The new FEMA regulations for exports and imports take effect on 1 October 2026, and most of the decisions in them now sit with your AD bank rather than the Reserve Bank.

This episode looks at what that means for a corporate treasury: realisation periods and advances for exporters, payment terms and advances for importers, netting and central treasury arrangements, and the documentation that comes with all of it.

If you'd like a follow-up episode once banks publish their policies, let me know on LinkedIn or X.

Personal views. Not investment advice.

SOURCES

- Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026 — RBI Notification FEMA 23(R)/2026-RB, 13 January 2026; Directions on Export and Import of Goods and Services, 16 January 2026; effective 1 October 2026 — regulation text as reproduced by World Trade Scanner; summaries by PwC India, EY India, AZB & Partners
- Export realisation 15 months, 18 months where invoiced or settled in rupees (Regulation 5); earlier history: 9 months, 15 months from 13 November 2025, 9 months from 5 June 2026 — CorpLawUpdates
- Earlier rule on export advances (shipment within one year; refund thereafter needed RBI approval) — RBI Master Direction – Export of Goods and Services, via TaxGuru; three-year extension, 13 November 2025 — Council for Leather Exports
- Import payments per the underlying contract (Regulation 9), replacing the six-month rule; USD 200,000 guarantee threshold on import advances replaced by bank discretion (Regulation 10(3)); consequences if an import doesn't materialise (Regulation 12) — regulation text; EY India
- Set-off of export receivables against import payables with the same overseas buyer or supplier or their overseas group or associate companies (Regulation 7); third-party receipts and payments (Regulation 8) — regulation text
- Group set-off through a centralised settlement arrangement — RBI A.P. (DIR Series) Circular No. 08, 4 December 2020, via TaxGuru
- Credit or debit only after the bank is satisfied of genuineness, with EDPMS/IDPMS updated simultaneously (Regulation 4(2)); bank internal policy and SOP (Regulation 19) — regulation text
- RBI framework for invoicing and settlement of international trade in rupees, 11 July 2022 — PIB

Figures are as reported. Check against the underlying regulation text before relying on them.