Export realisation period from 1 October 2026: nine months, not fifteen
You raised an invoice on 2 October to a client in Austin. Their accounts team pays on net-90 and is usually late. A few months ago you might have shrugged: everything you read said you had fifteen months to get that money into India. That is no longer the rule.
On 22 September 2026, nine days before India's new export regulations took effect, the Reserve Bank of India amended them. The realisation period for exports made on or after 1 October 2026 is now nine months, not fifteen. For exports invoiced or settled in rupees it is twelve months, not eighteen. This post explains what the rule says, how to count it, and what to do when a client is going to pay late.
What the rule says now
The change sits in the Foreign Exchange Management (Export and Import of Goods and Services) (Amendment) Regulations, 2026, notification FEMA 23(R)/(1)/2026-RB. It was issued on 22 September 2026, published in the Gazette on 24 September, and takes effect on 1 October 2026, the same day the principal FEMA 23(R)/2026-RB Regulations commenced.
It changes Regulation 5 of those Regulations in two places. The ordinary period to realise and repatriate the full export value drops from fifteen months to nine. For goods the clock starts on the date of shipment. For services it starts on the date of invoice. Where the export is invoiced or settled in Indian rupees, the period drops from eighteen months to twelve.
One thing did not change: your authorised dealer (AD) bank can still extend the period if you ask and give reasons for the delay.
How we got here: four changes in under a year
If you are confused, that is reasonable. The number has moved four times. In November 2025, RBI raised the realisation period under the old 2015 Export Regulations from nine months to fifteen. A first amendment in 2026 brought it back to nine months for exports under those old rules. Separately, the new Regulations notified in January 2026 said that from 1 October 2026 the period would be fifteen months, or eighteen for rupee exports.
The 22 September amendment changed those new Regulations before they started. So the fifteen- and eighteen-month windows never applied to exports made from 1 October 2026. If you have read the fifteen-month figure in older guides, including some on this blog, treat it as superseded for anything you export from October onward.
How to count your deadline
For a service exporter the arithmetic is simple. Take the invoice date and add nine months. An invoice dated 15 October 2026 needs to be realised by 15 July 2027. The same invoice raised in rupees would have until 15 October 2027.
Count from the invoice date, not from the date your client approves the work or the date their payment terms expire. A net-90 client who pays thirty days late has used four of your nine months. Two slow cycles in a row can put you close to the line.
For invoices dated before 1 October 2026, we have not seen a clear official statement on transitional treatment. Don't assume either window applies. Ask your AD bank which period it is tracking against your older invoices.
If a client is going to pay late
Ask for an extension before the nine months run out, not after. The regulations let your AD bank extend the period when you cite reasons for the delay. Put the request in writing, explain what happened, and attach whatever shows the debt is real and being chased: the invoice, the contract or statement of work, and your follow-up emails.
Under Regulation 19, every AD bank has to publish a standard operating procedure covering timelines, extensions and charges, along with an escalation and appeal route. As of late September 2026 those SOPs were still not public, so check your own bank's website for its policy before you rely on any particular process.
The same regulation says an AD bank cannot levy charges or penalties on you for a regulatory delay or violation on your part. We explain that rule in more detail in our guide to bank penal charges on late export filings.
What happens if the money never arrives
Some clients never pay. Under Regulation 13, if export proceeds stay unrealised for more than one year after the due date, including any extension your bank granted, you can make further exports only against full advance payment or an irrevocable letter of credit. With a nine-month realisation period and no extension, that point now arrives about 21 months after the invoice date.
That makes it worth dealing with bad debts early instead of letting them sit. We cover the options in our guide to unrealised export proceeds. For smaller amounts, the regulations also let you close or reduce an open entry on your own declaration up to ₹10 lakh, explained in our guide to the ₹10 lakh self-declaration route.
The EDF clock runs alongside
The realisation deadline is not the only date in the new regime. From 1 October 2026, service exporters file an Export Declaration Form (EDF) with their AD bank. It is due within 30 days from the end of the month in which you raised the invoice, and you can club a month's invoices into one form. Exporters of services other than software can instead file on or before the date they receive payment. Your bank can extend the EDF window if you ask with reasons.
The EDF is what your bank later matches incoming payments against, so an unfiled EDF makes every other step harder. Our explainer on why SOFTEX is gone and how the EDF works walks through the filing.
A simple routine for the nine-month window
Set payment terms that leave room. If a client insists on net-90, you have six months of slack. Net-120 plus a habit of paying late leaves much less.
Track each open invoice against its own deadline, not just against your cash flow. A spreadsheet with invoice date, amount, currency and a nine-month due date is enough for most freelancers and small agencies.
Escalate at month six. If an invoice is still unpaid six months after its date, chase the client formally and decide whether you will need an extension. That leaves time to ask your bank before the deadline.
Keep the paper trail. Contracts, invoices, delivery evidence and payment reminders are what support an extension request, and later a write-off if it comes to that.
Where a Global Collections Account fits
A Winvesta Global Collections Account does not change the deadline, and nothing can make a client pay on time. What it does is give your client local account details to pay into, the way they would pay a local supplier. Each receipt shows up in your dashboard, so you can tie it back to the invoice it settles and see what is still open and how close each invoice is to its nine-month line.
If you are still being paid through a mix of platforms and bank wires, it is worth consolidating before the first invoices under the new rules come due in mid-2027.
Disclaimer: The information provided in this blog is for general informational purposes only and does not constitute financial or legal advice. Winvesta makes no representations or warranties about the accuracy or suitability of the content and recommends consulting a professional before making any financial decisions.
Get paid globally. Keep more of it.
