What Are the FEMA Rules for Export of Goods and Services?
- Author:
- Manoj Sharma
- Verified by:
- Editorial team
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Short answer
The FEMA rules for exports require every exporter to declare the export, realise the full value within nine months and bring it into India through an AD bank. From 1 October 2026 these rules sit in RBI's Export and Import of Goods and Services Regulations, 2026. The old Master Direction on exports no longer applies.
| Applies to | Governed by | Deadline | Penalty | Last verified |
|---|---|---|---|---|
| Every person resident in India who exports goods, software or services, including freelancers, agencies and companies | FEMA 1999 sections 7 and 8; Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026 (FEMA 23(R)/2026-RB, as amended on 22 September 2026); A.P. (DIR Series) Circular No. 20 of 16 January 2026 | Services EDF within 30 days from the end of the invoice month; realisation within 9 months (12 months if invoiced or settled in rupees), extendable by the AD bank | Up to three times the sum involved under FEMA section 13(1); after one year overdue, further exports only against full advance or an irrevocable letter of credit | 8 Oct 2026 |
What do the FEMA rules for export of goods and services cover?
The FEMA rules for exports cover three duties: declaring each export, realising the full export value on time, and routing the money through an authorised dealer (AD) bank that reports it to RBI. The Act sets these duties and RBI's 2026 regulations give the details.
- Declare: Every exporter of goods must declare the full export value, and every exporter of services must declare the payment details, in the form RBI specifies (FEMA section 7). Under the 2026 regulations that form is the Export Declaration Form, or EDF (Regulation 3).
- Realise: A person resident in India who is owed foreign exchange must take all reasonable steps to realise it and bring it to India within the period RBI specifies (FEMA section 8). For exports that period is nine months (Regulation 5).
- Receive: Export receipts must follow the Manner of Receipt and Payment Regulations, 2023 (Regulation 4(1)). Those regulations require receipts and payments between a person resident in India and a person outside India to go through an authorised bank or authorised person (Regulation 3(2)).
- Report: The AD bank records each export in EDPMS, closes the entry once paid, and reports all foreign trade transactions in FETERS (Regulation 18).
- Software: Software counts as a service for these regulations (Regulation 2(1)). The separate SOFTEX circulars were superseded on 1 October 2026 (A.P. (DIR Series) Circular No. 20, Annex).
In short, FEMA asks exporters to declare, get paid in full on time, and use an AD bank, while the bank handles most of the monitoring and reporting. For a background explainer, see what is FEMA.
Who do the FEMA rules for exports apply to?
The FEMA rules for exports apply to every exporter of goods, software and services from India, including individuals and small businesses. The 2026 regulations ease EDPMS closure paperwork for invoices up to ₹10 lakh. A traveller carrying personal effects out of India is not treated as an exporter.
| Entity type | Applicable | Why | Best for |
|---|---|---|---|
| Freelancer or consultant | Yes | Services exporters must file an EDF and realise within nine months of invoice (Regulations 3(2) and 5). See FEMA rules for freelancers | Individuals invoicing foreign clients |
| Software or IT company | Yes | Software is treated as a service; the specified authority is the AD bank or STPI in the DTA, and the Development Commissioner in an SEZ (Regulation 2(1)(f)) | Firms that earlier filed SOFTEX |
| Goods exporter | Yes | EDF at the time of export, deemed filed with the shipping bill at EDI ports (Regulation 3(1)) | Manufacturers and merchant exporters |
| Exporter invoicing in rupees | Yes, with 12 months to realise | First proviso to Regulation 5(1) | Trade settled in Indian rupees |
| Project exporter | Yes, contract terms apply | Regulations 5(1)(c) and 15 | Turnkey and construction contracts abroad |
| Merchanting trader | Yes, separate rules | Both legs must complete within six months, extendable by the AD bank (Regulation 16) | Traders buying abroad and selling abroad |
| Traveller with personal effects | No | Not treated as an exporter (second proviso to Regulation 3(1)) | People relocating with household goods |
How does an exporter comply with the FEMA rules for exports step by step?
An exporter complies with the FEMA rules for exports by declaring the export on an EDF, receiving payment through an AD bank within the realisation period, and making sure the bank closes the EDPMS entry. Most of the reporting to RBI is done by the AD bank.
