Revised Framework For Export And Import Of Goods And Services

On January 13, 2026, Reserve Bank of India (RBI) notified the Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026, which shall come into force on October 01, 2026 (2026 Regulation). The 2026 Regulation shall supersede the Foreign Exchange Management (Export of Goods and Services) Regulations, 2015 (2015 Regulation).

The 2026 Regulation mark a significant shift in India's foreign trade compliance framework. The objective behind the changes is to codify existing operational practices, integrate export and import, trade provisions into a single framework, promote data-driven monitoring through digital systems, and reinforce accountability of authorised dealer banks (AD Banks) while facilitating ease of doing business.

The key provisions of 2026 Regulation are as follows:

A. Omission of exemptions relating to export declaration form ("EDF")

One of the key changes under the 2026 Regulation is the omission of the regulation providing explicit EDF exemption. Under the 2015 Regulation, exporters could ship goods without submitting an EDF if no foreign exchange was involved or if the exports were personal in nature. The 2026 Regulation replace this exemption with a consolidated EDF that allows exporters to declare a 'NIL' export value for goods exported without consideration. This represents a shift from an exemption-based approach to a comprehensive, reporting-driven compliance framework, emphasizing transparency and uniformity in export documentation.

B. Single declaration for export of goods, services and software –

Under the 2015 Regulation, exports of goods were reported through EDF, while software exports were separately reported through SOFTEX. The 2026 Regulation simplify and unify this process by requiring a single EDF for all types of exports, including goods, services, and software.

For goods, EDF is required to be submitted to the specified authority at the time of export, in line with existing customs procedures. For services, including software, EDF is to be furnished within 30 (thirty) days from the end of the month in which the invoice for the services is raised.

C. Extension of time period for realisation of export settled in Indian Rupees

The 2026 Regulation retain the requirement that full export value of goods should be realised within 15 (fifteen) months from the date of shipment and, in the case of services, within 15 (fifteen) months from the date of invoice. However, where exports of goods or services are invoiced and/or settled in Indian Rupees, the period for realisation and repatriation has been extended to 18 (eighteen) months from the date of shipment (for goods) or the date of invoice (for services).

D. Enhanced scrutiny through Export Data Processing and Monitoring System (EDPMS) and Import Data Processing and Monitoring System (IDPMS) by AD Banks

The 2026 Regulation delegate greater operational authority to AD Banks by enabling them to address matters such as extension of timelines for export realisation or import payments, set-off of export receivables against import payables, and third-party transactions at the transaction level, supported by digital monitoring systems like EDPMS and IDPMS. Additionally, AD Banks must report all foreign trade transactions through the Foreign Exchange Transaction Electronic Reporting System (FETERS) in accordance with RBI guidelines.

E. AD Banks to frame Internal Policies and Standard Operating Procedure ("SOP")

The 2026 Regulation place responsibilities on the AD Banks by mandating them to frame internal policies and SOPs, which must be published on their respective websites. These policies are required to address documentation requirements, applicable timelines and charges for various processes & approval, extension of timelines for export realisation and import payments, adjustment of export proceeds, advance receipts and payments, delegation of internal approval powers, and export and import factoring.

The policies and SOPs must also provide for a clear escalation mechanism for customer grievances, along with an internal appeal process. Appeals are to be handled at a higher internal level, which must take a final decision based on the genuineness of the customer's submissions.

Conclusion

The 2026 Regulation reflect the RBI's move towards a simplified yet more robust and integrated trade compliance framework. By consolidating reporting requirements and empowering AD Banks to frame structured internal policies, the 2026 Regulation aim to enhance operational clarity and accountability. They also place greater reliance on digital monitoring systems such as EDPMS and IDPMS, while reinforcing the responsibility of exporters and service providers to ensure timely realisation, accurate documentation, and compliant reporting of cross-border transactions.

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