherto required approval of the Reserve Bank of India under:
the Foreign Exchange Management (Export of Goods and Services) Regulations, 2015;
Master Direction – Export of Goods and Services (FED Master Direction No. 16/2015-16, dated January 1, 2016, as updated till July 17, 2026); and
Master Direction – Import of Goods and Services (FED Master Direction No. 17/2016-17, dated January 1, 2016, as updated till January 12, 2026).
5. Practical Implication / Action Point
Members advising exporters should note the tightened repatriation timelines effective October 1, 2026, and ensure clients review their outstanding export receivables against the revised nine-month and twelve-month periods under Regulation 5. For exporters on the Caution List as on September 30, 2026, existing RBI orders remain operative until formal removal from the list. Authorised Dealers may now exercise delegated powers for pre-October 1, 2026 transactions that previously required RBI approval — no separate RBI application will be required for such cases going forward.
