What Must Exporters Do After a Change of Buyer or Consignee After Shipment?

A change of buyer or consignee after shipment happens when goods already exported are sold or delivered to someone other than the buyer named in the original contract. It usually follows a default, a refusal to take delivery or a cancelled order. For FEMA, the question is whether the full export value still reaches India on time.

• No special rule: The 2026 regulations deal with declaration, realisation, reduction, set-off and third-party receipts, and contain no provision that names a change of buyer or consignee (FEMA 23(R)/2026-RB).
• Old rule gone: The old Master Direction allowed a transfer to another buyer after the original buyer defaulted, without RBI approval, if any reduction stayed within 25 per cent of invoice value and realisation was within 9 months (para C.18). That direction was superseded on 1 October 2026 (A.P. (DIR Series) Circular No. 20, para 4).
• Realisation duty: You must still realise and repatriate the full export value, or the reduced value allowed by the bank, within the period in Regulation 5(1).
• Bank checks: The AD bank credits your account for an export receipt only after it is satisfied the transaction is genuine, and then closes or updates the EDPMS entry (Regulation 4(2)).
• Bank SOP: Each AD bank must set out documents, timelines and charges for each process in its internal policy and SOP and publish the main features on its website (Regulation 19).

In practice, a change of buyer is now handled through the general tools in the 2026 regulations: an extension if the new buyer pays late, a reduction if the new buyer pays less and the bank's approval if someone other than the original buyer pays.

Any exporter whose EDPMS entry names one buyer while the money will come from another needs to act. That mainly covers goods exporters whose cargo is diverted after a default. Service exporters face a similar issue when a different client takes over and pays an invoice already declared on an EDF.

You report a change of buyer after shipment by writing to the AD bank that holds the EDPMS entry before the new buyer pays. Explain why the original buyer dropped out, name the new buyer and give the new price. The bank then decides how to record the receipt and close the entry.

1. Get the original buyer's default, refusal or cancellation in writing, such as an email, a notice of non-acceptance or the collecting bank's advice of unpaid documents.
2. Agree terms with the new buyer in a written contract or purchase order that states the price, currency and payment date.
3. Write to the AD bank that handled the shipping bill or EDF. Give the shipping bill or invoice number, the original buyer, the new buyer, the reason and the expected payment date. Ask for its document list, which it must set out under Regulation 19(1)(a).
4. If the bank holds the shipping documents on collection, ask it to instruct its overseas correspondent to release them to the new buyer only against payment or acceptance.
5. If a customs document needs changing after export, speak to your customs broker first. Amendments after export are allowed only on documentary evidence that existed when the goods were exported (section 149 of the Customs Act).
6. If the new buyer pays less than the declared value, ask the bank for a reduction with reasons. A declaration is enough where the shipping bill or invoice is up to ₹10 lakh (Regulation 6).
7. If the new buyer will pay after the realisation deadline, ask for an extension before the deadline passes (second proviso to Regulation 5(1)).
8. Once the money arrives, confirm that the bank has closed or updated the EDPMS entry (Regulation 4(2)). You can track open entries with how to check EDPMS outstanding.

The 2026 regulations do not list documents for a change of buyer. Each AD bank sets its own list in its internal policy and SOP under Regulation 19. The table shows papers that match each situation and the rule they support. Ask your AD bank for its exact list.

If the bank is not told, the EDPMS entry stays linked to the original buyer and stays open until it can match a genuine receipt. A payment from an unknown party can be held while the bank checks it. If the value is not realised in time, the export counts as unrealised.

• Open entry: The bank marks off an EDPMS entry only after ensuring the export value is realised (Regulation 18(1)(g)) and must follow up on open entries (Regulation 18(1)(f)).
• Advance only: If proceeds stay unrealised for more than one year beyond the due date or extended date, further exports are allowed only against full advance or an irrevocable letter of credit (Regulation 13).
• GST refunds: If an IGST or input tax credit refund was paid on exported goods and the proceeds are not realised within the FEMA period with any extension, the refund must be repaid with interest within 30 days (CGST Rule 96B).
• LUT services: For services exported under LUT, tax with interest becomes payable if payment is not received within the period in CGST Rule 96A(1)(b).
• Bank charges: The AD bank may not levy any charge or penalty on you for a regulatory delay or violation by you (Regulation 19(3)). See FEMA penalties and compounding for the separate penalty regime.

Write to the bank as soon as you notice the gap, attach the default evidence and the new contract, and ask it to update the entry. If the deadline has passed, ask for an extension together with the update. If the bank refuses, use the escalation and appeal process in its SOP under Regulation 19(2). See export proceeds not realised.

From 1 October 2026, the Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026 govern a change of buyer through their general rules on realisation, reduction and third-party receipts. A.P. (DIR Series) Circular No. 20 superseded the Master Direction, including para C.18, from the same date.

• Telling late: Informing the AD bank only after the new buyer's payment arrives, which can delay the credit while the bank checks the receipt.
• Clock reset: Assuming the 9 month period starts again from the date of the new sale.
• Old cap: Applying the 25 per cent limit from the superseded para C.18 instead of asking for a reduction under Regulation 6.
• No paper trail: Moving goods to a new buyer without written proof that the original buyer defaulted or refused.
• Customs edits: Expecting to rewrite the shipping bill after export without evidence that existed at the time of export.
• Payment details: Letting the new buyer pay without quoting the shipping bill or invoice number, which makes matching harder.

Every rule, deadline and form on this page is linked to its official source, checked on the dates below.

1. Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026, Notification FEMA 23(R)/2026-RB dated 13 January 2026, amended up to 22 September 2026, Regulations 3, 4, 5, 6, 7, 8, 13, 18, 19 and 20; footnotes 2 to 6 (amendment of 22 September 2026) (checked 8 Oct 2026)
2. RBI A.P. (DIR Series) Circular No. 20, RBI/2025-26/194: Export and Import of Goods and Services, 16 January 2026, Paras 4 and 7 (checked 8 Oct 2026)
3. RBI Master Direction: Export of Goods and Services (FED Master Direction No. 16/2015-16), superseded from 1 October 2026, Paras C.17 and C.18 (checked 8 Oct 2026)
4. Customs Act, 1962 (CBIC tax information portal): Section 149, Amendment of documents, Section 149 and first proviso (checked 8 Oct 2026)
5. Central Goods and Services Tax Rules, 2017: Rule 96A, Rule 96A(1)(b) (checked 8 Oct 2026)
6. Central Goods and Services Tax Rules, 2017: Rule 96B, Rule 96B(1) (checked 8 Oct 2026)