Export Realisation Period Under FEMA for Goods and Services (2026)

Written by CA Nandini Hasija, Krystal7 Consultants. Last updated 23 October 2026.

The export realisation period under FEMA is nine months from 1 Oct 2026. Regulation 5(1) of FEMA 23(R)/2026-RB runs it from the shipment date for goods and the invoice date for services. Exports invoiced or settled in Indian rupees get twelve months. Your AD bank can extend either period on a reasoned request. Between 14 Nov 2025 and 5 Jun 2026 the 2015 regulations allowed fifteen months, so check older invoices separately.

This page covers the period for goods, services, warehouse and project exports, and how EDPMS tracks it. It also covers extension, set off, reduction and write off, the consequences of non realisation, and the GST refund link.

What is the export realisation period under FEMA?

The export realisation period is nine months from 1 Oct 2026. Regulation 5(1)(a) of the Export and Import Regulations, 2026 runs it from the shipment date for goods and the invoice date for services. Rupee invoiced or rupee settled exports get twelve months.

Regulation 5(1) of the 2026 Regulations sets each period:

Type of export	Period to realise and repatriate	Runs from	Rule
Goods (other than to an overseas warehouse)	Nine months	Date of shipment	Regulation 5(1)(a)
Services, including software	Nine months	Date of invoice	Regulation 5(1)(a)
Goods exported to a warehouse outside India	Nine months	Date of sale from the warehouse	Regulation 5(1)(b)
Project exports	As per the contract's payment terms	Contract	Regulation 5(1)(c)
Any of the above invoiced or settled in INR	Twelve months	Shipment, invoice or warehouse sale date, as above	First proviso to regulation 5(1)

The amount to realise is the full export value. Regulation 5(1) also counts a reduced value allowed under regulation 6, and a realisation by set off under regulation 7. The second proviso lets the AD bank extend the period if it is satisfied with the exporter's reasons.

The duty rests on section 8 of the Foreign Exchange Management Act, 1999. A resident owed foreign exchange must "take all reasonable steps to realise and repatriate" it. It must do so within the period RBI specifies. Regulation 5 is that period.

How did the realisation period change in 2025 and 2026?

RBI changed the period in three amending notifications between November 2025 and September 2026. The first raised it from nine to fifteen months under the 2015 regulations from 14 Nov 2025. It cut the period back to nine on 5 Jun 2026. The 2026 Regulations first said fifteen months, and an amendment of 22 Sep 2026 made it nine before they started.

Date	Instrument	Regulation	Change
13 Nov 2025 (Gazette 14 Nov 2025)	FEMA 23(R)/(7)/2025-RB	2015 Regulations, regulation 9(1) and 9(2)(a)	Nine months raised to fifteen months
13 Nov 2025	FEMA 23(R)/(7)/2025-RB	2015 Regulations, regulation 15	Shipment against an export advance: one year raised to three years
13 Jan 2026 (Gazette 15 Jan 2026)	FEMA 23(R)/2026-RB, original text	2026 Regulations, regulation 5	Fifteen months; eighteen months for INR exports; in force from 1 Oct 2026
5 Jun 2026	FEMA 23(R)/(8)/2026-RB	2015 Regulations, regulation 9(1) and 9(2)(a)	Fifteen months cut back to nine months
22 Sep 2026 (Gazette 24 Sep 2026)	FEMA 23(R)/(1)/2026-RB	2026 Regulations, regulation 5	Fifteen months cut to nine; eighteen months cut to twelve
1 Oct 2026	FEMA 23(R)/2026-RB comes into force	Whole regulations	2015 Regulations and the Export Master Direction superseded

So the fifteen and eighteen month periods in the January 2026 text never applied to any export. The footnotes on the RBI page record the old words: "Prior to substitution, the words 'nine months' read as 'fifteen months'".

