Which RBI Circulars Should Exporters and Freelancers Track in 2025-26?
- Author:
- Manoj Sharma
- Verified by:
- Editorial team
- Published:
- Last modified:
Short answer
The key RBI circulars for exporters in 2025-26 are the FEMA (Export and Import of Goods and Services) Regulations, 2026 and A.P. (DIR Series) Circular No. 20, both effective 1 October 2026. Export proceeds must be realised within nine months. Invoices up to ₹10 lakh can be closed in EDPMS on the exporter's declaration.
| Applies to | Governed by | Deadline | Penalty | Last verified |
|---|---|---|---|---|
| Exporters of goods, software and services from India, including freelancers and small firms that invoice overseas clients | FEMA, 1999; Notification 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 nine months, or twelve months if invoiced or settled in INR (Regulations 3(2) and 5(1)) | No fixed penalty in these circulars. Exports unrealised for more than one year after the due date can continue only against full advance or an irrevocable letter of credit (Regulation 13) | 8 Oct 2026 |
What are RBI circulars for exporters, and which types matter in 2026?
RBI circulars for exporters are the notifications and directions that tell authorised dealer (AD) banks how to handle export receipts under FEMA. Most export rules sit in FEMA regulations and in A.P. (DIR Series) circulars addressed to AD banks. RBI publishes all of them on its notifications page, newest first.
- Regulations: FEMA notifications numbered 23(R) set the legal rules on export declaration, realisation and EDPMS. The current one is FEMA 23(R)/2026-RB, in force from 1 October 2026.
- A.P. circulars: A.P. (DIR Series) circulars are instructions to AD banks under sections 10(4) and 11(1) of FEMA. Circular No. 20 is the one that replaced the old export Master Direction.
- Master Directions: Master Directions used to collect all export instructions in one place. The export and import Master Directions stand superseded from 1 October 2026 under paragraph 4 of Circular No. 20.
- Credit directions: Directions from RBI's Department of Regulation cover export credit from banks, such as the Trade Relief Measures Directions, 2026. These affect loans, not the FEMA paperwork.
- Payment circulars: Payment system circulars set service standards for banks, such as the April 2026 circular on faster cross-border inward payments.
For a plain summary of the new framework itself, see FEMA export and import regulations update. This page tracks each circular by date so you can see what changed and what to do.
Which exporters are affected by the 2025-26 RBI circulars?
Every exporter who receives foreign exchange through an AD bank is affected, because the 2026 regulations cover goods, software and services in one framework. Regulation 2(1) says services include software. Some circulars affect only borrowers, merchanting traders or exporters invoicing in rupees.
| Exporter type | Affected | Why | Best for |
|---|---|---|---|
| Freelancer or service exporter | Yes | Must file a services EDF and realise invoices within nine months under Regulations 3(2) and 5 | Designers, developers, consultants paid from abroad |
| Software exporter | Yes | SOFTEX circulars are superseded; the specified authority for software is the AD bank or STPI under Regulation 2(1)(f)(iii) | IT firms and STPI units |
| Goods exporter | Yes | EDF is deemed part of the shipping bill at EDI ports under Regulation 3(1) | Manufacturers and merchant exporters |
| Exporter invoicing in INR | Yes | Twelve months to realise under Regulation 5(1); vostro account rules in Circular No. 19 | Exporters to partner-country buyers paying in rupees |
| Exporter with bank export credit | Possibly | Longer credit tenor for credit disbursed up to 30 June 2026 under the 2025 and 2026 trade relief directions, if the bank agrees | Exporters with packing credit or post-shipment loans |
| Merchanting trader | Yes | Six-month limit between the two legs under Regulation 16 | Traders buying abroad and selling abroad |
How should an exporter track and act on new RBI circulars?
An exporter should check RBI's notifications page each month, note any FEMA or A.P. (DIR Series) item that mentions export, and read its effective date. Then confirm with the AD bank how its process will change. Most circulars ask AD banks to inform their customers.
- Open RBI's notifications page and filter by year and month.
- Look for titles with Export, EDPMS, FEMA 23(R), Vostro, Merchanting or cross-border payments.
- Read the date the circular comes into force. Many FEMA rules start on a stated date, not on the date of issue.
- Check the annex for superseded circulars. Circular No. 20 lists 96 export circulars it replaces.
- Read your AD bank's export policy and SOP. Regulation 19(4) requires each AD bank to disclose its policy and the main features of its SOP on its website.
- Update your invoice, EDF and follow-up routine, and keep a dated note of the rule you relied on.
How do you tell whether an RBI circular applies to an exporter?
