The regulation that was amended before it ever took effect

Search for the export realisation period this week and you will be told it is nine months. Search again and you will be told fifteen. Both figures are in print, both are recent, and both are attributed to the same set of regulations.

The regulations themselves settle it, and the explanation is better than the answer.

Nine months, and why the other number exists

The Export and Import of Goods and Services Regulations, 2026 — Notification No. FEMA 23(R)/2026-RB, dated 13 January 2026 — came into force on 1 October 2026, superseding the 2015 Export Regulations.

As notified in January, regulation 5 gave fifteen months, and eighteen where an export was invoiced or settled in rupees.

It was amended on 22 September 2026, nine days before it commenced, to nine months and twelve.

Both the principal regulation and its amendment came into force on the same day. So the fifteen-month period, although it was properly notified and sat in the text for eight months, was never in force for a single day.

Anyone reading the January notification is reading a period that never applied. That is why the figure is still circulating, and why a file working to it is working to nothing.

What regulation 5 actually says

Four limbs, and they do not all start the clock in the same place:

• Goods — nine months from the date of shipment
• Services — nine months from the date of invoice
• Goods sent to a warehouse abroad — nine months from the date the goods are sold from the warehouse
• Project exports — according to the payment terms of the contract

And across all of them: twelve months where the export is invoiced or settled in Indian Rupees.

The warehouse limb is the one to check

For goods sent to a warehouse outside India, the period runs from the date of sale out of the warehouse, not from the date the goods left the country.

That is a materially different clock, and it cuts both ways. Stock sitting unsold in a foreign warehouse has not started its nine months at all — which is generous. But it also means the exporter must know, and be able to evidence, when each consignment was sold, because that is the date the regulation measures from. An exporter who files by shipment date is measuring the wrong event.

The rupee twelve months

An export invoiced or settled in rupees carries twelve months rather than nine. Three extra months of working capital, turning not on anything about the goods or the buyer but on how the invoice was raised.

For a client with a real choice about invoicing currency — and in rupee-settled trade with neighbouring markets that choice is often genuine — this is now a term worth deciding deliberately rather than by habit.

What the shorter period actually changes

Going from fifteen months to nine is a third of the window gone. Two consequences follow, and the second is the one that bites.

The obvious one: receivables that were comfortably inside the old period may fall outside the new one. Any export where collection was expected around the ten to fourteen month mark is now late by design.

The one to look for: the period is not a soft target. Proceeds not realised within it, and not extended, are a contravention — and the exporter is the one who answers for it, not the overseas buyer who paid slowly.

An authorised dealer may extend the period where the exporter gives reasons it finds satisfactory. That is a real route and it is discretionary, which means it is applied for, not assumed. A client who intends to rely on extension should be asking for it before the period expires rather than explaining afterwards.

What to do

• Pull the export ledger by date of shipment and apply nine months. Anything already past it, or due to pass it in the next quarter, is the list.
• Separate the rupee-invoiced exports — they have twelve, and mixing them understates your problem on one set and overstates it on the other.
• For warehouse stock, find the sale dates. If the client cannot produce them, that is the finding, because the regulation measures from a date they are not recording.
• Where collection is genuinely going to be late, go to the authorised dealer early. Extension is discretionary, and a request made before expiry reads very differently from one made after.
• Stop quoting fifteen months. It is in print in a great many places, including in a notification that was properly made, and it never applied.