This page first went out on 28 Jan 2026. At that date, the 2015 regulations allowed fifteen months, and the 2026 Regulations had just been notified with fifteen and eighteen months. The section "What has happened since" below sets out the later changes.

How does the period work for export of services?

For services, the nine months run from the invoice date. Regulation 3(2) also requires an Export Declaration Form (EDF) within 30 days from the end of the month in which the invoice is raised. One EDF can cover all services exported in a month. Services other than software may file the EDF on or before receipt of payment.

The EDF replaced the SOFTEX form for software from 1 Oct 2026. Our guides on the EDF and the end of SOFTEX cover the form.

An Indian subsidiary that bills its foreign parent each month for services is the most common case we see. The clock runs on each invoice separately. A March invoice is due by December, even if the parent pays on a quarterly cycle.

The old 2015 regulations had a similar rule for software. The Explanation to regulation 9 deemed the "date of export" of software in non physical form to be the invoice date. The 2026 Regulations apply the invoice date to all services.

How does EDPMS track export realisation?

The Export Data Processing and Monitoring System (EDPMS) holds each shipping bill and services EDF. Your AD bank enters non EDI shipping bills and services EDFs within five working days of receiving them, under regulation 18(1). It marks off each entry once the export is realised, set off or reduced.

Regulation 18 sets out the bank's duties:

Bank duty	Rule
Enter EDFs from non EDI ports in EDPMS within five working days	Regulation 18(1)(a)
Enter services EDFs within five working days of receipt	Regulation 18(1)(b)
Enter all inward remittances for exports in EDPMS	Regulation 18(1)(e)
Monitor open entries and follow up with the exporter for documents	Regulation 18(1)(f)
Mark off the entry after realisation	Regulation 18(1)(g)
Close an export advance entry where no export took place and refund is not possible	Regulation 18(1)(i), on request
Report all foreign trade transactions in FETERS	Regulation 18(2)

Small entries are easier. The first proviso to regulation 4(2) covers a shipping bill or invoice of up to INR 10,00,000. The bank can close that entry on the exporter's declaration that payment was realised. The exporter can give the declaration per transaction or quarterly in bulk.

Your bank links each inward remittance to the EDF. Quote the invoice number on the remittance and ask the parent to do the same. Our guide on FIRC and eBRC explains the bank records that prove realisation.

Can the AD bank extend the export realisation period?

Yes. The second proviso to regulation 5(1) lets the AD bank extend the period on the exporter's request. The bank must be satisfied with the reasons for delay. The regulation sets no cap on the length. Regulation 19(1)(b) requires each bank to cover extensions in its published internal policy.

Under the old Master Direction on Export of Goods and Services, extensions had fixed conditions. Paragraph C.20 of the Master Direction applied until 30 Sep 2026:

• Extension up to six months at a time, irrespective of invoice value.
• The bank had to be satisfied the exporter could not realise the proceeds for reasons beyond its control.
• Beyond one year from export, the exporter's total outstanding could not exceed USD 1 million or 10 percent of its average export realisations over the preceding three financial years, whichever was higher.
• Where the exporter had sued the buyer abroad, the limit did not apply.
• Other cases needed prior approval from RBI's Regional Office.

The new rule is simpler, but it is not automatic. Ask before the period ends, in writing, with evidence. Give the buyer's correspondence, any dispute papers and a revised payment date.

Extension rule	Until 30 Sep 2026 (Master Direction C.20)	From 1 Oct 2026 (regulation 5)
Who grants	AD bank within limits; RBI beyond them	AD bank
Length	Six months at a time	Not fixed
Value test	USD 1 million or 10 percent of average realisations over three years, whichever higher, beyond one year	None in the regulation
Policy	Bank internal guidelines	Published policy under regulation 19

Regulation 19(2) gives you an appeal. The bank's policy must have an escalation process and an appeal decided at a higher internal level.

Can export receivables be set off against import payables?