Read who it is addressed to and the law it is issued under. A.P. (DIR Series) circulars issued under FEMA, like Circular No. 12 of October 2025, change how banks handle export entries. Directions issued under the Banking Regulation Act, like the Trade Relief Measures Directions, change bank lending instead.
- Addressed to AD Category-I banks and issued under FEMA: affects export receipts and EDPMS.
- Addressed to banks or lenders under banking law: affects export credit only.
- Addressed to payment system participants: affects how fast money reaches your account.
What does the effective date of an RBI circular mean for exporters?
The effective date decides which rule applies to a transaction. The 2026 regulations are dated 13 January 2026 and came into force on 1 October 2026. Regulation 20 lets AD banks handle older export cases that once needed RBI approval.
Why does the AD bank process change after an RBI circular?
The 2026 framework moves many decisions from RBI to AD banks. Extensions, reductions in value and third-party receipts are now decided by the AD bank under Regulations 5, 6 and 8. Each bank sets its own documents and timelines in its SOP, so ask your bank for its version.
Which RBI circulars for exporters were issued between June 2025 and October 2026?
The table lists RBI items from June 2025 to the check date of 8 October 2026 that touch export receipts, export credit or inward payments. Two items changed the realisation period and later reversed it, so read the dates closely. Items dealing only with imports, ECB or money changing are left out.
| Circular | Date | Summary | Action | Best for |
|---|---|---|---|---|
| FEMA 23(R)/(6)/2025-RB | 24 June 2025 | Added tugs, dredgers and offshore support vessels, subject to re-import, to Regulation 4 of the 2015 export regulations | None for most exporters | Marine service firms |
| A.P. (DIR Series) Circular No. 11 | 1 October 2025 | Raised the merchanting foreign exchange outlay limit from four to six months | Plan both legs within six months | Merchanting traders |
| A.P. (DIR Series) Circular No. 12 | 1 October 2025 | EDPMS entries up to ₹10 lakh closed on the exporter's declaration; quarterly bulk declarations allowed; no penal charges | Send declarations to your AD bank | Small exporters with old open entries |
| Master Direction on Payment Aggregators | 15 September 2025 | Para 11(h): cross-border payment aggregators must give the exporter's AD bank the documents needed for EDPMS closure | Ask your provider for the closure documents | Exporters paid through a payment aggregator |
| FEMA 23(R)/(7)/2025-RB | 13 November 2025 | Realisation period under the 2015 regulations raised from nine to fifteen months; advance-shipment window raised from one to three years | Superseded on realisation; check older invoices with your bank | Exporters with invoices from late 2025 |
| Trade Relief Measures Directions, 2025 | 14 November 2025 | Eligible borrowers in listed sectors could get a moratorium for September to December 2025 and export credit up to 450 days | Ask your lender if you qualify | Exporters with bank loans |
| FEMA 23(R)/2026-RB | 13 January 2026 | New Export and Import of Goods and Services Regulations replacing the 2015 regulations from 1 October 2026 | Learn the EDF and EDPMS rules | Every exporter |
| A.P. (DIR Series) Circular No. 20 | 16 January 2026 | Supersedes the export and import Master Directions and 96 export circulars, including SOFTEX, from 1 October 2026 | Stop following old Master Direction steps | Every exporter |
| Interest subvention circular | 19 January 2026 | Interest subvention on pre- and post-shipment export credit under the Export Promotion Mission, on a pilot basis | Ask your lender about eligibility | Exporters using export credit |
| Trade Relief Measures Directions, 2026 | 31 March 2026 | Export credit tenor up to 450 days for credit disbursed till 30 June 2026; stuck packing credit may be repaid from other legitimate sources | Discuss tenor with your lender | Exporters with export credit |
| Faster cross-border inward payments | 9 April 2026 | Banks to inform customers of inward messages immediately and aim to credit same business day; effective six months from issue (9 October 2026) | Ask your bank about intimation and credit timing | Freelancers waiting on inward payments |
| FEMA 23(R)/(8)/2026-RB | 5 June 2026 | Realisation period under the 2015 regulations reduced from fifteen back to nine months | Plan collections on nine months | Every exporter |
| A.P. (DIR Series) Circular No. 19 | 17 July 2026 | Consolidates Special Rupee Vostro Account rules; AD banks may open an extra current account for exporters for INR trade settlement | Ask your bank if you invoice in INR | Exporters settling in rupees |
| A.P. (DIR Series) Circular No. 21 | 8 September 2026 | Withdraws seven old circulars on ECB, rupee borrowing and money transfer; none concern export receipts | No action | Reference only |
| FEMA 23(R)/(1)/2026-RB | 22 September 2026 | Sets realisation at nine months (twelve for INR) in the 2026 regulations; keeps existing caution-list orders; lets AD banks handle older cases | Use nine months from 1 October 2026 | Every exporter |
What happens when an exporter misses a change in RBI circulars?
