Compliance
The export realisation period in 2026: why it is 9 months again
Payzoplus team · Published · 4 min read
Written by the Payzoplus team. Not legal or tax advice — confirm with your CA.
You have 9 months from the invoice date (services) or the shipment date (goods) to realise and repatriate the full export value — 12 months if the export is invoiced or settled in Indian rupees. RBI briefly allowed 15 months from November 2025, reversed it in June 2026, and amended the 2026 regulations to 9 months before they took effect on 1 October 2026. Your AD bank can extend the period if it accepts your reasons.
Why do guides disagree on the realisation period?
Because RBI changed it three times in eleven months, under two sets of regulations. A guide written between November 2025 and June 2026 says 15 months, and so does anyone who read the 2026 regulations as first notified in January.
| Date | Notification | What it did |
|---|---|---|
| 13 November 2025 | FEMA 23(R)/(7)/2025-RB | Extended the period under the 2015 regulations from 9 to 15 months |
| 13 January 2026 | FEMA 23(R)/2026-RB | Notified the new 2026 regulations, effective 1 October 2026 — as first written, with 15 months (18 for rupee invoices) |
| 5 June 2026 | FEMA 23(R)/(8)/2026-RB | Cut the 2015 regulations back from 15 to 9 months |
| 22 September 2026 | FEMA 23(R)/(1)/2026-RB | Amended the 2026 regulations before they took effect: 9 months, and 12 for rupee invoices |
| 1 October 2026 | — | The 2026 regulations, as amended, came into force |
What is the realisation period now?
- Services: 9 months from the date of the invoice.
- Goods: 9 months from the date of shipment.
- Goods sent to a warehouse outside India: 9 months from the date they are sold from the warehouse.
- Exports invoiced or settled in Indian rupees: 12 months.
- Extensions: your AD bank may allow more time when you ask, citing reasons for the delay, if it is satisfied with them.
What does the timeline look like for one invoice?
| Step | Rule | For an invoice dated 14 October 2026 |
|---|---|---|
| EDF | 30 days from the end of the invoice month | By 30 November 2026 |
| Realisation (foreign-currency invoice) | 9 months from the invoice date | By 14 July 2027 |
| Realisation (rupee invoice) | 12 months from the invoice date | By 14 October 2027 |
| GST under an LUT | Payment within one year or the FEMA period, whichever is later; otherwise IGST with interest within 15 days | Payment by 14 October 2027, or IGST due by 29 October 2027 |
Dates are illustrative; your bank applies the rule to your actual invoice date.
What happens to invoices raised before 1 October 2026?
They were raised under the 2015 regulations, which have said 9 months since the June 2026 amendment. If an invoice was raised while the 15-month window applied, ask your AD bank which period it is applying to that invoice rather than assuming either — this is exactly the kind of case the bank decides.
What if my client pays late?
- Track every invoice from its date, not from when the client said they would pay.
- Part-payments count towards realisation; the balance still has to arrive inside the period.
- Talk to your AD bank before the deadline — it can extend the period if it accepts your reasons.
- For an invoice up to ₹10 lakh, the EDPMS entry can be closed on your declaration that it has been realised, in full or otherwise, and declarations can be filed quarterly in bulk.
- If a client will never pay in full, ask your bank about reducing the export value: the regulations let it accept a reduction, including non-realisation, based on your declaration.
Why does realisation matter for GST?
Under an LUT you invoice without IGST on the promise that the export completes. For services, rule 96A of the CGST Rules expects the payment within one year of the invoice, or the FEMA period including any RBI-permitted extension, whichever is later; otherwise you pay the tax with interest within 15 days after that. With FEMA at 9 months, the one-year GST clock is usually the later one. See GST on export of services.
Keep the trail
The invoice, the EDF and the remittance advice together show the export was declared and realised. Keep all three for every invoice. For how the money itself gets to you, see the complete guide to receiving international payments in India.
Frequently asked questions
What is the export realisation period in 2026?
9 months from the invoice date for services, or from the shipment date for goods, under RBI’s 2026 export regulations in force since 1 October 2026. Exports invoiced or settled in Indian rupees get 12 months.
Is the realisation period still 15 months?
No. RBI allowed 15 months from November 2025, cut the 2015 regulations back to 9 months in June 2026, and amended the 2026 regulations to 9 months before they took effect on 1 October 2026.
Can the realisation period be extended?
Yes. Your AD bank may allow an extension when you request it, citing the reasons for the delay, if it is satisfied with them. Ask before the period runs out.
What if the export is invoiced in rupees?
Where the export is invoiced or settled in Indian rupees, the realisation period is 12 months instead of 9.
Sources
The primary texts this guide was checked against, on 30 October 2026.
- RBI — Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026, Notification No. FEMA 23(R)/2026-RB dated 13 January 2026 (text as amended up to 22 September 2026)
- RBI — Foreign Exchange Management (Export and Import of Goods and Services) (Amendment) Regulations, 2026, Notification No. FEMA 23(R)/(1)/2026-RB dated 22 September 2026
- RBI — Foreign Exchange Management (Export of Goods and Services) (First Amendment) Regulations, 2026, Notification No. FEMA 23(R)/(8)/2026-RB dated 5 June 2026
- RBI — Foreign Exchange Management (Export of Goods and Services) (Second Amendment) Regulations, 2025, Notification No. FEMA 23(R)/(7)/2025-RB dated 13 November 2025
- CGST Rules, 2017 — rule 96A, export under bond or Letter of Undertaking (CBIC tax information portal)
General information, not tax or legal advice. These rules changed more than once in 2025–26: confirm the details for your business with your CA or your AD Category-I bank.
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