Yes. Regulation 7 lets the AD bank allow a set off of export receivables against import payables. The other party must be the same overseas buyer or supplier, or its group or associate companies. The set off must happen within the realisation period or any extension. The bank then closes the matching EDPMS and IDPMS entries.

For a subsidiary that sells services to its parent and buys licences from it, set off cuts the number of remittances. The old paragraph C.26 of the Export Master Direction had 15 conditions, including a bar on setting goods against services. Regulation 7 does not repeat that bar.

Our batch guide on netting off export receivables against import payables covers the conditions banks still apply.

Can an exporter write off or reduce unrealised export value?

Yes, through the AD bank. Regulation 6 lets the bank allow a reduction in export value on the exporter's reasons for under realisation or non realisation. For export value up to INR 10,00,000 per shipping bill or invoice, the exporter's declaration is enough.

The old rules had percentage limits. Paragraph C.23 of the Export Master Direction measured them against the export proceeds realised in the previous calendar year:

Write off route	Until 30 Sep 2026 (para C.23)	From 1 Oct 2026 (regulation 6)
Self write off, exporter other than a Status Holder	5% of previous calendar year realisations	No percentage limit; AD bank allows a reduction on reasons
Self write off, Status Holder exporter	10%	Same as above
Write off by the AD bank	10%	Same as above
How limits combine	Counted cumulatively	Not applicable
Age of the bill	Outstanding for more than one year	No age test in the regulation
Small values	Separate rules	Declaration route up to INR 10,00,000 per shipping bill or invoice

Under the old paragraph C.23.2, the exporter also had to be a regular customer of the bank for at least six months. Some categories, such as goods destroyed or an insolvent buyer, could be written off without any limit under paragraph C.23.3 on evidence.

A reduction is not free. Income tax, GST and transfer pricing still apply to the value you invoiced. If the buyer is your parent, a reduction can look like a non arm's length adjustment. Document the commercial reason.

What happens if export proceeds are not realised in time?

Three things follow. Regulation 13 restricts further exports once proceeds stay unrealised for more than one year after the due date. Section 13 of FEMA allows a penalty of up to three times the sum involved. GST refunds and IGST exemptions linked to the export can be recovered.

Regulation 13 says the exporter "shall undertake further exports only against receipt of full advance or an irrevocable Letter of Credit". The one year runs from the due date or any extended date the bank allowed. For a services subsidiary paid on open account by its parent, this rule can stop its business model.

The old Exporters' Caution List survives only in transition. The proviso to regulation 13 keeps exporters on the list on 30 Sep 2026 under RBI's orders until they are removed. Under the old paragraph C.28, a caution listed exporter could ship only against advance payment or an irrevocable letter of credit.

Consequence	Trigger	Rule
Exports only against full advance or irrevocable LC	Proceeds unrealised more than one year after due date or extension	Regulation 13, FEMA 23(R)/2026-RB
Penalty up to three times the sum involved, or up to INR 2,00,000 if not quantifiable; up to INR 5,000 a day if continuing	Contravention of the regulations	Section 13(1), FEMA
Bank follow up and possible reference to the Directorate of Enforcement	Open EDPMS entries; doubtful transactions	Regulation 18(1)(f); A.P. (DIR Series) Circular No. 20 of 16 Jan 2026
Recovery of the GST refund on goods exports	Proceeds not realised within the FEMA period, including extension	Rule 96B, CGST Rules; read the current rule for the repayment date and interest
Pay IGST with interest on LUT services exports	Payment not received within the period in rule 96A	Rule 96A(1)(b), CGST Rules

Compounding is the route to settle a contravention with RBI. Our FEMA compounding guide covers the application.

How does export realisation affect GST refunds?

GST links refunds and zero rating to receipt of export proceeds. Rule 96B of the CGST Rules, 2017 deals with recovery of a refund of unutilised input tax credit, or of IGST paid, on export of goods where proceeds are not realised within the FEMA period, including extensions. Section 2(6)(iv) of the IGST Act treats a service as exported only if payment comes in convertible foreign exchange or RBI permitted rupees.

