How Do You Get an Extension of the Export Realisation Period from Your AD Bank?
- Author:
- Manoj Sharma
- Verified by:
- Editorial team
- Published:
- Last modified:
Short answer
An extension of the export realisation period is granted by your AD bank, not by RBI. You request it in writing and cite the reasons for the delay. The bank may extend the time if it is satisfied with those reasons. This power sits in Regulation 5(1) of RBI's export and import regulations, in force from 1 October 2026.
| Applies to | Governed by | Deadline | Penalty | Last verified |
|---|---|---|---|---|
| Exporters of goods, software and services who cannot receive the full export value within the normal realisation period | Second proviso to Regulation 5(1) and Regulation 19, Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026 | Regulation 5 sets no deadline for the request; the base period is 9 months from invoice or shipment, or 12 months if invoiced or settled in rupees | If proceeds stay unrealised more than one year after the due or extended date, further exports only against full advance or an irrevocable letter of credit | 8 Oct 2026 |
What is an extension of the export realisation period?
An extension of the export realisation period is extra time, allowed by your AD bank, to receive and bring into India the full value of an export. It applies when the normal period under Regulation 5 is about to end, or has ended, and the buyer has not yet paid.
- Normal period: Nine months from the invoice date for services and from the shipment date for goods (Regulation 5(1)(a)).
- Rupee trade: Twelve months where the export is invoiced or settled in Indian rupees (first proviso to Regulation 5(1)).
- Who decides: The Authorised Dealer (AD) bank, on a request from the exporter citing reasons for the delay (second proviso to Regulation 5(1)).
- Test applied: The bank must be satisfied with the reasons cited. The regulation sets no fixed maximum length for the extension (Regulation 5(1)).
- Bank policy: Every AD bank must have a written internal policy and SOP that covers extensions of the realisation period (Regulation 19(1)(b)).
- Old rule: Until 30 September 2026, AD banks could extend by up to six months at a time under conditions, and other cases needed RBI approval (Master Direction, para C.20).
In short, the extension is a bank-level decision under a rule that gives the bank discretion, so the strength of your reasons and records matters most.
Who can apply for an extension of the export realisation period?
Any exporter whose export proceeds are still due can apply for an extension of the export realisation period. The 2026 regulations cover goods, software and services under one framework, so a freelancer billing a foreign client uses the same route as a manufacturer.
| Entity type | Applicable | Why | Best for |
|---|---|---|---|
| Freelancer or consultant exporting services | Yes | Services are covered by Regulation 5(1)(a), with the clock starting on the invoice date | Individuals with a slow-paying foreign client |
| Software or IT services firm | Yes | Software counts as services under the Explanation to Regulation 2(1) | Firms that earlier filed SOFTEX forms |
| Goods exporter | Yes | Goods are covered by Regulation 5(1)(a), with the clock starting on the shipment date | Manufacturers and merchant exporters |
| Exporter to an overseas warehouse | Yes | The period runs from the date of sale from the warehouse (Regulation 5(1)(b)) | Exporters holding stock abroad |
| Exporter invoicing or settling in rupees | Yes | The base period is twelve months, and the same extension proviso follows it in Regulation 5(1) | Trade settled through rupee arrangements |
| Project exporter | Contract terms apply | Realisation follows the payment terms of the contract (Regulation 5(1)(c)) | Turnkey and construction contracts abroad |
How do you apply for an extension of the export realisation period?
You apply to the AD bank that holds the export entry in EDPMS, in writing, citing why the payment is late. The bank checks the request against its internal policy and decides whether to allow more time.
- Check the due date for each open invoice or shipping bill. Count nine months, or twelve for rupee invoicing, from the invoice or shipment date under Regulation 5(1). The export realisation deadline calculator can help.
- Find your bank's published policy. Each AD bank must disclose its policy and the main features of its SOP on its website (Regulation 19(4)).
- Write to the AD bank that handled the export, ideally before the period ends. State the invoice or shipping bill details, the amount outstanding and the reasons for the delay (second proviso to Regulation 5(1)).
- Attach the documents your bank's policy lists. The policy must set out documents, timelines and charges for each process (Regulation 19(1)(a)).
- Wait for the bank's decision. If it refuses, use the bank's appeal mechanism, which must be handled at a higher internal level (Regulation 19(2)).
- Once the payment arrives, confirm that the bank has marked off the EDPMS entry (Regulation 18(1)(g)). See EDPMS closure.
When can an AD bank extend the export realisation period?
