A S BANKA ADVISORS

If you export goods or services, one FEMA number governs your cash flow more than almost any other: the realisation period, the outer limit within which you must bring in and repatriate the full value of an export. Over the last eight months that number has moved three times. If you are still planning around the figure you remember from last year, you may be walking a shipment straight into a contravention.

The number moved three times in eight months

Here is the sequence, stripped to what matters. The base rule under Regulation 9 of the FEMA (Export of Goods and Services) Regulations, 2015 was 9 months. In November 2025, RBI raised it to 15 months through the Second Amendment Regulations, 2025 to relieve exporters facing weak global demand and shipping stress. Then, through the First Amendment Regulations, 2026 (Notification FEMA 23(R)/(8)/2026-RB dated June 5, 2026), RBI substituted “fifteen months” with “nine months” and restored the 9-month window. Finally, from October 1, 2026, a brand-new consolidated code, the FEMA (Export and Import of Goods and Services) Regulations, 2026, takes over and again sets 15 months, or 18 months where the export is invoiced or settled in Indian Rupees.

The net effect is a short 9-month trough sitting between June and September 2026, wedged between two 15-month regimes. That trough is where most exporters will get caught.

The rule that actually decides your deadline

The single most important point: your realisation window is fixed by the date of export of each shipment, not by today’s date. Map every open shipment to the right band:

• On or after October 1, 2026: 15 months, or 18 months if invoiced or settled in INR (FEMA 23(R)/2026-RB).
• June 5 to September 30, 2026: 9 months (First Amendment Regulations, 2026).
• Roughly November 14, 2025 to June 4, 2026: 15 months (Second Amendment Regulations, 2025).
• Before the November 2025 extension: 9 months (Regulation 9, 2015 Regulations).

Watch the boundaries most carefully: shipments near June 4 to June 5, 2026 and near September 30 to October 1, 2026 fall on either side of a regime change, so confirm each date against the actual RBI notifications before you certify realisation.

Why this is a live risk, not a filing footnote

Miss the realisation deadline without an approved extension and you are in contravention of FEMA, exposed to compounding, and your AD bank flags the open entry in the EDPMS system. The trap in 2026 is quiet: if you shipped in June to September and your buyer sits on longer credit terms, you may hit the 9-month limit far sooner than the 15-month rule you had mentally budgeted. Review your export receivables ageing against a 9-month clock, not a 15-month one.

What the October 1 code changes beyond the number

The 2026 code is a full rewrite, and it carries easements worth building into your process now, even though they only take effect from October 1: realisation for warehouse exports runs from the date of sale rather than shipment; monitoring-system entries for transactions up to Rs 10 lakh can be closed on the exporter or importer declaration instead of full documentation; closure declarations can be filed on a consolidated quarterly basis; and AD banks get clearer authority to grant extensions and permit set-off on bona fide transactions.

What to do this week

1. List every open export shipment and tag its exact date of export.
2. Map each shipment to the correct realisation window using the bands above.
3. Flag any June to September 2026 shipment where realisation will genuinely run past 9 months.
4. Engage your AD bank early for an extension, rather than letting the entry breach and dealing with it later.

This applies to every exporter of goods and services, including SEZ, EOU, EHTP, STP and BTP units and Status Holder exporters, plus the AD banks and CAs who certify their realisation.

Download the full carousel PDF for the date-of-export map and action plan in one page.

Navigating a cross-border realisation deadline or an extension application? Talk to an Expert. CA Adityavikram Banka, Founder, A S Banka Advisors Private Limited. Book a quick call: https://calendly.com/asbanka-info/30min