We do not reproduce rule 96B here, because its repayment date, interest and exceptions can change by notification. Read the current rule on the CBIC GST rules page, with any later amendment, before you plan a repayment. Settle three points from the rule text:

• When the repayment falls due after the FEMA period or the extended period ends.
• How interest is charged on the amount repaid.
• What the rule says where RBI writes off the requirement to realise the proceeds.

The third point matters under the 2026 Regulations. Regulation 6 has the AD bank, not RBI, allow a reduction in export value. On our reading, a reduction allowed under regulation 6 should be treated like a write off. A GST officer could read the rule narrowly. Keep the bank's reduction letter with the refund file.

For services exported under a Letter of Undertaking, rule 96A(1)(b) applies. Notification No. 12/2024-Central Tax of 10 Jul 2024 substituted it. It runs fifteen days after the expiry of one year from the invoice date, or of the period allowed under FEMA including any RBI permitted extension, whichever is later. The Commissioner may allow a further period.

Miss it, and the exporter pays the IGST with interest. With a nine month FEMA period, the one year date usually decides, unless the bank grants a long extension.

Two CBIC circulars help service exporters. Circular No. 202/14/2023-GST of 27 Oct 2023 treats INR received through a Special Rupee Vostro Account as meeting section 2(6)(iv). Circular No. 78/52/2018-GST of 31 Dec 2018 covers part of the price retained abroad with RBI permission.

Our guides on GST on export of services, LUT filing and the GST refund of unutilised ITC cover the GST side in full.

Which rules apply to exports made before 1 Oct 2026?

Exports shipped or invoiced before 1 Oct 2026 were made under the 2015 Export Regulations and the Export Master Direction. The preamble to the 2026 Regulations saves things done before the supersession of the 2015 Regulations. Regulation 20 makes AD banks handle older transactions that earlier needed RBI approval. The 2015 Regulations set the period for those exports, subject to the open point below.

The hard question is the fifteen month window. Exports made between 14 Nov 2025 and 5 Jun 2026 had a fifteen month period when they were made. FEMA 23(R)/(8)/2026-RB of 5 Jun 2026 cut regulation 9 of the 2015 Regulations back to nine months from the date of its Gazette publication. The notification has no transition or saving clause. We found no RBI circular or press release that says whether those exports keep fifteen months. So the written law does not answer the question.

Our practical view is to plan on the shorter date. Ask your bank which due date it has recorded in EDPMS for each open invoice from that window. Where it shows nine months and the money is late, ask for an extension in writing before the date passes. For an export made before 1 Oct 2026, regulation 20 lets the AD bank decide cases that earlier needed RBI approval, under the 2015 Regulations and the Export Master Direction.

Does the period apply to export advances?

The realisation period applies to exports already made. For advances received before export, regulation 10(1) requires one AD bank for the advance and later realisations. The exporter may switch banks if it tells both. Interest on an advance cannot exceed the trade credit all in cost ceiling under regulation 10(4).

The 2015 regulations had a time limit for shipping against an advance. Regulation 15 required shipment within three years of the advance. FEMA 23(R)/(7)/2025-RB had raised that from one year on 13 Nov 2025. As we read regulation 10(1) of the 2026 Regulations, it sets no equivalent shipment deadline. Where no export happens and a refund is not possible, regulation 18(1)(i) lets the bank close the advance entry on a reasoned request.

For the import side, where an Indian company pays an overseas supplier first, our guide to advance remittance for import under FEMA covers the limits and IDPMS reporting.

What changed in 2026

The 2026 Regulations came into force on 1 Oct 2026 with a nine month period and twelve months for rupee exports. Extensions, reductions and set offs moved to the AD bank. They replaced the 2015 Regulations and the Export Master Direction. Earlier in 2026, the 2015 period went back from fifteen to nine months.

