What Changes Under the New FEMA Export and Import Regulations, 2026?

The FEMA Export and Import Regulations, 2026 are a single RBI rulebook for exports and imports of goods, software and services, in force from 1 October 2026 (Regulation 1). They replace the 2015 export regulations, and RBI's companion circular supersedes the two Master Directions and 167 older circulars (A.P. (DIR Series) Circular No. 20, para 4 and Annex).

• One framework: Exports and imports now sit in one set of regulations. The word services includes software for these rules (Regulation 2(1)).
• Stated aim: RBI says the rules aim to promote ease of doing business, especially for small exporters and importers, and to let AD banks serve customers faster (Circular No. 20, para 1).
• Bank powers: Decisions on extensions, reductions in export value and set-offs now rest with your AD bank (Regulation 5, Regulation 6 and Regulation 7).
• Late amendment: An amendment of 22 September 2026, published in the Gazette on 24 September 2026, cut the realisation period in the new rules from fifteen months to nine before they took effect (footnotes to Regulation 5).
• Reporting: AD banks still report all foreign trade transactions in FETERS, so purpose codes still apply (Regulation 18(2)).

For most freelancers and small exporters, the practical changes are a monthly EDF for services, easier closure of small entries, and more decisions taken directly by the bank.

The FEMA Export and Import Regulations, 2026 apply to every person in India who exports or imports goods, software or services, and to merchanting traders. Regulation 3 sets no minimum size, so a freelancer with one foreign client is covered (Regulation 3 and Regulation 16).

Exporters should update their monthly routine for declarations, payment tracking and bank requests. The steps below follow the order in which the new rules apply to a typical service or goods export from 1 October 2026.

1. List every invoice or shipment dated on or after 1 October 2026. The new rules are in force from that date (Regulation 1(2)).
2. For services, file one EDF with your AD bank within 30 days from the end of each invoice month. One EDF can cover all clients for that month (Regulation 3(2)(a)). See what is an EDF form.
3. If you export services other than software, you may instead file the EDF on or before the date you receive payment (Regulation 3(2)(b)). If you will miss the deadline, ask the bank to extend it, giving reasons (Regulation 3(2)(c)).
4. Track each invoice against the nine-month realisation period, or twelve months if invoiced or settled in rupees (Regulation 5(1)). See export realisation period.
5. For invoices up to ₹10 lakh, send your bank a realisation declaration, one by one or in a quarterly bulk declaration, to close EDPMS entries (proviso to Regulation 4(2)). See EDPMS closure.
6. Before a deadline passes, ask your AD bank for an extension or a reduction in export value, citing the reasons for the delay or shortfall (Regulation 5(1), Regulation 6).
7. Read your bank's published export and import policy. Each AD bank must publish the main features of its SOP, including documents, timelines and charges (Regulation 19(1) and 19(4)).

The main differences are a declaration for services, the end of SOFTEX, bank-led decisions in place of RBI approvals, and new consequences for long-overdue exports. The table compares the rules up to 30 September 2026 with the rules from 1 October 2026.

Non-compliance leaves entries open in EDPMS or IDPMS and can lead to restrictions on future trade and a FEMA penalty. The AD bank may extend deadlines or allow a reduction in export value when you give reasons.

• Advance only: If export 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). See export proceeds not realised.
• Caution list: The old caution list continues only for exporters already on it on 30 September 2026 (proviso to Regulation 13). See RBI exporter caution list.
• Import advances: If an import advance is not repatriated when goods do not arrive, future import advances need a standby LC or guarantee (Regulation 12(2)).
• 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). See FEMA penalties and compounding.
• Bank charges: An AD bank cannot levy charges or penalties on a customer for a regulatory delay or violation by that customer (Regulation 19(3)).

Contact your AD bank before the deadline. Ask for an extension of the EDF date or realisation period, or a reduction in export value, and give the reasons with any supporting documents the bank asks for. If the bank refuses, use the appeal route in its published SOP.

The framework rests on the FEMA Export and Import Regulations, 2026 and RBI's A.P. (DIR Series) Circular No. 20. The table also lists the older texts and amendments so you can see what applied when.

• Fifteen months: Relying on the fifteen-month realisation period in the January 2026 text, which was changed to nine months before the rules took effect.
• No services EDF: Assuming service exporters still need no declaration, as under the 2015 regulations. Regulation 3(2) now requires an EDF.
• Still filing SOFTEX: Following the old SOFTEX process for invoices from October 2026, after the SOFTEX circulars were superseded.
• Missed month-end: Counting 30 days from the invoice date instead of from the end of the invoice month.
• Late requests: Asking the AD bank for an extension or reduction only after the deadline, with no record of buyer follow-up.
• Old write-off caps: Applying the old 5% and 10% write-off limits instead of requesting a reduction under Regulation 6.
• Ignoring bank SOP: Not reading the AD bank's published policy, which sets documents, timelines, charges and the appeal route.

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, Preamble; Regulations 1 to 20; footnotes on Notification FEMA 23(R)/(1)/2026-RB dated 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 1, 3, 4, 7 and Annex A and B (superseded circulars) (checked 8 Oct 2026)
3. Foreign Exchange Management (Export of Goods and Services) Regulations, 2015, Notification FEMA 23(R)/2015-RB, amended up to 5 June 2026, Regulations 3(3), 6, 9, 10, 15, 16 and amendment footnotes (checked 8 Oct 2026)
4. RBI Master Direction: Export of Goods and Services (FED Master Direction No. 16/2015-16), updated as on 17 July 2026, Paras B.5, C.23, C.26, C.28, C.31 (checked 8 Oct 2026)
5. RBI Master Direction: Import of Goods and Services (FED Master Direction No. 17/2016-17), updated as on 12 January 2026, Paras B.5.1 and C.1.1 (checked 8 Oct 2026)
6. RBI Master Circular on Compounding of Contraventions under FEMA, 1999 (1 July 2014), Para 1.1, restating FEMA section 13(1) (checked 8 Oct 2026)