- October 9, 2026
- Gaurav Vashistha
- 0
Table of Content
- 1. Who Do the FEMA Export Import Rules 2026 Apply To?
- 2. Import Payments: The Biggest Relief Under the New Rules
- 3. Export Realisation Timelines Under FEMA Export Import Rules 2026
- 4. Third-Party Payments Now Expressly Permitted
- 5. More Ease-of-Business Measures
- 6. Action Checklist Before October 1, 2026
- 7. How Corporate Legit Can Help
From October 1, 2026, India’s cross-border trade rules change significantly. The Reserve Bank of India notified the Foreign Exchange Management (Export and Import of Goods and Services) Regulations 2026 (Notification No. FEMA 23(R)/2026-RB, as amended September 22, 2026). The FEMA Export Import Rules 2026 replace the 2015 export regulations and the separate Master Directions on exports and imports with one unified rulebook.
For foreign companies operating in India, this is a major step toward ease of doing business in India.
Who Do the FEMA Export Import Rules 2026 Apply To?
The new regulations apply to every Indian entity that imports or exports, including:
- Wholly owned subsidiaries of foreign companies
- Joint ventures with Indian partners
- Branch offices of foreign companies
- Project offices for project-related imports
- Global Capability Centres, IT back offices, and shared support service centres
Import Payments: The Biggest Relief Under the New Rules
Until now, importers had to pay for goods within 6 months from shipment. Under the FEMA Export Import Rules 2026, payment follows the underlying commercial contract or purchase order terms (Regulation 9).
| Import Category | Up to September 30, 2026 | From October 1, 2026 |
| Import of goods | Within 6 months from shipment | As per contract / PO terms |
| Import of services | Per invoice, no specific rule | As per contract, monitored by AD bank |
| Extension | AD bank, 6 months at a time, maximum 3 years | AD bank, on merit, per its own policy |
Why it matters: most foreign subsidiaries import from their parent or group companies. They can now use the credit period agreed in the intercompany agreement, improving working capital. Long deferrals may still fall under trade credit rules, so structure them carefully.
Export Realisation Timelines Under FEMA Export Import Rules 2026
Export proceeds must still be realised and repatriated to India through the Authorised Dealer bank.
Export of services (key for GCCs and IT companies):
| Invoice Currency | Up to September 30, 2026 | From October 1, 2026 |
| Foreign currency | 9 months | 9 months from invoice date |
| Indian Rupees (INR) | 9 months | 12 months |
Export of goods:
| Category | Up to September 30, 2026 | From October 1, 2026 |
| Normal exports, foreign currency | 9 months | 9 months from shipment |
| Normal exports, INR | 9 months | 12 months |
| Overseas warehouse | 15 months from shipment | 9 months from date of sale |
| SEZ / EOU / STPI / Status Holder | 9 months | 9 months |
AD banks can grant extensions on a reasoned request.
Third-Party Payments Now Expressly Permitted
Regulation 8 of the FEMA Export Import Rules 2026 permits third-party receipts and payments where the AD bank is satisfied the transaction is genuine. This supports group treasury and regional HQ payment structures.
| Transaction | Up to September 30, 2026 | From October 1, 2026 |
| Import of goods | Allowed with strict conditions | Allowed under Regulation 8 |
| Export of goods | Allowed with strict conditions | Allowed under Regulation 8 |
| Import of services | No express provision | Allowed under Regulation 8 |
| Export of services | Software exports only | Allowed under Regulation 8 |
More Ease-of-Business Measures
- Set-off (Regulation 7): export receivables can be netted against import payables with the same overseas party or its group companies, including goods against services.
- Rs. 10 lakh simplified closure: small import and export entries can be closed by self-declaration, including quarterly bulk filing.
- Single Export Declaration Form: replaces SOFTEX for software exports. One monthly EDF covers all service exports.
Action Checklist Before October 1, 2026
- Review payment terms in intercompany supply and service agreements
- Set up monthly EDF filing for service exports
- Reconcile open EDPMS and IDPMS entries
- Record third-party payers on invoices and contracts
- Obtain your AD bank’s new FEMA 2026 policy or SOP
How Corporate Legit Can Help
Corporate Legit Consulting LLP advises foreign companies, especially Japanese and Korean investors, on FEMA compliance, AD bank documentation, intercompany agreements and transition to the new regime.
Contact our FEMA experts today to make your India trade operations compliant from day one.
Frequently Asked Questions
The regulations apply to transactions on or after October 1, 2026. Transactions entered into before that date continue to follow the prior framework, specifically the 2015 export regulations and associated Master Directions.
Yes, but the deadline is now determined by the underlying commercial contract or purchase order rather than a fixed 6-month statutory window. The AD bank monitors compliance with the contractual payment timeline and can grant extensions on merit under its own policy.
Yes. Third-party receipts are expressly permitted under Regulation 8 of the FEMA Export Import Rules 2026 where the AD bank is satisfied that the transaction is genuine. This enables group treasury centralisation and regional headquarters payment structures that were previously handled under stricter conditions.
The repatriation period for INR-invoiced service exports extended from 9 months to 12 months from the invoice date. Foreign currency-invoiced service exports remain at 9 months. This is particularly relevant for GCCs and IT companies that invoice intercompany services in INR to their overseas group entities.
Yes. The monthly EDF replaces SOFTEX for software and IT service exports. One monthly EDF filing now covers all service exports for the month, replacing the transaction-by-transaction SOFTEX filing that applied previously. Companies should confirm the EDF process with their AD bank before October 1, 2026.