Rule	Old position	New position	Date	Instrument
Realisation period, goods and services	Fifteen months (from 14 Nov 2025 under the 2015 Regulations)	Nine months	5 Jun 2026 (2015 Regulations); 1 Oct 2026 (2026 Regulations)	FEMA 23(R)/(8)/2026-RB; FEMA 23(R)/2026-RB as amended by FEMA 23(R)/(1)/2026-RB
INR invoiced or settled exports	Eighteen months in the January 2026 text, never in force	Twelve months	1 Oct 2026	FEMA 23(R)/(1)/2026-RB of 22 Sep 2026
Overseas warehouse	Fifteen months from shipment (2015 regulation 9(1)(a))	Nine months from sale from the warehouse	1 Oct 2026	Regulation 5(1)(b)
Extension	AD bank within C.20 limits, else RBI	AD bank on reasons, no cap	1 Oct 2026	Second proviso to regulation 5(1)
Write off	5% or 10% of previous year realisations	Reduction on reasons; declaration up to INR 10,00,000	1 Oct 2026	Regulation 6
Set off	15 conditions in para C.26, no goods against services	Same party or group, within the period	1 Oct 2026	Regulation 7
Non realisation	Caution listing by RBI	Exports only against advance or LC after one year past due	1 Oct 2026	Regulation 13
Services declaration	SOFTEX for software within 30 days of invoice	EDF within 30 days from end of invoice month	1 Oct 2026	Regulation 3(2)
Bank policy	Internal guidelines	Published policy with appeal; no penalty charges	1 Oct 2026	Regulation 19

What has happened since the publish date

At the 28 Jan 2026 publish date, the 2015 Regulations allowed fifteen months. The 2026 Regulations, notified on 13 Jan 2026, said fifteen months and eighteen for rupee exports from 1 Oct 2026. RBI then reversed course.

FEMA 23(R)/(8)/2026-RB of 5 Jun 2026 cut the 2015 period to nine months. FEMA 23(R)/(1)/2026-RB of 22 Sep 2026 cut the 2026 periods to nine and twelve months. The Gazette published it on 24 Sep 2026. The 2026 Regulations came into force on 1 Oct 2026 with those shorter periods.

Worked example

Take a hypothetical Indian subsidiary that supplies IT services to its US parent under a Letter of Undertaking. It raises an invoice of USD 250,000 on 15 Oct 2026, billed in US dollars. We use an assumed rate of INR 88 to USD 1 and an assumed IGST rate of 18 percent for the arithmetic.

1. EDF. The invoice month is October 2026. The EDF is due within 30 days from 31 Oct 2026, so by 30 Nov 2026.
2. FEMA due date. Nine months from the 15 Oct 2026 invoice date is 15 Jul 2027.
3. GST date under rule 96A. One year from the invoice is 15 Oct 2027. Fifteen days after that is 30 Oct 2027. That is later than the FEMA date, so 30 Oct 2027 applies for GST.
4. Part payment. The parent pays USD 200,000 on 1 Jun 2027. It disputes USD 50,000.
5. Set off. The subsidiary owes the parent USD 30,000 for a software licence. The bank allows a set off under regulation 7, which leaves USD 20,000 open (50,000 minus 30,000).
6. Reduction or extension. USD 20,000 is INR 17,60,000 (20,000 × 88). That is above INR 10,00,000, so a declaration alone will not do. The subsidiary must either get an extension under regulation 5 or a reduction under regulation 6 on reasons.
7. GST cost if unpaid. Suppose the USD 20,000 is still unpaid on 30 Oct 2027. IGST at 18 percent on INR 17,60,000 is INR 3,16,800, plus interest under section 50.

