Trade Policy
FEMA 2026: 9 vs 12 Months? 15/18-Month Myth Explained
No, the FEMA 2026 export deadline is not 15 or 18 months. The January 2026 text said 15/18, but the 22 September 2026 amendment cut it to 9 months — 12 where the export is invoiced and/or settled in INR — before the rules took effect on 1 October 2026.
Short answer: 9 months, or 12 for INR exports — not 15 or 18
From 1 October 2026, an Indian exporter must realise and repatriate the full export value within 9 months — or 12 months where the export is invoiced and/or settled in INR. The 15-month and 18-month figures you still see in blogs and advisor notes come from the January 2026 text, which was amended on 22 September 2026 before it ever took effect.
| Type of export | Period | Clock starts from |
|---|---|---|
| Goods (not sent to a warehouse abroad) | 9 months | Date of shipment |
| Services, including software | 9 months | Date of invoice |
| Goods sent to a warehouse outside India | 9 months | Date of sale from the warehouse |
| Project exports | As per contract | Payment terms of the contract |
| Any of the above, invoiced and/or settled in INR | 12 months | Same start date as that export type |
General information, not legal advice
This is a practical guide to the FEMA 2026 realisation framework, not legal advice. Your AD bank decides on extensions, reductions, and closures on your transaction and documents. Confirm any transaction-specific position with your AD bank in writing.
Timeline of the confusion: how 15/18 became 9/12
The myth has a real source — the numbers genuinely appeared in official text. They just never became the operative rule. Here is the sequence:
- 13 January 2026: RBI notifies FEMA (Export and Import of Goods and Services) Regulations, 2026 — Regulation 5(1) says 15 months, with 18 months for INR-invoiced or settled exports. Effective date set as 1 October 2026.
- January–September 2026: advisors, blogs, and finance teams plan around the 15/18-month window. Some coverage still circulates today.
- 5 June 2026: separately, the old 2015 export regulations are amended back from 15 to 9 months for the interim period.
- 22 September 2026: RBI notifies the Amendment Regulations, substituting 9 months for 15 months and 12 months for 18 months in Regulation 5(1) — published in the Gazette on 24 September 2026.
- 1 October 2026: the 2026 Regulations commence — with the shorter 9/12 timelines. The 15-month figure never takes effect.
So if a colleague, consultant, or article cites 15 or 18 months for post-October 2026 exports, they are reading the superseded January text. Reset any receivable ageing built on 15 months to 9 months (12 for INR exports).
9 vs 12 vs 15 vs 18: the comparison that ends the debate
| Provision | January 2026 text (never took effect) | Operative from 1 Oct 2026 |
|---|---|---|
| Regulation 5(1)(a) — goods and services | 15 months | 9 months |
| Regulation 5(1)(b) — warehouse goods | 15 months from sale | 9 months from sale |
| First proviso — INR invoiced/settled | 18 months | 12 months |
| Project exports | As per contract | As per contract (unchanged) |
| AD bank extension power | On request with reasons | On request with reasons (unchanged) |
The September amendment changed only the numbers. Everything else in the 2026 framework — the EDF for services, EDPMS monitoring, set-off, third-party receipts, the small-value declaration route — still commenced on 1 October 2026 as planned.
The 12-month INR condition: invoiced AND/OR settled
The first proviso to Regulation 5(1) says: where the export of goods and services is invoiced or/and settled in Indian Rupees, the period is 12 months. The and/or matters — you do not necessarily need both conditions.
- Invoiced in INR but settled in foreign currency: can qualify for 12 months on the invoicing leg.
- Invoiced in foreign currency but settled in INR (for example through the INR settlement mechanism): can qualify on the settlement leg.
- Both invoiced and settled in INR: squarely within 12 months.
- Neither in INR: standard 9 months applies.
INR settlement still has its own rules
Qualifying for the 12-month period does not exempt you from the applicable rules on receiving and settling proceeds in rupees. Keep the underlying invoicing and settlement evidence — your AD bank will ask for it before recognising the longer period.
Your contract cannot override the FEMA deadline
A common follow-up myth: if the buyer contract allows 12-month credit on a non-INR export, the FEMA deadline stretches to match. It does not. The FEMA clock runs independently of commercial terms.
- If the contract pays after the FEMA deadline, approach your AD bank for an extension with documented reasons — before expiry, with written approval.
- Alternatively, restructure the terms: advance, shorter credit, or LC-backed payment within the period.
- For service exporters, remember the clock starts on the invoice date — milestone and monthly billing each create their own deadline.
- Track the remedy, not just the deadline: extension, reduction under Regulation 6, or set-off under Regulation 7 where applicable.
A commercial credit period agreed with the customer does not, by itself, replace the FEMA realisation requirement.
What to do now: reset your receivables to 9/12
- Re-age every open export receivable: goods by shipment date, services by invoice date, warehouse goods by sale date.
- Move INR-invoiced or INR-settled exports to the 12-month bucket; everything else to 9 months.
- Flag anything built on the old 15-month assumption that now falls due within 9 months — prioritise collection or extension requests.
- Reconcile each open EDPMS entry with your AD bank and confirm services EDFs were filed on time.
- Set a 6-month warning and a pre-expiry extension checkpoint on every receivable, with reasons and documents ready.
FEMA 2026 questions on a live transaction?
Talk to trad — realisation deadlines, extensions and write-offs for Indian exporters.
Contact us →Keep reading
What banks check under FEMA 2026
eBRC, EDF, realisation and EDPMS — how your bank monitors exports from 1 Oct 2026.
Read the eBRC and FEMA guide →Frequently asked questions
Is the FEMA 2026 export payment deadline 15 months or 18 months?
No. The January 2026 regulations did say 15 months (18 for INR exports), but the September 2026 amendment replaced those figures before the rules took effect on 1 October 2026. The operative rule is 9 months normally, 12 months where the export is invoiced and/or settled in INR.
What is the export realisation period under FEMA from 1 October 2026?
Nine months: from date of shipment for goods, from date of invoice for services including software, and from date of sale for goods sent to an overseas warehouse. Project exports follow the payment terms of the contract.
When do I get 12 months instead of 9 months?
Where the export is invoiced and/or settled in INR. You do not necessarily need both conditions — either invoicing in rupees or settling in rupees can qualify, running from the same start date (shipment, invoice, or warehouse sale). Applicable rules on receiving and settling proceeds still apply.
Can my export contract override the 9-month FEMA period?
No. If your customer contract pays after the FEMA deadline, the FEMA clock still applies. Approach your AD bank for an extension with reasons before expiry, or restructure the payment terms.
Did FEMA 2026 reduce the export realisation period?
Not really versus history. The earlier export framework also generally used 9 months. The confusion comes from the January 2026 version, which temporarily contained longer 15/18-month periods that never took effect. Those longer periods are no longer the operative rule.
What happens if export proceeds stay outstanding past the deadline?
Your AD bank may extend the period on a reasoned request it finds acceptable — get written approval. Without a valid extension or write-off, entries stay open in EDPMS, and if proceeds remain outstanding beyond one year from the due date or extended period, further exports may be permitted only against full advance or irrevocable LC.
Does the 12-month INR rule apply to services and software too?
Yes. The first proviso to Regulation 5(1) covers goods and services: where the export of goods and services is invoiced or/and settled in INR, the period is 12 months from the date of shipment (goods), invoice (services), or sale (warehouse goods).