An exporter who misses a change can plan collections on the wrong deadline or leave EDPMS entries open. The most serious outcome is under Regulation 13: exports unrealised for over one year after the due date can continue only against full advance or an irrevocable letter of credit.
- Wrong deadline: Planning on fifteen months after the September 2026 amendment restored nine months can leave invoices overdue.
- Open entries: An AD bank must follow up on outstanding EDPMS entries under Regulation 18(1)(f), so unclosed invoices lead to bank queries.
- Restricted exports: After one year beyond the due date, Regulation 13 limits further exports to full advance or an irrevocable letter of credit.
- Caution list: Exporters on the caution list on 30 September 2026 stay under the earlier RBI order until removed, under the proviso to Regulation 13.
- Late EDF: A services EDF filed after 30 days needs the AD bank to accept your reasons under Regulation 3(2)(c).
Ask your AD bank for an extension of realisation time, citing reasons, under the second proviso to Regulation 5(1). For invoices up to ₹10 lakh, file a declaration to close or reduce the entry under Regulations 4(2) and 6. Your bank cannot charge a penalty for a regulatory delay under Regulation 19(3).
Which RBI regulation or circular sets each export rule now in force?
From 1 October 2026 the rules come from FEMA 23(R)/2026-RB as amended on 22 September 2026, with Circular No. 20 as the covering instruction to banks. The older 2015 regulations and Master Directions apply only to things done before that date.
| Circular or regulation | Clause | Date | Plain meaning | Best for |
|---|---|---|---|---|
| FEMA 23(R)/2026-RB | Regulation 3(2) | 13 January 2026; in force 1 October 2026 | Services EDF within 30 days from the end of the invoice month; one EDF can cover a whole month | Freelancers and service exporters |
| FEMA 23(R)/2026-RB | Regulation 4(2) | 1 October 2026 | EDPMS entries up to ₹10 lakh close on the exporter's declaration, or quarterly in bulk | Small exporters |
| FEMA 23(R)/(1)/2026-RB | Regulation 5(1) | 22 September 2026; in force 1 October 2026 | Nine months to realise; twelve months if invoiced or settled in INR; AD bank may extend | Every exporter |
| FEMA 23(R)/2026-RB | Regulation 6 | 1 October 2026 | AD bank may allow reduced realisation; up to ₹10 lakh on declaration | Exporters with short payments |
| FEMA 23(R)/2026-RB | Regulations 7 and 8 | 1 October 2026 | AD bank may allow set-off within the realisation period, and third-party receipts if satisfied of their bona fides | Exporters with group or agent payers |
| FEMA 23(R)/2026-RB | Regulation 10(1) | 1 October 2026 | Advance and final payment through the same AD bank, unless both banks are told | Exporters taking advances |
| FEMA 23(R)/2026-RB | Regulation 18(2) | 1 October 2026 | AD banks report all foreign trade transactions in FETERS under RBI's guidelines | Anyone choosing a purpose code |
| A.P. (DIR Series) Circular No. 20 | Paragraph 4 and Annex | 16 January 2026; effective 1 October 2026 | Old export and import Master Directions and listed circulars stand superseded | Exporters using older guides |
What mistakes do exporters make when reading RBI circulars?
- Old guides: Following the export Master Direction after 1 October 2026, when Circular No. 20 superseded it.
- Fifteen months: Relying on the November 2025 fifteen-month rule, which FEMA 23(R)/(8)/2026-RB reversed.
- Issue date: Treating the issue date as the start date, when the circular names a later effective date.
- SOFTEX: Filing SOFTEX for software exported from 1 October 2026, when the 2026 regulations use the EDF.
- Loan rules: Reading trade relief directions as FEMA relief. They change loan tenor only, not the realisation period.
- Bank charges: Paying penalty charges for delays. Regulation 19(3) bars AD banks from levying them.