Item	Date or amount	Rule
Invoice	15 Oct 2026, USD 250,000 (INR 2,20,00,000)	Regulation 5(1)(a)
EDF due	30 Nov 2026	Regulation 3(2)
FEMA realisation due	15 Jul 2027	Regulation 5(1)(a)
Received from parent	USD 200,000 on 1 Jun 2027	Regulation 18(1)(g)
Set off against licence fee	USD 30,000	Regulation 7
Balance open	USD 20,000 (INR 17,60,000)	Regulations 5 and 6
GST deadline under LUT	30 Oct 2027	Rule 96A(1)(b)
IGST if never paid	INR 3,16,800 plus interest	Rule 96A(1)(b)

Now take a goods exporter. It ships goods worth USD 120,000 on 10 Nov 2026 and claims a refund of unutilised input tax credit. The FEMA due date is 10 Aug 2027. If USD 40,000 is still unpaid then and the bank has not extended the period, the refund linked to that one third (40,000 ÷ 120,000) is exposed to recovery under rule 96B. Read the rule for the repayment date and interest before 10 Aug 2027 arrives.

The lesson is timing. Ask for the extension or reduction before 15 Jul 2027 in the first case, and before 10 Aug 2027 in the second. A bank decision made after the GST date does not stop the tax demand.

Common mistakes

1. Planning on fifteen months. RBI cut the 2015 period back to nine months on 5 Jun 2026, and the fifteen months never applied under the 2026 Regulations. Fix: diarise nine months from shipment or invoice, twelve for rupee exports.
2. Counting from payment terms instead of the invoice. A 120 day credit term does not move the FEMA clock. Fix: count from the invoice date for services and the shipment date for goods.
3. Asking for an extension after the due date. A late request weakens the case, and the GST clock keeps running. Fix: apply before the period ends, with evidence.
4. Leaving small entries open. Entries up to INR 10,00,000 can close on a declaration. Fix: send the quarterly bulk declaration under regulation 4(2).
5. Netting with the parent informally. An adjustment without the bank leaves both EDPMS and IDPMS entries open. Fix: ask the bank to record a set off under regulation 7.
6. Missing the EDF for monthly services. Regulation 3(2) needs one within 30 days from the end of each invoice month. Fix: file one EDF per month for all invoices.
7. Ignoring the GST link. Rule 96B and rule 96A both look to the FEMA period. Fix: track GST dates on the same sheet as FEMA due dates.
8. Writing off parent receivables without support. A reduction can raise transfer pricing questions. Fix: record the commercial reason and the bank's reduction letter.

To check open EDPMS entries or an extension request, write to Krystal7 through our FEMA compliance service.

Checklist for realising export proceeds on time

1. Record the shipment date or invoice date for every export.
2. Calculate the due date at nine months, or twelve for rupee invoiced exports.
3. File the services EDF within 30 days from the end of each invoice month.
4. Ask the buyer to quote the invoice number on every remittance.
5. Download the EDPMS outstanding statement from your bank every month.
6. Send the quarterly declaration for entries up to INR 10,00,000.
7. Ask the bank to record any set off against import payables under regulation 7.
8. Request an extension in writing before the due date for any delayed invoice.
9. Apply for a reduction under regulation 6 where part of the value will not come.
10. Check rule 96A and rule 96B dates for each export with a GST refund or LUT.
11. Keep the bank's extension or reduction letter with the GST refund file.
12. Escalate under the bank's regulation 19 appeal route if the bank refuses.

A single receipt of INR 50 crore or more also needs an LEI. See our guide on LEI for cross border transactions.

Frequently Asked Questions

What is the export realisation period in India in 2026?+

From 1 Oct 2026, it is nine months under regulation 5(1)(a) of FEMA 23(R)/2026-RB. It runs from the shipment date for goods and the invoice date for services. Exports invoiced or settled in Indian rupees get twelve months. The AD bank can extend the period on a reasoned request from the exporter.

Is the export realisation period nine months or fifteen months?+

Nine months. FEMA 23(R)/(7)/2025-RB raised the period to fifteen months under the 2015 Regulations from 14 Nov 2025. FEMA 23(R)/(8)/2026-RB cut it back to nine months on 5 Jun 2026. The 2026 Regulations, in force from 1 Oct 2026, also say nine months after the amendment of 22 Sep 2026.