- Pick one AD bank to handle the export. If you receive an advance, route the advance and the later realisation through the same AD bank, or tell both banks if you switch (Regulation 10(1)). See what is an authorised dealer bank.
- Declare the export. Goods exporters file the EDF at the time of export, and at EDI ports it is deemed part of the shipping bill (Regulation 3(1)).
- Services exporters file the EDF within 30 days from the end of the month in which the invoice is raised. One EDF can cover all exports of that month (Regulation 3(2)). See EDF form for exports.
- Receive the full export value within nine months of shipment (goods) or invoice (services), or twelve months if invoiced or settled in rupees (Regulation 5(1)).
- Let the AD bank verify the transaction. It credits your account only after satisfying itself that the transaction is genuine, and closes or updates the EDPMS entry at the same time (Regulation 4(2)).
- If payment will be late or short, ask the AD bank for an extension or a reduction in export value, giving reasons (Regulations 5 and 6).
- Track open entries. The AD bank must follow up on outstanding EDPMS entries (Regulation 18(1)(f)), and you can check status with it. See how to check EDPMS outstanding.
What replaced the RBI Master Direction on Export of Goods and Services?
From 1 October 2026, the Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026 and A.P. (DIR Series) Circular No. 20 replaced the Master Direction on Export of Goods and Services (Circular No. 20, paras 4 and 7).
- The 2026 regulations supersede the Export of Goods and Services Regulations, 2015, except for things done before the supersession (preamble).
- Circular No. 20 also supersedes a long list of older export circulars, including those on SOFTEX, write-off, set-off, third party payments and EDPMS (Annex).
- AD banks now handle transactions made before 1 October 2026 that earlier needed RBI approval under the old rules (Regulation 20).
- The old Master Direction stays useful only for understanding past practice. See RBI Master Direction on exports and new FEMA export and import regulations.
How are small export invoices of up to ₹10 lakh handled under FEMA?
Where a shipping bill or invoice is up to ₹10 lakh, the AD bank may close the EDPMS entry on the exporter's declaration that payment has been realised in full or otherwise. Exporters may also give this declaration quarterly for bulk closure (first proviso to Regulation 4(2)).
- A reduction in export value, including non-realisation, of up to ₹10 lakh per shipping bill or invoice may be allowed on the exporter's declaration (proviso to Regulation 6).
- For more on closures, see EDPMS closure.
Which other FEMA export facilities can an AD bank allow?
The 2026 regulations let the AD bank approve several common situations directly, provided it is satisfied with the reasons or bona fides of the transaction.
- Set-off of export receivables against import payables with the same overseas buyer or supplier, or their group or associate companies (Regulation 7). See set-off of export receivables.
- Third party receipts for export transactions (Regulation 8). See third-party payments for exports.
- Closing an EDPMS entry for an export advance where no export was made and a refund is not possible (Regulation 18(1)(i)).
- Interest paid on export advances must stay within the all-in-cost ceiling for trade credit (Regulation 10(4)).
What are the FEMA deadlines and documents for exports from 1 October 2026?
The main FEMA deadlines for exports are the EDF filing date and the realisation period. Both depend on whether you export goods or services and the currency of the invoice. The table sets out each one under the 2026 regulations.
| Obligation | Deadline or rule | Who acts | Source | Best for |
|---|---|---|---|---|
| EDF for goods | At the time of export; deemed filed with the shipping bill at EDI ports | Exporter, to Customs (DTA) or the SEZ Development Commissioner | Regulations 2(1)(f) and 3(1) | Goods exporters |
| EDF for services and software | Within 30 days from the end of the invoice month; one EDF per month allowed | Exporter, to the specified authority: the AD bank, STPI for software, or the SEZ Development Commissioner in an SEZ | Regulation 3(2) | Freelancers, agencies, IT firms |
| EDF for services other than software | May be filed on or before the date payment is received | Exporter, to the AD bank | Regulation 3(2)(b) | Consultants paid quickly after invoicing |
| Realisation, foreign currency invoice | 9 months from shipment (goods) or invoice (services) | Exporter | Regulation 5(1)(a) | Most exporters |
| Realisation, rupee invoice or settlement | 12 months | Exporter | First proviso to Regulation 5(1) | Rupee trade settlements |
| Goods sent to an overseas warehouse | 9 months from the date of sale from the warehouse | Exporter | Regulation 5(1)(b) | Exporters stocking goods abroad |
| EDPMS entry of a services EDF | Within five working days of receiving the EDF | AD bank | Regulation 18(1)(b) | Checking that your EDF was recorded |
| Merchanting trade | Six months between the two legs, extendable | Trader and AD bank | Regulation 16(1)(a) | Merchanting traders |
What happens if an exporter breaks the FEMA rules for exports?
