The realisation clock changes on 01-10-2026
The exporter's last deadline is not the shipment. It is the money coming home, on a clock that moved four times in under a year, and every open bill is judged on the window in force on its own date of export.
Export proceeds for goods shipped on or after 01-10-2026 must be realised and repatriated within nine months of the date of shipment, or twelve months where the export is invoiced or settled in Indian Rupees, under regulation 5(1) of the Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026 as amended by Notification No. FEMA 23(R)/(1)/2026-RB dated 22-09-2026. The 2026 Regulations as first notified said fifteen and eighteen months, and that text never came into force. The fifteen month window that did exist ran only for exports from 14-11-2025 to 04-06-2026, and those bills are still open in ledgers today.
What is the realisation period, and under which instrument?
It depends on the date of export, because the period has been changed twice by amending notification and once more by a new set of regulations:
- Exports before 14-11-2025: nine months. Regulation 9(1) of the Foreign Exchange Management (Export of Goods and Services) Regulations, 2015, Notification No. FEMA 23(R)/2015-RB dated 12-01-2016, provides that the full export value shall be realised and repatriated to India within nine months from the date of export.
- Exports from 14-11-2025 to 04-06-2026: fifteen months. Notification No. FEMA 23(R)/(7)/2025-RB dated 13-11-2025 substituted "fifteen months" for "nine months" in regulation 9(1), in force from its publication in the Official Gazette on 14-11-2025.
- Exports from 05-06-2026 to 30-09-2026: nine months. Notification No. FEMA 23(R)/(8)/2026-RB dated 05-06-2026 substituted "nine months" back for "fifteen months", in force from its publication in the Official Gazette the same day.
- Exports on or after 01-10-2026: nine months, or twelve in rupees. Regulation 5(1) of the Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026, Notification No. FEMA 23(R)/2026-RB dated 13-01-2026, runs the period from the date of shipment for goods, the date of invoice for services and the date of sale for goods exported to a warehouse outside India. Notification No. FEMA 23(R)/(1)/2026-RB dated 22-09-2026, in force from the same 01-10-2026, substituted "nine months" for "fifteen months" in clauses (a) and (b), and "twelve months" for "eighteen months" in the rupee proviso.
The Reserve Bank's FED Master Direction No. 16/2015-16 on Export of Goods and Services restates the 2015 position at paragraph A.2(i), and its footnotes record both substitutions. It is the operative text an authorised dealer bank works from for exports under the 2015 Regulations, and the regulation is where its authority comes from. Paragraphs A.2(ii) and A.2(iii) record two older exceptions: fifteen months for exports made on or before 31-07-2020, and fifteen months from shipment for goods exported to a warehouse outside India.
The same Master Direction carries most of the rest of the exporter's realisation obligations. Paragraph C.15(iv) records that with the Export Data Processing and Monitoring System operational from 01-03-2014, realisation of all export transactions with shipping documents after 28-02-2014 is reported in EDPMS. Paragraph C.28 deals with the exporters' caution list. Paragraph C.30 deals with issuance of the electronic Bank Realisation Certificate. It is one document, and most of what an exporter needs to know about the money coming home is inside it.
What changes on 01-10-2026?
Not the length of the window for a foreign currency export: it is nine months for an export on 30-09-2026 and nine months for an export on 01-10-2026. What changes is the instrument, the day the clock starts and the rupee rule. The 2015 Regulations count from the date of export; the 2026 Regulations count from the date of shipment for goods and the date of invoice for services. A rupee invoiced or rupee settled export gets twelve months under the first proviso to regulation 5(1), where the 2015 Regulations had no separate rupee period.
Three other provisions arrive on the same day. Regulation 6 lets an authorised dealer permit a reduction in export value on a declaration from the exporter where the export value is up to Rs 10 lakh per shipping bill or invoice, which takes a class of small short realisations out of the approval queue. Regulation 13 provides that where proceeds remain unrealised beyond one year from the due date, or any extension allowed, the exporter may undertake further exports only against full advance or an irrevocable letter of credit. And Notification No. FEMA 23(R)/(1)/2026-RB adds a proviso to regulation 13 keeping an exporter on the Caution List as on 30-09-2026 governed by its order under regulation 16 of the 2015 Regulations until removed from the list, and a new regulation 20 under which authorised dealers handle transactions undertaken before 01-10-2026 that hitherto required approval of the Reserve Bank.
Why do different windows run at once?
Because the fifteen month cohort is still open. An export made on 04-06-2026 on fifteen months falls due on 04-09-2027, while an export made the next day on nine months falls due on 05-03-2027, six months earlier. Until the last of the fifteen month bills falls due, exports on nine, fifteen and, for rupee invoices after 01-10-2026, twelve months sit in the same ledger. A diary entry that says nine months, or a spreadsheet column that says fifteen, will be wrong for part of the book. The window belongs to the export, not to the calendar the reader happens to be looking at when they open the file.
What we could not establish: none of the amending notifications says whether it reaches an export already made. Notification No. FEMA 23(R)/(8)/2026-RB substitutes nine months for fifteen from 05-06-2026 with no saving clause for exports already shipped on fifteen, and the 2026 Regulations supersede the 2015 Regulations except in respect of things done or omitted to be done before such supersession. This guide, and the tool, keep each export on the window in force on its date of export, but neither instrument says so in terms. Where a decision turns on it, your authorised dealer bank's position on your own bill governs.
This is the general form of the rule the whole library is built on: match the instrument to the transaction's own dates. The realisation clock suggests the window for a shipping bill or Let Export Order date and names the instrument behind it, so two bills can be compared side by side rather than argued about.
What can be done when the money does not fully arrive?
