What Are the RBI Payment and Realisation Rules for Consignment Exports?
- Author:
- Manoj Sharma
- Verified by:
- Editorial team
- Published:
- Last modified:
Short answer
Consignment exports follow the general FEMA realisation rules. The full export value must be realised within nine months from the date of shipment, or twelve months if invoiced or settled in rupees. For goods exported to a warehouse outside India, the period runs from the date of sale. Your AD bank can extend it.
| Applies to | Governed by | Deadline | Penalty | Last verified |
|---|---|---|---|---|
| Exporters of goods who ship to an overseas agent or consignee who sells the goods on their behalf and remits the sale proceeds | FEMA (Export and Import of Goods and Services) Regulations, 2026, mainly Regulations 3, 4, 5, 6, 13 and 19; your AD bank's internal policy | Nine months from shipment (twelve if invoiced or settled in INR); for goods exported to a warehouse outside India, nine months from the date of sale; AD bank may extend | Proceeds unrealised for over a year past the due or extended date mean further exports only against full advance or an irrevocable LC; GST export refunds can be recovered | 8 Oct 2026 |
What is a consignment export under RBI and FEMA rules?
A consignment export is a shipment sent to an overseas agent or consignee who sells the goods on the exporter's behalf and sends back the sale proceeds. The price is known only after the sale. RBI's export rules from 1 October 2026 have no separate consignment chapter, so the general declaration, realisation and EDPMS rules apply.
- Declaration: Every goods export needs a declaration of the full export value at the time of export. At an EDI port the shipping bill counts as the Export Declaration Form (Regulation 3(1)).
- Value: The 2015 Regulations let you declare the value you expected to receive on sale abroad when the full value was not known at export (Regulation 3(1)(ii), 2015 Regulations). The 2026 Regulations simply say "full export value", so agree the declared value with your customs broker and AD bank.
- Proceeds: The agent's remittance of the sale proceeds is your export realisation. Your AD bank credits it and closes or updates the EDPMS entry only after checking the transaction is genuine (Regulation 4(2)).
- Old rules: Until 30 September 2026, banks followed a dedicated paragraph on consignment exports in the Master Direction (para C.12). That Master Direction was superseded from 1 October 2026 (A.P. (DIR Series) Circular No. 20, para 4).
- Gems: The Foreign Trade Policy allows gems and jewellery exporters to export and import diamonds, gemstones and jewellery on consignment basis under the Handbook of Procedures and customs rules (FTP 2023, para 4.53).
In practice, most consignment questions are now settled by your AD bank under its board-approved internal policy, which it must publish in summary on its website (Regulation 19(4)).
Which exporters do the RBI consignment export rules apply to?
The rules apply to any exporter of goods who ships before a sale is concluded and depends on an overseas agent or consignee to sell. Service exporters do not ship goods on consignment. Gems and jewellery exporters have a specific permission in the Foreign Trade Policy, and goods sent to an overseas warehouse have their own realisation start date.
| Exporter type | Applicable | Why | Best for |
|---|---|---|---|
| Goods exporter selling through an overseas commission agent | Yes | The general realisation period of nine months from shipment applies (Regulation 5(1)(a)) | Agricultural, textile and handicraft exporters using selling agents |
| Exporter shipping to its own or a hired warehouse outside India | Yes, with a different start date | Realisation runs nine months from the date of sale from the warehouse (Regulation 5(1)(b)) | Exporters holding stock near buyers abroad |
| Gems and jewellery exporter | Yes | Consignment exports and imports are expressly allowed under the Foreign Trade Policy (para 4.53) | Diamond, gemstone and jewellery exporters |
| Exporter invoicing or settling in Indian rupees | Yes, longer period | The period is twelve months instead of nine (first proviso to Regulation 5(1)) | Exporters using rupee invoicing |
| Service exporter or freelancer | No | Services have no shipment. The period runs from the invoice date (Regulation 5(1)(a)) | Freelancers checking whether this page applies to them |
How are consignment export proceeds realised and closed in EDPMS?
Consignment proceeds are realised when the overseas agent sells the goods and remits the money to your AD bank. The bank matches the remittance to the shipping bill and closes the EDPMS entry. Any shortfall against the declared value is closed as a reduction, which the bank may allow on your request.