No FX markups. No GST. Funds in 1 day.
You raised an invoice on 2 October to a client in Austin. Their accounts team pays on net-90 and is usually late. A few months ago you might have shrugged: everything you read said you had fifteen months to get that money into India. That is no longer the rule.
On 22 September 2026, nine days before India's new export regulations took effect, the Reserve Bank of India amended them. The realisation period for exports made on or after 1 October 2026 is now nine months, not fifteen. For exports invoiced or settled in rupees it is twelve months, not eighteen. This post explains what the rule says, how to count it, and what to do when a client is going to pay late.
What the rule says now
The change sits in the Foreign Exchange Management (Export and Import of Goods and Services) (Amendment) Regulations, 2026, notification FEMA 23(R)/(1)/2026-RB. It was issued on 22 September 2026, published in the Gazette on 24 September, and takes effect on 1 October 2026, the same day the principal FEMA 23(R)/2026-RB Regulations commenced.
It changes Regulation 5 of those Regulations in two places. The ordinary period to realise and repatriate the full export value drops from fifteen months to nine. For goods the clock starts on the date of shipment. For services it starts on the date of invoice. Where the export is invoiced or settled in Indian rupees, the period drops from eighteen months to twelve.
One thing did not change: your authorised dealer (AD) bank can still extend the period if you ask and give reasons for the delay.
How we got here: four changes in under a year
If you are confused, that is reasonable. The number has moved four times. In November 2025, RBI raised the realisation period under the old 2015 Export Regulations from nine months to fifteen. A first amendment in 2026 brought it back to nine months for exports under those old rules. Separately, the new Regulations notified in January 2026 said that from 1 October 2026 the period would be fifteen months, or eighteen for rupee exports.
The 22 September amendment changed those new Regulations before they started. So the fifteen- and eighteen-month windows never applied to exports made from 1 October 2026. If you have read the fifteen-month figure in older guides, including some on this blog, treat it as superseded for anything you export from October onward.
How to count your deadline
For a service exporter the arithmetic is simple. Take the invoice date and add nine months. An invoice dated 15 October 2026 needs to be realised by 15 July 2027. The same invoice raised in rupees would have until 15 October 2027.
Count from the invoice date, not from the date your client approves the work or the date their payment terms expire. A net-90 client who pays thirty days late has used four of your nine months. Two slow cycles in a row can put you close to the line.
For invoices dated before 1 October 2026, we have not seen a clear official statement on transitional treatment. Don't assume either window applies. Ask your AD bank which period it is tracking against your older invoices.
If a client is going to pay late
Ask for an extension before the nine months run out, not after. The regulations let your AD bank extend the period when you cite reasons for the delay. Put the request in writing, explain what happened, and attach whatever shows the debt is real and being chased: the invoice, the contract or statement of work, and your follow-up emails.
Under Regulation 19, every AD bank has to publish a standard operating procedure covering timelines, extensions and charges, along with an escalation and appeal route. As of late September 2026 those SOPs were still not public, so check your own bank's website for its policy before you rely on any particular process.
The same regulation says an AD bank cannot levy charges or penalties on you for a regulatory delay or violation on your part. We explain that rule in more detail in our guide to bank penal charges on late export filings.
What happens if the money never arrives
Some clients never pay. Under Regulation 13, if export proceeds stay unrealised for more than one year after the due date, including any extension your bank granted, you can make further exports only against full advance payment or an irrevocable letter of credit. With a nine-month realisation period and no extension, that point now arrives about 21 months after the invoice date.
That makes it worth dealing with bad debts early instead of letting them sit. We cover the options in our guide to unrealised export proceeds. For smaller amounts, the regulations also let you close or reduce an open entry on your own declaration up to ₹10 lakh, explained in our guide to the ₹10 lakh self-declaration route.
The EDF clock runs alongside
The realisation deadline is not the only date in the new regime. From 1 October 2026, service exporters file an Export Declaration Form (EDF) with their AD bank. It is due within 30 days from the end of the month in which you raised the invoice, and you can club a month's invoices into one form. Exporters of services other than software can instead file on or before the date they receive payment. Your bank can extend the EDF window if you ask with reasons.
The EDF is what your bank later matches incoming payments against, so an unfiled EDF makes every other step harder. Our explainer on why SOFTEX is gone and how the EDF works walks through the filing.
A simple routine for the nine-month window
Set payment terms that leave room. If a client insists on net-90, you have six months of slack. Net-120 plus a habit of paying late leaves much less.
Track each open invoice against its own deadline, not just against your cash flow. A spreadsheet with invoice date, amount, currency and a nine-month due date is enough for most freelancers and small agencies.
Escalate at month six. If an invoice is still unpaid six months after its date, chase the client formally and decide whether you will need an extension. That leaves time to ask your bank before the deadline.
Keep the paper trail. Contracts, invoices, delivery evidence and payment reminders are what support an extension request, and later a write-off if it comes to that.
Where a Global Collections Account fits
A Winvesta Global Collections Account does not change the deadline, and nothing can make a client pay on time. What it does is give your client local account details to pay into, the way they would pay a local supplier. Each receipt shows up in your dashboard, so you can tie it back to the invoice it settles and see what is still open and how close each invoice is to its nine-month line.
If you are still being paid through a mix of platforms and bank wires, it is worth consolidating before the first invoices under the new rules come due in mid-2027.
Disclaimer: The information provided in this blog is for general informational purposes only and does not constitute financial or legal advice. Winvesta makes no representations or warranties about the accuracy or suitability of the content and recommends consulting a professional before making any financial decisions.
Get paid globally. Keep more of it.
No FX markups. No GST. Funds in 1 day.