An AD bank can extend the export realisation period whenever the exporter asks, cites reasons for the delay, and the bank is satisfied with those reasons (Regulation 5(1)). The 2026 regulations do not list approved reasons or a cap on the extension.
- The bank must also run systems to monitor and follow up with exporters on realisation within the period (Regulation 5(2)).
- Delegation of approval powers inside the bank is part of the required policy (Regulation 19(1)(e)).
- Under the old Master Direction, reasons had to be beyond the exporter's control, and the invoices could not be under investigation (para C.20(i)). Banks may still look at similar factors, but those conditions are no longer the legal test.
When is RBI approval needed for an extension of the export realisation period?
From 1 October 2026, the regulations give no RBI approval route for extending the realisation period. The AD bank decides. Even pending cases that needed RBI approval under the old rules are now handled by AD banks (Regulation 20).
- Under the old rules, cases outside the AD bank's limits needed prior approval from the RBI Regional Office (para C.20(ii)).
- That Master Direction was superseded from 1 October 2026 (A.P. (DIR Series) Circular No. 20, para 4).
- AD banks send any references they make to RBI through the PRAVAAH portal (Circular No. 20, para 3).
Can an AD bank charge a fee for an extension of the export realisation period?
An AD bank may charge for handling the request, but its charges must be reasonable and proportional to the service. It cannot levy a charge or penalty for a regulatory delay or violation by the exporter (Regulation 19(3)).
- The bank's policy must list its charges for each process (Regulation 19(1)(a)).
What documents should you keep ready for an extension of the export realisation period?
The regulations do not list documents for an extension. Each AD bank sets its own list in its internal policy under Regulation 19(1)(a). The items below are what a request usually needs to show the reasons for delay; check your bank's published list before you apply.
| Document | Why the bank may ask | Rule it supports | Best for |
|---|---|---|---|
| Written request citing reasons for delay | The extension is allowed only on a request citing reasons | Second proviso to Regulation 5(1) | Every exporter applying |
| Invoice or shipping bill and EDPMS entry reference | Identifies the export and its original due date | Due dates in Regulation 5(1); EDPMS entries in Regulation 18(1) | Exporters with several open entries |
| Correspondence with the buyer | Shows why payment is late and that you followed up | Bank must be satisfied of the reasons cited (Regulation 5(1)) | Disputes, buyer cash-flow delays |
| Declaration on expected realisation | The old rule required one; check whether your bank's policy still asks for it | Former para C.20(i)(c) | Exporters who expect payment soon |
| Proof of legal or recovery action, if any | Old rules allowed extension regardless of amount where a suit was filed abroad | Former para C.20(i)(e) | Exporters pursuing a defaulting buyer |
| Bank's own application form, if it has one | Banks set documents and timelines in their policy | Bank policy under Regulation 19(1)(a) | Anyone unsure of the bank's format |
What happens if you do not get an extension of the export realisation period?
Without an extension, the export stays overdue in EDPMS from the original due date. The longer it stays open, the more FEMA and GST consequences follow, starting with closer follow-up by the bank under Regulation 5(2).
- Advance only: If proceeds stay unrealised for more than one year after the due date or the extended period, you may export further 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.
- GST under LUT: For services exported under LUT, IGST with interest is due if payment is not received within fifteen days after one year, or the FEMA period including any extension, whichever is later (Rule 96A(1)(b)).
- No set-off: Set-off of export receivables against import payables is allowed only within the realisation period or extended period (Regulation 7).
- Bank follow-up: The AD bank must monitor open EDPMS entries and follow up with you for closure (Regulation 18(1)(f)).
Apply to your AD bank as early as possible, with buyer correspondence. If the money will not arrive, ask for a reduction in export value under Regulation 6 instead. See export proceeds not realised and reduction in export invoice value.
Which RBI rule allows an extension of the export realisation period?