What is the realisation period for export of services?+

Nine months from the invoice date, under regulation 5(1)(a) of the 2026 Regulations. It is twelve months if the service is invoiced or settled in Indian rupees. The exporter must also file an EDF within 30 days from the end of the invoice month, under regulation 3(2).

Can the AD bank extend the export realisation period?+

Yes. The second proviso to regulation 5(1) lets the AD bank extend the period at the exporter's request. The bank must be satisfied with the reasons. The regulation sets no fixed cap. Until 30 Sep 2026, paragraph C.20 of the Master Direction limited extensions to six months at a time with value tests.

What are the write off limits for unrealised export proceeds?+

From 1 Oct 2026, regulation 6 has no percentage limit. The AD bank may allow a reduction in export value on the exporter's reasons. A declaration is enough up to INR 10,00,000 per shipping bill or invoice. The old limits were 5 percent self write off, 10 percent for Status Holders and 10 percent by the bank.

What happens if export proceeds are not realised within nine months?+

The export becomes overdue and the bank follows up under regulation 18(1)(f). Regulation 13 then applies if proceeds stay unrealised beyond one year after the due date. Further exports are allowed only against full advance or an irrevocable letter of credit. Section 13 of FEMA allows a penalty of up to three times the sum involved.

Can export receivables be set off against import payables?+

Yes. Regulation 7 of the 2026 Regulations lets the AD bank allow a set off against import payables. The party must be the same overseas buyer or supplier, or its group or associate companies. It must happen within the realisation period or any extension. The bank then closes the related entries in EDPMS and IDPMS.

What is EDPMS in export realisation?+

EDPMS is the Export Data Processing and Monitoring System, an RBI platform. AD banks record each shipping bill and services EDF in it and match inward remittances against them. Under regulation 18(1)(g), the bank marks off an entry once the export is realised. Open entries show as overdue after the realisation period.

Is the realisation period different for exports to an overseas warehouse?+

Yes. Under regulation 5(1)(b) of the 2026 Regulations, the nine months run from the date of sale from the warehouse outside India. Shipment does not start the clock. Under the 2015 Regulations, regulation 9(1)(a) allowed fifteen months from shipment for goods sent to an RBI permitted overseas warehouse.

Does the realisation period apply to project exports?+

Project exports follow the payment terms of the contract, under regulation 5(1)(c) of the 2026 Regulations. There is no fixed nine month period. Regulation 15 lets the AD bank permit project receipts and payments under the contract once it is satisfied the project is genuine.

How does export realisation affect a GST refund?+

Rule 96B of the CGST Rules covers recovery of refunds of unutilised ITC or IGST on goods exports where proceeds are not realised within the FEMA period, including extensions. Read the current rule 96B on cbic-gst.gov.in for the repayment date, the interest and any exception for a write off by RBI.

When must IGST be paid on services exported under LUT if payment is late?+

Rule 96A(1)(b) of the CGST Rules applies. The exporter pays IGST with interest if payment does not arrive within fifteen days after the expiry of one year from the invoice date, or of the FEMA period including any extension, whichever is later. With a nine month FEMA period, the one year date usually decides.

Does INR settlement through a Vostro account count as export realisation?+

Yes, if RBI permits it. Regulation 5 gives twelve months for exports invoiced or settled in rupees. For GST, CBIC Circular No. 202/14/2023-GST of 27 Oct 2023 covers services. It treats INR from a Special Rupee Vostro Account as meeting section 2(6)(iv) of the IGST Act.

Which period applies to exports made between November 2025 and June 2026?+

Exports made between 14 Nov 2025 and 5 Jun 2026 had a fifteen month period under the 2015 Regulations when made. The 5 Jun 2026 amendment has no transition clause. Ask your AD bank which due date it records in EDPMS, and seek an extension under regulation 5 if the nine month date has passed.