- Before shipment, sign a written agreement with the overseas agent or consignee covering sale terms, deductions, commission and the date by which proceeds will be remitted. Keep the date inside the realisation period.
- File the shipping bill with the export value. At an EDI port it doubles as the Export Declaration Form (Regulation 3(1)). Declare any agency commission on it, as banks have long expected (para D.1(i)).
- Route the shipping documents through your AD bank. Under the old Master Direction, the bank told its overseas correspondent to release them only against a trust receipt or undertaking to remit proceeds by a set date (para C.12(i)). Ask whether your bank's current policy keeps this step.
- When the agent sells the goods, collect the account sales: a statement of gross sale price, deductions and net proceeds.
- Have the agent remit the net proceeds to your AD bank, quoting the shipping bill number. The bank credits your account and closes or updates the EDPMS entry (Regulation 4(2)).
- If the net amount is lower than the declared value, ask the bank to allow a reduction, citing reasons (Regulation 6). Up to ₹10 lakh per shipping bill, your declaration is enough.
- If the goods are still unsold near the deadline, ask for an extension before the period ends (second proviso to Regulation 5(1)). See extension of export realisation period.
- Ask the bank to confirm the EDPMS entry is closed and keep the account sales and bank advice in your export file.
How is the realisation period for consignment exports counted under the 2026 Regulations?
For an ordinary consignment export, the realisation period is nine months from the date of shipment (Regulation 5(1)(a)). If the goods go to a warehouse outside India, it is nine months from the date of sale from the warehouse (Regulation 5(1)(b)). Rupee invoicing or settlement makes it twelve months.
- The amendment dated 22 September 2026 cut these periods before they took effect. The original 2026 text said fifteen months and eighteen months (footnotes 2 to 4, FEMA 23(R)/(1)/2026-RB).
- The Regulations do not define whether an agent's premises count as a "warehouse outside India". Confirm with your AD bank which start date it will apply to your shipment before you ship.
- Under the old rules, goods exported to a warehouse established outside India had fifteen months from the date of shipment (Master Direction para A.2(iii)). That changed on 1 October 2026.
- Use the export realisation period guide for the general rule across all exports.
How should an exporter account for deductions and commission in consignment sales?
Account for the gross sale price, the agent's deductions and the net amount received, all tied to the shipping bill. The old Master Direction let agents deduct normal expenses of receipt, storage and sale, such as landing charges, warehouse rent and handling charges, and remit the net proceeds (para C.12(ii)).
- Banks verified the account sales and asked for original bills or receipts for deductions, except petty items such as postage and stamp duty (para C.12(iii)). Expect similar checks under your bank's policy.
- Agency commission could be paid by deduction from invoice value or by separate remittance. The bank looked for the commission to be declared on the export declaration (para D.1(i)).
- From 1 October 2026, the bank's internal policy must cover adjustment of under-, over- and non-realisation of export proceeds (Regulation 19(1)(c)). Ask for its document list.
- If net proceeds fall short of the declared value, the gap is closed as a reduction. See reduction in export invoice value.
What happens to consignment goods that remain unsold abroad?
Unsold consignment goods leave the shipping bill open until you resolve it. You can sell to another buyer, bring the goods back, or ask the AD bank to allow a reduction for value that will never be received (Regulation 6). Each route needs evidence.
- Selling to a different buyer abroad is a change of buyer. See change of buyer after shipment.
- Bringing goods back is a re-import for customs. See export goods returned.
- For exports of books on consignment, the old rules let banks allow exporters to abandon unsold books at the end of the sale contract and show their value as a deduction in the account sales (para C.12(v)). The 2003 circular behind it was superseded (Circular No. 20, Annex A).
What documents and deadlines apply to consignment export payments?