If an exporter breaks the FEMA rules for exports, the export stays open in EDPMS and the exporter can face a FEMA penalty after adjudication. Long delays also restrict how future exports can be paid for, and GST benefits on unpaid exports can be lost.
- FEMA penalty: Up to three times the sum involved where quantifiable, or up to ₹2 lakh where not, plus up to ₹5,000 for each day a contravention continues (FEMA section 13(1)).
- Advance only: If proceeds remain unrealised for more than one year after the due or extended date, further exports are allowed only against full advance or an irrevocable letter of credit (Regulation 13).
- Caution list: Exporters on RBI's caution list as on 30 September 2026 stay governed by that order until removed (proviso to Regulation 13). See RBI exporter caution list.
- GST on LUT: Services exported under LUT become liable to tax with interest if payment is not received within 15 days after one year from the invoice, or the FEMA period including extensions, whichever is later (CGST Rule 96A(1)(b)).
- Compounding: A contravention under section 13 may be compounded on an application by the person who committed it (FEMA section 15). See FEMA penalties and compounding.
Speak to your AD bank before the deadline. Ask for an extension of the EDF or realisation period, or a reduction in export value, and give reasons with buyer correspondence. Each AD bank must publish its policy and main SOP features on its website, including an appeal to a higher internal level (Regulation 19). See export proceeds not realised.
Which RBI rules and FEMA provisions set the export rules?
FEMA sections 7 and 8 set the duty to declare and realise exports, and RBI's Export and Import of Goods and Services Regulations, 2026 set the details from 1 October 2026. A.P. (DIR Series) Circular No. 20 gives the matching directions to AD banks and supersedes the old Master Direction.
| Circular or regulation | Clause | Date | Plain meaning | Best for |
|---|---|---|---|---|
| Foreign Exchange Management Act, 1999 | Sections 7, 8, 13 and 15 | 1999, as amended | Duty to declare exports and realise foreign exchange; penalties and compounding | Understanding the legal basis |
| FEMA (Export and Import of Goods and Services) Regulations, 2026, FEMA 23(R)/2026-RB | Regulations 3 to 8, 10, 13, 18 and 19 | 13 January 2026; in force 1 October 2026 | EDF, realisation period, EDPMS closure, set-off, third party receipts, reporting | Every exporter from 1 October 2026 |
| Amendment Regulations, 2026, FEMA 23(R)/(1)/2026-RB | Regulation 5(1); proviso to Regulation 13; Regulation 20 | 22 September 2026; Gazette 24 September 2026 | Cut the realisation period from 15 months to 9 (18 to 12 for rupee trade), added the caution list proviso and gave AD banks powers over older cases, 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 2, 4 and 7; Annex | 16 January 2026; in force 1 October 2026 | Directions to AD banks; supersedes the Master Directions on export and import and listed circulars | Checking which old circulars still apply |
| Manner of Receipt and Payment Regulations, 2023, FEMA 14(R)/2023-RB | Regulation 3 | December 2023, amended February 2025 | Receipts must come through an authorised bank or person, in rupees or foreign currency as allowed | Exporters choosing how to get paid |
| Master Direction: Export of Goods and Services | Whole direction | 1 January 2016; superseded 1 October 2026 | The old consolidated rulebook, including SOFTEX and write-off procedures | Exports and records before 1 October 2026 |
What are the common mistakes exporters make with FEMA export rules?
- Old rulebook: Following the Master Direction on Export of Goods and Services after 1 October 2026, when the 2026 regulations and Circular No. 20 apply.