Do I need RBI approval for a delayed export from before 1 Oct 2026?+

Usually not. Regulation 20 of the 2026 Regulations makes AD banks handle export transactions undertaken before 1 Oct 2026 that earlier needed RBI approval. They decide under the 2015 Regulations and the Export Master Direction as updated to 17 Jul 2026. Start with the bank that holds the EDPMS entry.

Sources

• Reserve Bank of India, Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026, FEMA 23(R)/2026-RB, 13 Jan 2026, Gazette 15 Jan 2026, amended up to 22 Sep 2026 (regulations 3 to 7, 10, 13, 18 to 20), https://www.rbi.org.in/Scripts/BS_FemaNotifications.aspx?Id=13277
• Reserve Bank of India, Foreign Exchange Management (Export and Import of Goods and Services) (Amendment) Regulations, 2026, FEMA 23(R)/(1)/2026-RB, 22 Sep 2026, Gazette 24 Sep 2026, https://www.rbi.org.in/Scripts/BS_FemaNotifications.aspx?Id=13714
• Reserve Bank of India, A.P. (DIR Series) Circular No. 20, RBI/2025-26/194, Export and Import of Goods and Services, 16 Jan 2026, https://www.rbi.org.in/Scripts/NotificationUser.aspx?Id=13278&Mode=0
• Reserve Bank of India, Foreign Exchange Management (Export of Goods and Services) Regulations, 2015, FEMA 23(R)/2015-RB, amended up to 5 Jun 2026 (regulations 9 and 15), https://rbi.org.in/scripts/NotificationUser.aspx?Mode=0&Id=10256
• Reserve Bank of India, Foreign Exchange Management (Export of Goods and Services) (Second Amendment) Regulations, 2025, FEMA 23(R)/(7)/2025-RB, 13 Nov 2025, Gazette 14 Nov 2025, https://www.rbi.org.in/Scripts/BS_FemaNotifications.aspx?Id=12923
• Reserve Bank of India, Foreign Exchange Management (Export of Goods and Services) (First Amendment) Regulations, 2026, FEMA 23(R)/(8)/2026-RB, 5 Jun 2026, https://www.rbi.org.in/Scripts/BS_FemaNotifications.aspx?Id=13467
• Reserve Bank of India, Master Direction on Export of Goods and Services, FED Master Direction No. 16/2015-16, updated as on 17 Jul 2026, superseded from 1 Oct 2026 (paras A.2, C.20, C.23, C.26, C.28), https://www.rbi.org.in/Scripts/BS_ViewMasDirections.aspx?id=10395
• Government of India, Foreign Exchange Management Act, 1999, sections 7, 8 and 13, India Code, https://www.indiacode.nic.in/bitstream/123456789/1988/1/a199942.pdf
• Central Board of Indirect Taxes and Customs, Circular No. 202/14/2023-GST, Clarification relating to export of services, sub clause (iv) of section 2(6) of the IGST Act, 27 Oct 2023, https://gstcouncil.gov.in/sites/default/files/2024-06/circular-no-202-14-2023.pdf
• Central Board of Indirect Taxes and Customs, Circular No. 78/52/2018-GST, Clarification on export of services under GST, 31 Dec 2018, https://cbic-gst.gov.in/pdf/Circular_78-52-2018_Export_Services.pdf
• Central Board of Indirect Taxes and Customs, Notification No. 12/2024-Central Tax, 10 Jul 2024 (rule 96A(1)(b) of the CGST Rules, 2017 substituted), https://gstcouncil.gov.in/sites/default/files/2024-09/central-tax-12-2024-11072024.pdf
• Central Board of Indirect Taxes and Customs, GST rules page (current text of rules 96A and 96B of the CGST Rules, 2017), https://cbic-gst.gov.in/gst-goods-services-rules.html