What Is the Export Realisation Period in India?
- Author:
- Manoj Sharma
- Verified by:
- Editorial team
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Short answer
The export realisation period in India is nine months. For services it runs from the invoice date, and for goods from the shipment date. Exports invoiced or settled in Indian rupees get twelve months. These periods come from Regulation 5 of RBI's FEMA export and import regulations, in force from 1 October 2026.
| Applies to | Governed by | Deadline | Penalty | Last verified |
|---|---|---|---|---|
| All exporters of goods, software and services from India, including freelancers paid from abroad | Regulation 5, Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026, as amended on 22 September 2026 | 9 months from invoice (services) or shipment (goods); 12 months if invoiced or settled in rupees; AD bank may extend | FEMA section 13 penalty of up to three times the sum involved; after one year overdue, further exports only against full advance or irrevocable LC | 6 Oct 2026 |
What is the export realisation period under FEMA?
The export realisation period is the time within which an exporter must receive the full export value and bring it into India. From 1 October 2026 it is nine months, or twelve months for exports invoiced or settled in rupees.
- Services: Nine months from the date of invoice (Regulation 5(1)(a)).
- Goods: Nine months from the date of shipment, other than goods sent to a warehouse outside India (Regulation 5(1)(a)).
- Warehouse exports: Nine months from the date the goods are sold from the overseas warehouse (Regulation 5(1)(b)).
- Rupee invoicing: Twelve months where the export is invoiced or settled in Indian rupees (first proviso to Regulation 5(1)).
- Project exports: As per the payment terms of the contract (Regulation 5(1)(c)).
- Recent changes: The period was raised from nine to fifteen months by an amendment of 13 November 2025, cut back to nine months by an amendment of 5 June 2026, and set at nine months in the new regulations by the 22 September 2026 amendment, before they took effect.
The nine-month rule therefore still applies to most exports, with twelve months for rupee-invoiced trade and AD bank extensions available on request.
Who does the export realisation period apply to?
The export realisation period applies to every exporter of goods and services from India, whatever their size. RBI's 2026 regulations use one framework for goods, software and services, so a freelancer billing a foreign client is covered in the same way as a manufacturer.
| Entity type | Applicable | Why | Best for |
|---|---|---|---|
| Freelancer or consultant exporting services | Yes, 9 months from invoice | Covered by Regulation 5(1)(a) | Individuals invoicing foreign clients in foreign currency |
| Software or IT services company | Yes, 9 months from invoice | Software and services fall under the same regulations from 1 October 2026 (A.P. (DIR Series) Circular No. 20) | Firms that also file SOFTEX or EDF |
| Goods exporter | Yes, 9 months from shipment | Covered by Regulation 5(1)(a) | Manufacturers and merchant exporters |
| Exporter invoicing or settling in rupees | Yes, 12 months | First proviso to Regulation 5(1) | Trade settled through rupee vostro arrangements |
| Goods sent to an overseas warehouse | Yes, 9 months from sale | Regulation 5(1)(b) | Exporters stocking goods abroad before sale |
| Project exporter | Contract terms | Regulation 5(1)(c) | Turnkey and construction contracts abroad |
How does the export realisation period work in practice?
The export realisation period starts on the invoice or shipment date and ends when the full value is received in India. Your AD bank tracks each export in EDPMS and marks it off once realisation is confirmed.
- Raise the invoice (services) or ship the goods. This date starts the nine-month clock under Regulation 5.
- For services, file the EDF declaration within 30 days from the end of the month in which the invoice is raised; one EDF can cover all exports of a month (Regulation 3(2)). See what is an EDF form.
- Receive the payment in your account with an AD bank. The bank verifies the transaction before crediting it and updates EDPMS (Regulation 4(2)).
- The AD bank marks off the EDPMS entry once it is satisfied the export value has been realised (Regulation 18). See what is EDPMS.
- If payment will be late, ask your AD bank for an extension before the period ends, giving reasons for the delay (second proviso to Regulation 5(1)).
- If the buyer pays less or not at all, ask the AD bank to allow a reduction in the export value (Regulation 6).
How do you get an extension of the export realisation period?
You apply to your AD bank, citing the reasons for the delay, and the bank may extend the time if it is satisfied with those reasons (Regulation 5(1)). The 2026 regulations do not set a fixed cap on the extension.
- Each AD bank must have a documented internal policy and SOP that covers extensions of the realisation period (Regulation 19).
- Under the old Master Direction, para C.20, banks could extend by up to six months at a time, subject to outstanding limits. That direction was superseded on 1 October 2026.
- For more detail, see extension of export realisation period.
Can small unrealised export bills be closed on a declaration?