- 15 months: Relying on the fifteen-month realisation period that was cut back to nine months by the 22 September 2026 amendment.
- No EDF: Assuming only goods exporters file an EDF. Regulation 3(2) requires services exporters to file one within 30 days from the end of the invoice month.
- SOFTEX habit: Continuing to prepare SOFTEX forms for software exports after 1 October 2026 without checking the EDF process with the AD bank or STPI.
- Split banks: Taking an advance through one AD bank and the balance through another without telling both, as Regulation 10(1) requires.
- Late requests: Asking for an extension or reduction only after the deadline has passed, with no record of efforts to collect from the buyer.
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, Preamble; Regulations 1 to 8, 10, 13, 15, 16, 18, 19, 20; 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 2, 4 and 7; Annex A list of superseded export circulars (checked 8 Oct 2026)
- The Foreign Exchange Management Act, 1999 (India Code), Sections 7, 8, 13(1) and 15(1) (checked 8 Oct 2026)
- Foreign Exchange Management (Manner of Receipt and Payment) Regulations, 2023, FEMA 14(R)/2023-RB, amended up to 12 February 2025, Regulation 3(1) and 3(2)(I) (checked 8 Oct 2026)
- Foreign Exchange Management (Export of Goods and Services) Regulations, 2015, FEMA 23(R)/2015-RB, Superseded by the 2026 regulations from 1 October 2026 (checked 8 Oct 2026)
- RBI Master Direction: Export of Goods and Services (FED Master Direction No. 16/2015-16), updated to 17 July 2026, superseded from 1 October 2026, Contents (Parts A to D) and para A.2 (checked 8 Oct 2026)
- Central Goods and Services Tax Rules, 2017: Rule 96A, Rule 96A(1)(b) (checked 8 Oct 2026)
Frequently asked questions
Is the RBI Master Direction on Export of Goods and Services still valid in 2026?
No. A.P. (DIR Series) Circular No. 20 superseded the Master Direction on Export of Goods and Services from 1 October 2026. Exports from that date follow the Export and Import of Goods and Services Regulations, 2026. The old direction still explains how earlier exports were handled, and AD banks now deal with those older cases.
Do freelancers need to file an EDF under the FEMA export rules?
Regulation 3(2) of the 2026 regulations requires every exporter of services to file an EDF with the specified authority, which is the AD bank for services other than software outside an SEZ. A freelancer can file one EDF for all invoices of a month, within 30 days from the end of that month. Confirm the format with your AD bank.
Has the EDF replaced the SOFTEX form for software exports under FEMA?
Circular No. 20 superseded the SOFTEX circulars from 1 October 2026, and the 2026 regulations treat software as a service declared on the EDF. The specified authority for software is the AD bank or STPI in the domestic tariff area, and the SEZ Development Commissioner in an SEZ. See what is SOFTEX for the history.
What is the FEMA export realisation period for exports invoiced in Indian rupees?
Exports invoiced or settled in Indian rupees must be realised within twelve months under the first proviso to Regulation 5(1). The clock starts from the shipment date for goods, the invoice date for services, and the date of sale for goods sent to an overseas warehouse. The AD bank may extend this period on request.
Can an exporter receive payment from a third party under FEMA rules?
Yes, if the AD bank allows it. Regulation 8 of the 2026 regulations lets an AD bank permit third party receipts for export transactions when it is satisfied that the transactions are bona fide. Keep the contract and any agreement showing why the third party is paying, since the bank will ask for evidence.
Does an AD bank charge penalties for late EDF or late realisation under FEMA?
Regulation 19(3) says an AD bank shall not levy any charge or penalty on its exporter for a regulatory delay or violation by that exporter. Its charges for handling transactions must be reasonable and proportional. Penalties for contraventions are imposed under FEMA section 13 after adjudication, which is a separate process.
Does the FEMA ₹10 lakh declaration rule apply to each export invoice?
Yes. Under Regulation 4(2), where a shipping bill or services invoice is up to ₹10 lakh or its foreign currency equivalent, the AD bank may close the EDPMS entry on the exporter's declaration. The exporter can also give a quarterly declaration for bulk closure. Larger invoices are closed after the bank confirms realisation.