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 (amended up to 22 September 2026), Regulations 1, 2(1), 3, 4(2), 5, 6, 7, 8, 10(1), 13, 16, 18, 19, 20 (checked 8 Oct 2026)
- Foreign Exchange Management (Export and Import of Goods and Services) (Amendment) Regulations, 2026, FEMA 23(R)/(1)/2026-RB, 22 September 2026, Paras 2 to 4 (checked 8 Oct 2026)
- A.P. (DIR Series) Circular No. 20, Export and Import of Goods and Services, RBI/2025-26/194, 16 January 2026, Paras 1, 4, 6, 7 and Annex (checked 8 Oct 2026)
- A.P. (DIR Series) Circular No. 12, EDPMS and IDPMS reconciliation of entries, RBI/2025-26/89, 1 October 2025, Paras 3 and 4 (checked 8 Oct 2026)
- A.P. (DIR Series) Circular No. 11, Merchanting Trade Transactions, review of time period for outlay of foreign exchange, 1 October 2025, Para 2 (checked 8 Oct 2026)
- Foreign Exchange Management (Export of Goods & Services) (Amendment) Regulations, 2025, FEMA 23(R)/(6)/2025-RB, 24 June 2025, Para 2 (checked 8 Oct 2026)
- Foreign Exchange Management (Export of Goods and Services) (Second Amendment) Regulations, 2025, FEMA 23(R)/(7)/2025-RB, 13 November 2025, Paras 2 and 3 (checked 8 Oct 2026)
- Foreign Exchange Management (Export of Goods and Services) (First Amendment) Regulations, 2026, FEMA 23(R)/(8)/2026-RB, 5 June 2026, Para 2 (checked 8 Oct 2026)
- Reserve Bank of India (Trade Relief Measures) Directions, 2025, RBI/2025-26/96, 14 November 2025, Paras 7, 9 and 10 (checked 8 Oct 2026)
- Reserve Bank of India (Trade Relief Measures) Directions, 2026, RBI/2025-26/263, 31 March 2026, Paras 1, 5, 6 and 7 (checked 8 Oct 2026)
- Interest Subvention for Pre- and Post-Shipment Export Credit under Export Promotion Mission, RBI/2025-26/195, 19 January 2026, Paras 1 to 3 (checked 8 Oct 2026)
- Guidelines to facilitate faster cross-border inward payments, RBI/2026-27/08, 9 April 2026, Paras 3 and 4 (checked 8 Oct 2026)
- A.P. (DIR Series) Circular No. 19, Special Rupee Vostro Accounts, RBI/2026-27/203, 17 July 2026, Paras 2 to 4 (checked 8 Oct 2026)
- A.P. (DIR Series) Circular No. 21, Review of Circulars issued under FEMA, RBI/2026-27/254, 8 September 2026, Para 2 and Annex (checked 8 Oct 2026)
- RBI Master Direction on Regulation of Payment Aggregator (PA), RBI/DPSS/2025-26/141, 15 September 2025, Para 11(h) (checked 8 Oct 2026)
- RBI Notifications page, Listing by year and month (checked 8 Oct 2026)
Frequently asked questions
Is the RBI Master Direction on Export of Goods and Services still valid after October 2026?
No. A.P. (DIR Series) Circular No. 20 says the Master Direction on Export of Goods and Services stands superseded from 1 October 2026. AD banks now follow the 2026 FEMA regulations and their own SOPs. The old Master Direction still matters for transactions done before that date.
What is the export realisation period under RBI rules in October 2026?
The period is nine months from the invoice date for services and from shipment for goods, under Regulation 5(1). It is twelve months when the export is invoiced or settled in Indian rupees. Your AD bank may extend either period if you give reasons. See export realisation period.
Did RBI ever allow fifteen months for export realisation?
Yes, for a short period. FEMA 23(R)/(7)/2025-RB raised the period to fifteen months in November 2025. FEMA 23(R)/(8)/2026-RB reduced it to nine months again in June 2026. The 2026 regulations were also amended to nine months before they took effect.
Does the ₹10 lakh EDPMS declaration rule apply to freelancers?
Yes. Regulation 4(2) lets an AD bank close an EDPMS entry for an invoice up to ₹10 lakh on the exporter's declaration that payment was realised. A freelancer can also send one declaration each quarter for bulk closure. See EDPMS closure for the steps.
Does the RBI faster inward payments circular apply to every bank?
The April 2026 circular is addressed to all scheduled commercial banks. It asks banks to tell customers about an inward payment as soon as the message arrives. Banks should aim to credit payments received in market hours the same business day, subject to FEMA checks.
Where can an exporter find new A.P. (DIR Series) circulars?
New A.P. (DIR Series) circulars appear on RBI's notifications page, which lists items by date and lets you filter by year and month. Each circular shows its RBI reference number, date and the authority it is issued under. Your AD bank should also inform customers of relevant changes.
Does SOFTEX still apply to software exports after October 2026?
No. Circular No. 20 supersedes the SOFTEX circulars from 1 October 2026. Software is treated as a service, and the exporter files an EDF with the AD bank or STPI under the 2026 regulations. See SOFTEX form filing for the earlier process.