Yes. For transactions up to ₹10 lakh, an exporter may declare the realisation status to the AD bank, individually or quarterly in bulk, to close EDPMS entries (Regulation 4(2)).
- A reduction in export value up to ₹10 lakh per shipping bill or invoice may be allowed on the exporter's declaration (Regulation 6).
Can export receivables be set off against import payables?
Yes. An AD bank may allow set-off of export receivables against import payables with the same overseas buyer or supplier (Regulation 7). Set-off counts as realisation under Regulation 5.
What deadlines apply to the export realisation period for each type of export?
The deadline depends on what you export and the currency of the invoice. The table below sets out each case under the regulations in force from 1 October 2026.
| Export type | Clock starts | Realisation period | Source | Best for |
|---|---|---|---|---|
| Services, foreign currency invoice | Date of invoice | 9 months | Regulation 5(1)(a) | Freelancers, agencies, IT firms |
| Goods, foreign currency invoice | Date of shipment | 9 months | Regulation 5(1)(a) | Goods exporters |
| Goods to overseas warehouse | Date of sale from warehouse | 9 months | Regulation 5(1)(b) | Exporters with stock abroad |
| Goods or services invoiced or settled in rupees | Invoice, shipment or sale date as above | 12 months | First proviso to Regulation 5(1) | Rupee trade settlements |
| Project exports | As per contract | Contract payment terms | Regulation 5(1)(c) | Overseas project contractors |
| Any export with an AD bank extension | Original due date | Extended period allowed by the AD bank | Second proviso to Regulation 5(1) | Exporters facing genuine buyer delays |
What happens if export proceeds are not realised within the export realisation period?
If proceeds are not realised in time, the export stays open in EDPMS and the exporter is in breach of FEMA unless the AD bank grants an extension. The longer it stays open, the more serious the consequences under FEMA and GST.
- Advance only: If proceeds stay unrealised for more than one year after the due date or extended date, further exports are allowed only against full advance or an irrevocable letter of credit (Regulation 13).
- Caution list: Exporters already on RBI's caution list on 30 September 2026 stay under that order until removed (proviso to Regulation 13). See RBI exporter caution list.
- FEMA penalty: A contravention can attract a penalty of up to three times the sum involved, or up to ₹2 lakh where it cannot be quantified, plus up to ₹5,000 a day if continuing (RBI Master Circular on Compounding, para 1.1, restating FEMA section 13(1)).
- GST payable: Services exported under LUT become taxable with interest if payment is not received within 15 days after one year from invoice, or the FEMA period with any extension, whichever is later (Rule 96A(1)(b)).
- Refund repayment: Goods exporters who got a refund under section 16(3) must deposit it with interest within 30 days after the FEMA time limit if proceeds are not realised (IGST Act section 16(3)).
Contact your AD bank before the due date and request an extension with reasons and buyer correspondence. If the amount will never be received, apply for a reduction in export value under Regulation 6. For an overview of next steps, see export proceeds not realised and how to check EDPMS outstanding.
Which RBI rule sets the export realisation period?
Regulation 5 of the Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026 sets the export realisation period. These regulations, with A.P. (DIR Series) Circular No. 20, replaced the old Master Direction on Export of Goods and Services from 1 October 2026.
| Circular or regulation | Clause | Date | Plain meaning | Best for |
|---|---|---|---|---|
| FEMA (Export and Import of Goods and Services) Regulations, 2026, FEMA 23(R)/2026-RB | Regulation 5 | 13 January 2026; in force 1 October 2026 | Current realisation periods and AD bank extension power | Every exporter from 1 October 2026 |
| Amendment Regulations, 2026, FEMA 23(R)/(1)/2026-RB | Regulation 5(1) and proviso; Regulations 13 and 20 | 22 September 2026; Gazette 24 September 2026 | Cut 15 months to 9, and 18 months to 12 for rupee trade, before the regulations took effect | Anyone who read about a 15-month rule |
| A.P. (DIR Series) Circular No. 20, RBI/2025-26/194 | Paras 4 and 6 | 16 January 2026; effective 1 October 2026 | Supersedes the old Master Directions on export and import and listed circulars | Readers checking which rules still apply |
| Export of Goods and Services (First Amendment) Regulations, 2026, FEMA 23(R)/(8)/2026-RB | Regulation 9 of the 2015 regulations | 5 June 2026 | Brought the old rule back from 15 to 9 months | Exports made between June and September 2026 |
| Export of Goods and Services (Second Amendment) Regulations, 2025, FEMA 23(R)/(7)/2025-RB | Regulations 9 and 15 of the 2015 regulations | 13 November 2025 | Raised the period from 9 to 15 months, and advance shipment time from one to three years | Exports made between November 2025 and June 2026 |
| Master Direction: Export of Goods and Services | Paras A.2(i) and C.20 | 1 January 2016; superseded 1 October 2026 | Old 9-month rule and old extension limits of up to six months at a time | Understanding past practice; see RBI Master Direction on exports |
What are the common mistakes with the export realisation period?