The second proviso to Regulation 5(1) of the Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026 allows the extension. Regulation 19 sets how banks must handle it. These replaced the old Master Direction and the extension circulars 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(1), second proviso | 13 January 2026; in force 1 October 2026 | AD bank may extend on reasons it accepts | Every exporter seeking more time |
| Same regulations | Regulation 19 | 13 January 2026; in force 1 October 2026 | Bank policy must cover extensions, documents, charges and appeals, and be disclosed on the bank's website | Exporters preparing a request or an appeal |
| Same regulations | Regulation 20 | Inserted 22 September 2026; in force 1 October 2026 | AD banks now handle older cases that earlier needed RBI approval | Exporters with pending pre-October 2026 cases |
| Amendment Regulations, 2026, FEMA 23(R)/(1)/2026-RB | Regulations 5(1), 13 and 20 | 22 September 2026; Gazette 24 September 2026 | Set the base period at nine months (twelve for rupee trade), added the caution list proviso and inserted Regulation 20 | Anyone who read about a 15-month period |
| A.P. (DIR Series) Circular No. 20, RBI/2025-26/194 | Paras 3, 4 and Annex | 16 January 2026; effective 1 October 2026 | Supersedes the old Master Direction and the 2002 and 2006 extension circulars | Readers checking which rules still apply |
| Master Direction: Export of Goods and Services | Para C.20 | 1 January 2016; superseded 1 October 2026 | Old limit of six months at a time, with conditions and RBI approval for other cases | Understanding past bank practice |
What are common mistakes when asking for an extension of the export realisation period?
- Asking late: Waiting until after the due date, when the entry already shows as overdue in EDPMS.
- No reasons: Sending a bare request without the reasons and buyer correspondence the bank must be satisfied with.
- Wrong bank: Applying to a bank other than the one holding the EDPMS entry, or splitting advance and balance across banks without telling both, as Regulation 10(1) requires.
- Old limits: Assuming the six-month cap or RBI approval route of the old Master Direction still applies after 1 October 2026.
- Ignoring GST: Forgetting to keep the bank's extension letter for LUT records under Rule 96A.
- Wrong request: Seeking repeated extensions for money that will never come, when a reduction in export value is the right request.
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 2(1) Explanation, 3(2), 4(2), 5, 6, 7, 10(1), 13, 18(1), 19, 20 and footnotes on FEMA 23(R)/(1)/2026-RB (checked 8 Oct 2026)
- RBI A.P. (DIR Series) Circular No. 20, RBI/2025-26/194: Export and Import of Goods and Services, 16 January 2026, Paras 3, 4, 7 and Annex A (items 10 and 37, extension of period of realisation circulars of 2002 and 2006) (checked 8 Oct 2026)
- RBI Master Direction: Export of Goods and Services (FED Master Direction No. 16/2015-16), updated as on 17 July 2026, superseded from 1 October 2026, Para C.20 (Extension of time) (checked 8 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 8 Oct 2026)
Frequently asked questions
Is there a maximum length for an extension of the export realisation period under the 2026 FEMA regulations?
Regulation 5 of the 2026 regulations sets no maximum length for an extension. The AD bank decides how much extra time to allow, based on the reasons you cite and its internal policy. The old six-month-at-a-time limit in the Master Direction no longer applies from 1 October 2026.
Can an exporter get more than one extension of the export realisation period for the same invoice?
The regulation does not limit the number of extensions. Each further request is judged by the AD bank on the reasons cited. Under Regulation 13, if proceeds stay unrealised for more than one year after the extended date, further exports need full advance or an irrevocable letter of credit.
Does an extension of the export realisation period change the GST deadline under an LUT?
It can. Rule 96A(1)(b) of the CGST Rules gives service exporters under LUT until fifteen days after one year, or the FEMA period including any extension, whichever is later. Keep the AD bank's extension letter with your GST records. Check with your tax adviser how your jurisdictional officer treats bank-granted extensions.
Is the EDF submission deadline extended along with the export realisation period?
No, the EDF deadline is a separate rule. Service exporters file the EDF within 30 days from the end of the invoice month under Regulation 3(2). Regulation 3(2)(c) lets the AD bank extend that filing period on a request citing reasons. See EDF form for exports for details.
What can an exporter do if the AD bank rejects an extension of the export realisation period?
Use the bank's appeal mechanism. Regulation 19(2) requires each AD bank's policy to include an escalation process for grievances and an appeal handled at a higher internal level, which takes a final decision on the genuineness of your submissions. Keep copies of every document you submitted.
Does an extension of the export realisation period apply to invoices up to ₹10 lakh?
Yes, the same Regulation 5 extension is available. For invoices up to ₹10 lakh, you also have simpler options. Regulation 4(2) lets the EDPMS entry close on your declaration, and Regulation 6 allows a reduction in export value on your declaration if the full amount will not be received.
Who handles an extension of the export realisation period for exports made before 1 October 2026?
The AD bank. Regulation 20 says AD banks handle export transactions made before 1 October 2026 that earlier needed RBI approval under the 2015 regulations and the old Master Direction. Ask your bank which due date it has recorded in EDPMS for older invoices before applying.