Short realisation has routes, and for exports under the 2015 Regulations they are set out in the Master Direction. Paragraph C.17(i) of FED Master Direction No. 16/2015-16 permits a reduction in invoice value of up to 25 percent of invoice value in specified circumstances, and paragraph C.17(i)(c) excludes exporters on the Reserve Bank's exporters' caution list from that route. Paragraph C.23.1 caps self write-off by an exporter other than a status holder exporter at 5 percent of the total export proceeds realised during the preceding calendar year.
From 01-10-2026 regulation 6 of the 2026 Regulations adds the declaration route for export values up to Rs 10 lakh per shipping bill or invoice. How that sits alongside the existing 25 percent reduction route is not something we can state from the instruments we have verified, so check the position in force on your own shipping bill's date. What does not change either way is the evidence: the exporter has to be able to say which shipping bill, which amount and why, from the file. That is a documentation problem before it is a foreign exchange one, which is the argument in One invoice value, thirteen assertions.
What does an unmatched EDPMS entry cost before anyone calls it late?
The cost of drift accrues quietly, well inside the window. EDPMS is the Reserve Bank's Export Data Processing and Monitoring System, and FED Master Direction No. 16/2015-16 records at paragraph C.15(iv) that realisation of all export transactions with shipping documents after 28-02-2014 is reported in it. An entry left unmatched there reaches the bank's follow-up queue, and the bank charges roughly Rs 500 per bill for chasing it. That charge arrives long before anything is formally late.
Left long enough it travels further: to the exporters' caution list, which the Master Direction deals with at paragraph C.28, and being caution listed also closes the reduction in value route under paragraph C.17(i)(c). The practical penalty is not a fine, it is a stoppage, and the exporter usually discovers it at the moment they try to ship again. That is the worst possible moment to find out, because the goods are already committed.
How does the loop actually close?
With the eBRC. FED Master Direction No. 16/2015-16 deals with issuance of the electronic Bank Realisation Certificate at paragraph C.30, and it is issued once the remittance is matched to the shipping bill. Everything before that is an open item with a running clock, and everything after it is settled. The eBRC is also the artefact downstream schemes ask for, so a realisation left unclosed is not only a foreign exchange exposure, it is a blocked claim sitting on a separate deadline of its own. The two clocks on every RoDTEP claim covers that second set of dates.
Purser holds the window on the shipment record from its own date of export, so an export made in March 2026 is judged on fifteen months, one made in August on nine, and a rupee invoice made in October on twelve, without anyone re-deciding the rule per file. It flags entries drifting toward the bank's follow-up queue while they are still cheap to fix. Purser never submits to a government portal, and it never sends an outbound message without a recorded human approval event: the reminder is yours to send, and the arithmetic is not yours to redo.
Where to go from here
Realisation is the last clock on an export file, and it is the one most likely to be judged against the wrong rule while three windows are open at once.
- The other export clock. The two clocks on every RoDTEP claim covers the scrip creation window and the validity window, both of which run off the same shipment.
- Why the entry did not match. One invoice value, thirteen assertions traces the field that has to agree between the shipping bill and the remittance.
- The same discipline on the import leg. Half of India's bills of entry get amended, and for the same reason: the data, not the timing.
- Compute the window for one bill. The realisation clock takes a shipping bill or Let Export Order date and suggests the window in force on it, with the instrument.
Frequently asked questions
How long does an exporter have to realise export proceeds?
It depends on the date of export. Exports on or after 01-10-2026 have nine months from the date of shipment, or twelve months where the export is invoiced or settled in Indian Rupees, under regulation 5(1) of the Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026 as amended by Notification No. FEMA 23(R)/(1)/2026-RB dated 22-09-2026. Exports from 05-06-2026 to 30-09-2026 have nine months, exports from 14-11-2025 to 04-06-2026 have fifteen months, and exports before 14-11-2025 have nine months, all from the date of export under regulation 9(1) of the Foreign Exchange Management (Export of Goods and Services) Regulations, 2015 as amended by Notifications No. FEMA 23(R)/(7)/2025-RB and FEMA 23(R)/(8)/2026-RB.
Did the 2026 Regulations extend the realisation period to fifteen months?
No, not in force. The Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026 as notified on 13-01-2026 said fifteen months, and eighteen for rupee exports, but Notification No. FEMA 23(R)/(1)/2026-RB dated 22-09-2026 substituted nine months and twelve months before the Regulations came into force on 01-10-2026. The only fifteen month window that was ever in force applied to exports from 14-11-2025 to 04-06-2026, under Notification No. FEMA 23(R)/(7)/2025-RB.
What changes for reduction in value from 01-10-2026?
Regulation 6 of the Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026 provides that where the export value is up to Rs 10 lakh per shipping bill or invoice, a reduction in export value may be permitted on a declaration from the exporter, removing that class of short realisation from the approval route. The existing route under paragraph C.17(i) of FED Master Direction No. 16/2015-16 permits a reduction of up to 25 percent of invoice value, and paragraph C.17(i)(c) excludes exporters on the Reserve Bank's caution list from it.
What happens if an EDPMS entry stays unmatched?
An unmatched EDPMS entry reaches the authorised dealer bank's follow-up queue, where the bank charges roughly Rs 500 per bill for chasing it, and if it stays open it can reach the exporters' caution list, which blocks future shipping bills. Caution listing also closes the reduction in value route under paragraph C.17(i)(c) of FED Master Direction No. 16/2015-16.
How does an export realisation actually close?
An export realisation closes with the electronic Bank Realisation Certificate, issued once the remittance is matched to the shipping bill; FED Master Direction No. 16/2015-16 deals with its issuance at paragraph C.30. Until then the entry is an open item with a running clock, and because downstream schemes ask for the eBRC, an unclosed realisation is a blocked claim as well as a foreign exchange exposure.