RBI FEMA Export-Import Amendments Now in Effect: Key Changes for Businesses

The Foreign Exchange Management (Export and Import of Goods and Services) (Amendment) Regulations, 2026, are now in force from 1 October 2026. The Reserve Bank of India (RBI) has introduced changes in FEMA to prescribed periods under Regulation 5, transitional treatment for exporters on the Caution List, and the handling of certain legacy export, import, and merchanting trade transactions by Authorised Dealers.

The changes are relevant to businesses engaged in cross-border trade and to Authorised Dealers responsible for processing foreign-exchange transactions.

What has changed for exporters under the 2026 FEMA amendments?

The amendments now in force introduce three key changes:

1. Specified periods under Regulation 5 have been shortened
2. Exporters who were on the Caution List as of 30 September 2026 remain subject to their existing RBI orders until they are removed from the list
3. Authorised dealers can handle specified transactions undertaken before 1 October 2026, where such transactions previously required RBI approval under the earlier FEMA framework

These provisions establish the compliance framework now applicable to businesses following the commencement of the amended regulations.

Regulation 5: Export proceeds must be realised within shorter periods

The FEMA amended Regulation 5(1) reduces the prescribed period for realisation and repatriation of export proceeds. The amendment replaces the existing 15-month period with nine months under clauses (a) and (b). It also reduces the period specified in the first proviso from 18 months to 12 months.

In practice, under the amended framework, the general period for realising and repatriating export proceeds is nine months, with the applicable starting point depending on the type of export. For goods, the period runs from the date of shipment, while for services it runs from the date of invoice. Goods exported to an overseas warehouse are subject to a nine-month period from the date of sale from the warehouse. Exports invoiced and/or settled in Indian rupees are subject to the 12-month period specified in the first proviso.

CLICK HERE: Import-Export Procedures in India: 2026 Edition

Caution list: Existing RBI orders continue to apply

The amended FEMA Regulation 13 provides transitional treatment for exporters who were already on the Caution List immediately before 1 October 2026.

Exporters who were on the Caution List as of 30 September 2026, under RBI orders issued pursuant to Regulation 16 of the Foreign Exchange Management (Export of Goods & Services) Regulations, 2015, continue to be governed by those orders until they are removed from the Caution List.

Authorised dealers can handle specified legacy transactions

The amended regulations introduce Regulation 20, “Powers to Authorised Dealers.”

The provision enables authorised dealers to handle specified transactions involving export and import of goods, services and merchanting trade, where the transactions were undertaken before 1 October 2026 and previously required RBI approval under the earlier FEMA framework.

This covers transactions governed by the Foreign Exchange Management (Export of Goods & Services) Regulations, 2015, and relevant RBI Master Directions on the export and import of goods and services.

What this means for businesses

Companies with outstanding pre-October 1 transactions should identify cases where RBI approval was previously required and assess whether the transaction now falls within Regulation 20.

Where applicable, businesses can work with their Authorised Dealers to process such transactions under the new provision.

Importantly, Regulation 20 concerns specified legacy transactions undertaken before 1 October 2026. It does not constitute a blanket removal of RBI approval requirements for transactions undertaken on or after 1 October.

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Compliance actions for businesses affected by the 2026 FEMA amendments

With the amended regulations now in force, businesses should implement the provisions relevant to their cross-border transactions.

Exporters: Review FEMA Regulation 5 timelines

Exporters should review transactions covered by Regulation 5 and apply the revised nine-month and 12-month periods for realisation and repatriation of export proceeds, as applicable. Internal compliance calendars and receivables-monitoring systems should be updated accordingly.

Businesses with legacy transactions: Review outstanding cases

Businesses involved in the export or import of goods, export or import of services, or merchanting trade should identify transactions undertaken before 1 October 2026 that remain pending or require regulatory action.

Where a transaction previously required RBI approval, the business should consult its authorised dealer to determine whether Regulation 20 now permits the Authorised Dealer to handle the transaction.

Exporters on the caution list: Continue existing obligations

Exporters who were on the Caution List as of 30 September 2026 should continue complying with the applicable RBI orders until they are removed from the list.

Finance, treasury, trade, and compliance teams: Update procedures for FEMA export and import regulations

Companies affected by these provisions should update their FEMA compliance processes to reflect:

• Revised Regulation 5 periods for applicable export transactions
• Continuing obligations under existing caution list orders
• The Authorised Dealer’s ability to handle specified pre-October 1 legacy transactions

This distinction is important because Regulation 5 primarily affects exporters; the Caution List provision applies specifically to exporters already on the list, while Regulation 20 can affect businesses involved in exports, imports, services, and merchanting trade with qualifying pre-October 1 transactions.