- Old 15 months: Relying on the 15-month period that applied from November 2025, which was cut back to nine months in June 2026.
- Wrong start: Counting from the payment due date in the contract instead of the invoice or shipment date set in Regulation 5.
- Late extension: Asking the AD bank for an extension only after the period has ended, with no record of buyer follow-up.
- Split banks: Receiving an advance through one AD bank and the balance through another without telling both, which Regulation 10(1) requires.
- GST overlooked: Forgetting that unpaid service invoices under LUT can trigger IGST with interest under Rule 96A.
- No reduction: Leaving a short-paid invoice open instead of asking the AD bank to allow a reduction under Regulation 6.
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, Notification FEMA 23(R)/2026-RB dated 13 January 2026, amended up to 22 September 2026, Regulations 3(2), 4(2), 5, 6, 7, 10(1), 13, 18, 19, 20; footnotes on Notification FEMA 23(R)/(1)/2026-RB dated 22 September 2026 (checked 6 Oct 2026)
- RBI A.P. (DIR Series) Circular No. 20, RBI/2025-26/194: Export and Import of Goods and Services, 16 January 2026, Para 4 (supersession of Master Directions and circulars), para 6 (effective 1 October 2026) (checked 6 Oct 2026)
- Foreign Exchange Management (Export of Goods and Services) (First Amendment) Regulations, 2026, FEMA 23(R)/(8)/2026-RB, 5 June 2026, Regulation 9(1) and 9(2)(a) of the 2015 regulations, fifteen months to nine months (checked 6 Oct 2026)
- Foreign Exchange Management (Export of Goods and Services) (Second Amendment) Regulations, 2025, FEMA 23(R)/(7)/2025-RB, 13 November 2025, Regulation 9 (nine months to fifteen months) and Regulation 15 (one year to three years) of the 2015 regulations (checked 6 Oct 2026)
- RBI Master Direction: Export of Goods and Services (FED Master Direction No. 16/2015-16), superseded from 1 October 2026, Paras A.2(i) (nine months) and C.20 (AD bank extension up to six months at a time) (checked 6 Oct 2026)
- RBI Master Circular on Compounding of Contraventions under FEMA, 1999 (1 July 2014), Para 1.1, restating FEMA section 13(1) penalties (checked 6 Oct 2026)
- Central Goods and Services Tax Rules, 2017: Rule 96A, Rule 96A(1)(b), as substituted by Notification 12/2024-CT dated 10.07.2024 (checked 6 Oct 2026)
- Integrated Goods and Services Tax Act, 2017: Section 16 (Zero rated supply), Proviso to section 16(3) (checked 6 Oct 2026)
Frequently asked questions
Is the export realisation period 9 months or 15 months in 2026?
From 1 October 2026 the export realisation period is nine months, or twelve months for exports invoiced or settled in rupees. A fifteen-month period applied under the old 2015 regulations from November 2025 until RBI's amendment of 5 June 2026. The new regulations were amended on 22 September 2026 to keep nine months.
Which export realisation period applies to invoices raised while the 15-month rule was in force?
RBI's amendment notifications change the period from their publication date but do not spell out how they apply to invoices already raised. If you issued invoices between November 2025 and June 2026, check with your AD bank which due date it has recorded in EDPMS for each export.
Does the export realisation period apply to freelancers with no IEC code?
Regulation 5 applies to the full export value of goods and services, without an exemption for individuals. A freelancer receiving payment for services from abroad should treat each invoice as subject to the nine-month period. Your AD bank can confirm how it records and closes such receipts. See also what is an IEC code.
Can an AD bank refuse to extend the export realisation period?
Yes. Regulation 5 lets an AD bank extend the period only if it is satisfied with the reasons the exporter cites. Each bank sets its own internal policy and SOP, which must include an appeal mechanism at a higher management level under Regulation 19. Keep buyer correspondence to support your request.
What is the export realisation period for advance payments received before export?
Where you receive an advance, you must route the advance and any later realisation through the same AD bank, or tell both banks if you change, under Regulation 10(1). The November 2025 amendment to the old rules allowed three years to ship against an advance. Check the current shipment period with your AD bank.
Does the export realisation period apply when part of the invoice is never paid?
Yes. If part of the value cannot be recovered, ask your AD bank to allow a reduction in the export value under Regulation 6. For amounts up to ₹10 lakh per invoice or shipping bill, the reduction may be allowed on your declaration. The reduced value then becomes the amount to realise.