FEMA 2026 Overhaul: Unified Export-Import Rules Simplified

The Reserve Bank of India (RBI) notified the Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026 (Notification No. FEMA 23(R)/2026-RB dated January 13, 2026), superseding the 2015 export regulations and introducing a unified framework for goods and services exports and imports. Effective from October 1, 2026, these principle-based rules aim to ease compliance for small traders and empower Authorised Dealers (ADs) with greater flexibility in monitoring via EDPMS/IDPMS systems. Directions on operational aspects align with this regime, promoting quicker services while ensuring transaction genuineness.]​

Key Definitions and Declaration Requirements

Exporters of goods must submit an Export Declaration Form (EDF) to specified authorities like Customs Commissioners (DTA) or SEZ Development Commissioners at export time, deemed filed via shipping bills at EDI ports. Service exporters (including software) file EDF within 30 days from invoice month-end, allowing single monthly filings or on payment receipt for non-software services, with AD extensions for delays. Personal effects by travelers are exempt from exporter status.​

Realisation Periods and Flexibilities

Full export value must realise within 15 months from shipment/invoice (18 months for INR invoicing), extendable by ADs on valid grounds; project exports follow contract terms. ADs can permit export receivable set-off against import payables with the same overseas entity/group and third-party receipts/payments after verifying bonafides. For transactions up to ₹10 lakh, self-declarations enable bulk EDPMS/IDPMS closures quarterly.​

Import Payment Rules and Restrictions

ADs monitor IDPMS for timely payments per contracts, granting extensions reasonably; advance remittances allowed post-genuineness check, but prohibited for gold/silver imports. Failed imports require repatriation or standby LC/guarantees for future advances; unrealised exports beyond a year mandate full advance or irrevocable LC for new shipments.​

Special Transactions: Merchanting and Projects

Merchanting Trade Transactions (MTT) must complete within 6 months (extendable), with remittances strictly between overseas buyer/seller (third-party exceptions allowed), backed by documents. Project exporters can deploy temporary surpluses abroad in short-term instruments; INR international trade follows extant guidelines.]​

AD Responsibilities and Compliance

ADs verify transactions before crediting/debiting, update EDPMS/IDPMS within 5 days, and maintain internal SOPs covering approvals, extensions, charges (no penalties for client delays), and disclosures on websites. Reporting occurs via FETERS; these updates demand banks revise frameworks ahead of October 2026 rollout.

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