Export Payment Realisation in India: The 9-Month Rule from 1 October 2026 (FEMA Explained)

Why you still see 15 months: the live tracker

The deadline moved three times in under a year. This table sets out each change in order, newest first, so you can tell which rule applied to which shipment.

The rule in one table

The rule is simple once you know which clock applies to your kind of export.

Source: Regulation 5 of the FEMA 2026 regulations as amended by FEMA 23(R)/(1)/2026-RB, and trade and legal summaries of the framework. Confirm details with your AD bank.

How the clock works

Goods start on shipment, services on invoice

For goods, the nine months run from the date of shipment. For services, they run from the invoice date, not the date you are paid, so a client on long payment terms uses up your window before you know it. Ask your AD bank which date it records in its export data monitoring entry, because that entry is what the bank tracks.

Worked examples

Calendar-month arithmetic, with the last day of the month used where the date does not exist. Your AD bank’s records decide the exact date.

Your contract cannot override the deadline

If your contract allows a foreign-currency buyer twelve months to pay, FEMA still expects the money within nine, unless your AD bank approves an extension. Either keep credit terms inside the deadline or arrange the extension early.

If you shipped before 1 October 2026

Nine months has applied since 5 June 2026. Shipments made between 14 November 2025 and 4 June 2026 were under the fifteen-month rule at the time. Ask your AD bank how it treats those open entries now.

What counts as realised

• Money received through your AD bank into your account, in the permitted way. Receipts are matched to your export entry by the bank, and the bank issues the e-BRC.
• Set-off (Regulation 7). With your AD bank’s permission, export receivables can be set off against import payables to the same overseas party or its group or associate companies, within the realisation period or the extended period. The 2026 text also allows set-off across goods and services.
• Payments from third parties. They are permitted in specified cases, subject to conditions and AD bank scrutiny. Get your bank’s approval before you agree to them.
• Advances. Money received before shipment is also tracked, and the bank will expect the matching export to be completed. Agree the handling with your bank.
• Not the same as invoicing. An invoice, a buyer’s acceptance or a letter of credit is not realisation. The money has to reach your bank account.

Service exporters: the monthly EDF

From 1 October 2026, services and software are run through the same system as goods. Trade and legal summaries of the new regulations report that:

• You file an Export Declaration Form (EDF) every month with your AD bank, reportedly within 30 days after the end of the month in which you raised the invoice. Your bank may allow more time for a valid reason.
• The bank records the entry in the export data monitoring system (EDPMS), and the realisation clock is nine months from the invoice date.
• SOFTEX is no longer used. One EDF replaces it for software and services exports.
• For an SEZ unit, the EDF goes to the Development Commissioner.
• After you realise the money, the e-BRC is issued through the DGFT system.

Tell your bank that you export services, and ask whether it wants the EDF on paper, by email or through its portal. List every export invoice from October onwards with its buyer, currency and service code.

If you cannot meet the deadline

1. Act before expiry. An extension request made after the deadline is harder. Set a reminder at six months.
2. Write to your AD bank with the reasons: a buyer dispute, financial difficulty, rejected goods, a government or force majeure event, or a banking delay.
3. Attach evidence: invoice, shipping bill, bill of lading, buyer correspondence, your reminder letters and any buyer acknowledgement of the debt.
4. Get the approval in writing and note the new date against the entry.
5. Consider other routes with your bank: set-off against imports from the same party, a reduction in value for a genuine short payment, or a write-off where recovery has failed. Reports mention a simplified self-declaration route for small invoices up to ₹10 lakh; confirm the threshold and conditions with your bank.
6. Check your insurance. If you hold ECGC cover, notify the claim within the policy’s timelines.

What happens if you miss it

• The entry stays open and is flagged. Banks monitor open entries, and unresolved items surface in their reporting.
• Limits on future exports. According to trade summaries of Regulation 13, if proceeds stay outstanding for more than one year beyond the due date or the extended period, further exports may be permitted only against full advance payment or an irrevocable letter of credit.
• Caution List. RBI can place exporters with long-outstanding receivables on a Caution List. The September amendment keeps existing Caution List orders for those on it on 30 September 2026 until they are removed.
• FEMA proceedings. A contravention can lead to penalty proceedings under Section 13 of FEMA, which allows a penalty of up to three times the sum involved where it can be quantified, and to compounding. Past delay does not disappear because the money later arrives.

This is a general summary, not legal advice. Ask your AD bank or a qualified professional about your own case.

Build a receivables process

Eight habits that keep you inside the deadline

1. Record the clock start date and the deadline for every shipment on the day you invoice.
2. Set three reminders: six months, 60 days and 30 days before the deadline. The calculator above makes a calendar file.
3. Agree payment terms with a buffer for banking time and transit.
4. Match every receipt to its invoice and its entry in your bank’s system each month.
5. Send documented reminders to late buyers, and keep copies.
6. Start extension conversations with your bank at the 60-day checkpoint, not the last week.
7. Verify new buyers before you ship. See Guide 2 for a checklist you can adapt for overseas buyers.
8. Review all open entries with your bank every quarter.

For payment terms, FEMA basics and the full export journey, see Guide 1: getting paid.

Mistakes to avoid

• Planning around the old 15-month figure, which replaced nine months for only part of 2025 and 2026.
• Counting service deadlines from the payment date instead of the invoice date.
• Agreeing longer credit terms in a contract and assuming FEMA follows them.
• Asking for an extension after the deadline instead of before.
• Accepting payment from an unrelated third party without your bank’s approval.
• Not telling your bank that you export services, and so missing the monthly EDF.
• Letting small unpaid invoices sit open instead of closing them through set-off or write-off.
• Treating a letter of credit or buyer acceptance as payment received.
• Ignoring old open entries from before October 2026.
• Relying on a blog’s figures without checking the notification date.

Printable realisation checklist

• Every open export entry listed with its clock start date and deadline
• Reminders set at six months, 60 days and 30 days for each entry
• Payment terms in every contract fit inside nine months (twelve for rupee exports)
• My AD bank has told me how it wants the monthly EDF for services (if I export services)
• Bank procedure noted for extensions, set-off, third-party receipts and write-offs
• Open entries from before 1 October 2026 reviewed with my bank
• Documents for each shipment filed: invoice, shipping bill or EDF, transport document, buyer correspondence
• ECGC or other insurance cover checked for open-account buyers
• New buyers verified before shipment
• e-BRC received and filed for every closed entry

Print this page for your compliance file. The layout prints cleanly.

Dates to bookmark

Glossary

Official sources directory

Always confirm on the issuing source. These are the notifications and portals this guide relies on.

Notifications referred to in this guide

Portals

Verified from the text and summaries of the RBI notifications as reproduced by legal and tax publishers, and from bank and trade guidance. Always confirm on the RBI website and with your AD bank.

Frequently asked questions

Knowledgebase series and change log

Coming next: RoDTEP 2026 status and how to claim, and the export documents checklist.

Change log

We re-check this page whenever RBI issues a notification on export realisation. If you spot something outdated, tell us through the contact page.

Disclaimer. LinksIndia is an independent directory and not a government body or a bank. This guide is general information and not legal, tax or financial advice. Rules change by notification, and banks apply them through their own procedures. Confirm with your AD bank or a qualified professional before acting.