The main deadline is the realisation period: nine months from shipment, or from the date of sale for goods in a warehouse abroad, and twelve months for rupee trade (Regulation 5(1)). Each AD bank sets its own document list and timelines in its internal policy (Regulation 19(1)(a)).
| Document or step | What it shows | Time limit | Best for |
|---|---|---|---|
| Consignment or agency agreement | Sale terms, deductions, commission and remittance date | Before shipment | Every consignment export |
| Shipping bill or EDF | Declared export value (Regulation 3(1)) | At the time of export | All goods exports |
| Account sales from the agent | Gross sale price, deductions and net proceeds | After each sale | Matching the remittance to the declared value |
| Bills and receipts for deductions | Expenses the agent charged | With the account sales | Exporters whose net proceeds are lower than declared |
| Inward remittance quoting the shipping bill | Realisation of proceeds (Regulation 4(2)) | Within the realisation period | EDPMS closure |
| Reduction request or ₹10 lakh declaration | Why the full declared value was not received (Regulation 6) | Once the shortfall is known | Unsold goods or low sale prices |
| Extension request | Reasons for delay (Regulation 5(1)) | Before the period ends | Goods still on sale abroad |
What happens if consignment export proceeds are not realised on time?
Unrealised consignment proceeds leave the EDPMS entry open and your bank will follow up (Regulation 5(2)). If proceeds stay unrealised for over a year after the due or extended date, you can export only against full advance or an irrevocable letter of credit (Regulation 13).
- Export restriction: Further exports need full advance or an irrevocable LC once proceeds are over one year past the due date (Regulation 13). See RBI exporter caution list.
- Caution list: Exporters already on the caution list on 30 September 2026 stay governed by that order until removed (proviso to Regulation 13).
- GST refunds: If you received an IGST or input tax credit refund on the export and proceeds are not realised within the FEMA period, you must deposit the refund to that extent with interest within 30 days of the end of that period (CGST Rule 96B(1)).
- Bank charges: Your AD bank cannot levy charges or a penalty on you for a regulatory delay (Regulation 19(3)). Its normal processing charges must be reasonable.
Ask your AD bank for an extension or a reduction before the deadline passes, with the agent's account sales and correspondence as evidence. If realisation comes after a GST refund was recovered, Rule 96B(2) allows a refund back if you produce proof within three months of realisation, provided realisation falls within any extended period RBI permits (CGST Rule 96B(2)). See export proceeds not realised.
Which RBI rule says how consignment export proceeds are realised?
From 1 October 2026, the FEMA (Export and Import of Goods and Services) Regulations, 2026 govern consignment exports, mainly through Regulations 3, 5 and 6 (FEMA 23(R)/2026-RB). The Master Direction paragraph on consignment exports and the 2015 Regulations no longer apply to new exports.
| Circular or regulation | Clause | Date | Plain meaning | Best for |
|---|---|---|---|---|
| FEMA 23(R)/2026-RB | Regulation 3(1) | 13 January 2026, in force 1 October 2026 | Declare the full export value of goods at the time of export | All goods exporters |
| FEMA 23(R)/2026-RB as amended | Regulation 5(1) | Amended 22 September 2026 | Realise within nine months of shipment, or of sale for warehouse exports; twelve months for INR | Planning the agent's remittance date |
| FEMA 23(R)/2026-RB | Regulation 6 | 13 January 2026 | AD bank may allow reduction in export value; declaration suffices up to ₹10 lakh | Unsold goods or lower sale prices |
| FEMA 23(R)/2026-RB | Regulation 19(1) | 13 January 2026 | AD bank policy covers documents, extensions and adjustment of proceeds | Knowing what your bank will ask for |
| A.P. (DIR Series) Circular No. 20 | Para 4 and Annex A | 16 January 2026 | Supersedes the export Master Direction, including the consignment paragraph, from 1 October 2026 | Checking whether older advice still applies |
| Master Direction on Export of Goods and Services | Paras C.12 and C.13 | Superseded from 1 October 2026 | Old consignment procedure and conditions for warehouses abroad | Exports shipped before 1 October 2026 |
| FEMA 23(R)/2015-RB | Regulations 3 and 9 | 12 January 2016, superseded | Allowed declaring expected value; warehouse exports had fifteen months from shipment | Understanding older shipping bills |
| CGST Rules | Rule 96B | Inserted 23 March 2020 | GST export refund repayable if proceeds are not realised in the FEMA period | Exporters who claimed GST refunds |
| Foreign Trade Policy 2023 | Para 4.53 | FTP 2023 | Gems and jewellery may be exported and imported on consignment basis | Gems and jewellery exporters |
What are common mistakes exporters make with consignment export payments?
- Old periods: Relying on the fifteen-month warehouse period from the old Master Direction. From 1 October 2026 the period is nine months from the date of sale (Regulation 5(1)(b)).
- No agreement: Shipping without a written agreement on deductions and remittance dates, which leaves you without evidence when the bank checks the account sales.
- Missing proof: Accepting deductions in the account sales without bills or receipts. Banks have historically asked for originals (para C.12(iii)).
- Late extension: Asking for an extension after the realisation period has ended, instead of before.
- Unquoted remittance: Letting the agent remit without the shipping bill number, which delays matching and EDPMS closure. See EDPMS closure.
- GST refund: Forgetting that an export refund may have to be repaid if proceeds are short (CGST Rule 96B).
How did we verify this?
Every rule, deadline and form on this page is linked to its official source, checked on the dates below.
- Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026 (FEMA 23(R)/2026-RB, amended up to 22 September 2026), Regulations 3(1), 4(2), 5(1), 5(2), 6, 13, 19(1), 19(3), 19(4); footnotes 2 to 5 (checked 8 Oct 2026)
- A.P. (DIR Series) Circular No. 20: Export and Import of Goods and Services (16 January 2026), Para 4; Annex A item 27 (Circular No. 26 of 3 October 2003, Export of Books on Consignment Basis) (checked 8 Oct 2026)
- Master Direction - Export of Goods and Services (superseded from 1 October 2026), Paras A.2(iii), C.12, C.13, D.1 (checked 8 Oct 2026)
- Foreign Exchange Management (Export of Goods and Services) Regulations, 2015 (FEMA 23(R)/2015-RB, superseded), Regulations 3(1) and 9(1) (checked 8 Oct 2026)
- CGST Rules, Rule 96B: Recovery of refund where export proceeds not realised, Rule 96B(1) and (2) (checked 8 Oct 2026)
- Foreign Trade Policy 2023, Chapter 4, Para 4.53 (checked 8 Oct 2026)
Frequently asked questions
Is consignment export allowed under the FEMA Regulations, 2026?
Yes. The FEMA (Export and Import of Goods and Services) Regulations, 2026 do not prohibit consignment exports. They apply the same declaration, realisation and EDPMS rules as other goods exports. The full export value must be realised within the period in Regulation 5, and your AD bank handles approvals under its own internal policy.
Can an overseas consignment agent deduct commission from sale proceeds?
The old Master Direction allowed agency commission by deduction from invoice value or by remittance, with the commission declared on the export form. That Master Direction was superseded on 1 October 2026. Under the 2026 Regulations, ask your AD bank how its internal policy treats commission and deductions in the account sales.
Does the ₹10 lakh EDPMS declaration apply to consignment shipping bills?
The ₹10 lakh rule applies to any shipping bill of up to ₹10 lakh or its foreign currency equivalent. The bank may close the EDPMS entry, or allow a reduction, based on your declaration that payment was realised in full or otherwise. Quarterly bulk declarations are also allowed under Regulation 4(2).
When does the realisation period start for goods sent to a warehouse outside India?
For goods exported to a warehouse outside India, the nine-month realisation period starts from the date of sale of goods from the warehouse. It is twelve months if the export is invoiced or settled in Indian rupees. The AD bank may extend either period if it accepts the reasons you give.
Do consignment exporters still need AD bank permission to open a warehouse abroad?
The old Master Direction let AD banks permit warehouses abroad if export outstanding did not exceed 5 per cent of the previous year's exports and turnover was at least USD 100,000. Those conditions were superseded on 1 October 2026. The 2026 Regulations do not repeat them, so check your AD bank's current internal policy.
What is an account sales in a consignment export?
An account sales is the statement an overseas agent or consignee sends after selling consignment goods. It shows the gross sale price, the expenses and commission deducted, and the net amount remitted. Your AD bank uses it to match the remittance to the shipping bill and to assess any reduction request.
Does CGST Rule 96B apply to unsold consignment goods?
Rule 96B applies when a GST export refund was paid but sale proceeds were not realised within the FEMA period, including any extension. The refund must be deposited to the extent of non-realisation, with interest, within thirty days of the period ending. If RBI writes off the realisation requirement on merits, the refund is not recovered.