Which FEMA rules applied to my shipment. The old or the new?

Why can't one date answer this?

Because the rules were not written to share a trigger. Each one attaches to the event it regulates, and those events happen on different days.

Take an ordinary export. You receive an advance in August 2024. You file the declaration and ship in February 2026. The money arrives, or does not, through 2027. Three rules are in play and all three are keyed differently: the window to ship against that advance started running in August 2024, the realisation period started running in February 2026, and the form you filed was fixed by what was in force on the day you filed it. There is no date you can write at the top of the file that settles all three.

The corollary is more comfortable. Where you were compliant under the rule in force at the time, a later change does not make you retrospectively non-compliant either. The regime that bound the export is the regime it is judged by, in both directions.

Which date does each rule key off?

Read this table before any of the ones below it. It is the part that stops the rest being misapplied.

How long did I have to bring the money home?

This rule has moved three times in under a year, which is why a table is more honest than a sentence. Every row keys off the date of shipment.

Two consequences follow from the shape of that table rather than from any one row.

• Read down the "shipped" column, not across from today's date. On the date-of-shipment principle the table applies itself: a shipment made in January 2026 was made under the fifteen-month text, and one made in July 2026 under the nine-month text, so the later shipment can carry the earlier deadline. Note that this is the principle applied rather than an express transitional provision. See section 8.
• Two bills a fortnight apart can have deadlines nine months apart. Shipments either side of 5 June 2026, or either side of 1 October 2026, are on different clocks. Sorting an EDPMS worklist by due date without first sorting by shipment date produces an order that looks wrong and is right.

For which document and which date actually starts the clock (a question this table assumes rather than answers) see when the realisation clock actually starts .

How long did I have to ship against an advance?

This is the rule most often applied against the wrong date, because the money and the shipment are separated by months and the instinct is to measure from the shipment. The period runs from the date the advance was received.

Two conditions ride along with the period in either version: interest on the advance, if any, must not exceed the reference rate plus 100 basis points, and the documents covering the shipment must be routed through the Authorised Dealer Category-I bank through whom the advance was received.

The refund limb keys off the same date. Where the exporter cannot ship within the period, the proviso to para C.2(1) provides that no remittance refunding the unutilised advance, and no remittance of interest on it, may be made after the period expires without the prior approval of the Reserve Bank. A refund is a bank-level transaction while you are inside the period and an RBI approval case the day after it. The full procedure is at advance received, shipment still pending .

Which declaration form did my export need?

This rule keys off the date of filing, and for one long period it also keyed off whether the port was EDI or non-EDI. A split that is routinely stated wrongly.

What the fold into a single EDF does to a software export declaration specifically (including who certifies it and what that changes operationally) is set out in SOFTEX to EDF .

Who could certify my software export?

For a software exporter this is the change with the most operational consequence, and it is the one least likely to be noticed, because it does not alter a deadline or a rate. It alters who you send the declaration to.

The 2026 Regulations set the specified authority by category: the Commissioner of Customs in the Domestic Tariff Area for goods; an Authorised Dealer for services other than software; and an Authorised Dealer or STPI for software. So STPI stops being the only route for a software export. It does not stop being a route.

How do I work out which version bound a bill I am closing today?

Four steps, in this order. The order matters, because step 1 is what makes the rest answerable.

1. Write down three dates, not one. The date the advance was received, if there was one; the date of shipment for goods or the date of invoice for services; and the date the declaration was filed. Do this before arguing a period with anyone: a disagreement about the number of months is often a disagreement about which event is being measured from.
2. Take each rule to its own table above and read off the version. Do not carry a version across rules. The realisation period your shipment fell under says nothing about which declaration form it needed.
3. Compute the deadline and compare it to today. A bill shipped before 14 November 2025 and still open is already well past nine months, and the live question is which remedy applies (extension, write-off, or a realisation that was never reported) not which period was correct.
4. Put the instrument and the date in writing to your bank. Cite the paragraph, give the date your export keys off, and ask the bank to confirm which period it is applying. Putting the instrument and the date on the record is what converts a telephone disagreement into one that can be escalated.

Where the deadline has already gone, the routes out are separate pages rather than a line here: writing off an unrealised export bill and replying to a bank's realisation-pending letter .

Which parts does this guide not state, and why?

A page whose entire purpose is to be correct about dates should be explicit about where its own coverage stops. Five limbs are deliberately absent.

• Any transitional rule for bills in flight across 1 October 2026. The instruments state the period and the commencement date. They do not, on their face, carry a rule for a bill shipped under one regime and outstanding under the next. The date of shipment is the only test this page applies, and anything borderline is a question for your Authorised Dealer bank before you compute a deadline rather than after.
• What the 2026 Regulations do to the three-year export-advance window. Section 4 states the window as the corpus's own cited account has it, under FED Master Direction No. 16/2015-16 para C.2(1). That Master Direction is among the instruments superseded on 1 October 2026, and the successor provision for export advances has not been read for this page. Treat section 4 as stating the position up to 30 September 2026.
• The specified authority for units in a Special Economic Zone. Section 6 is scoped to the Domestic Tariff Area, as its own tip box says.
• Penalty exposure for missing any of these periods. Nothing on this page states a penalty amount or a compounding figure. What happens when a period is missed is a separate question with its own procedure.
• The extension route in the 2026 Regulations. Authorised Dealers are reported to retain a discretionary power to extend on a reasoned request, and project exports are reported to run on contractual payment terms instead. Neither limb is stated as a rule here, because neither has been read in the regulation text.

Questions exporters ask when closing an old bill

I am closing a bill that shipped in March 2023. Which realisation period applies to it?

Nine months from the date of export. A bill shipped in March 2023 was made under Regulation 9(1) and 9(2)(a) of Notification No. FEMA 23(R)/2015-RB, as stated at para A.2(i) of RBI Master Direction No. 16/2015-16, and the period that bound it when it shipped is the period it keeps. Neither the fifteen-month substitution of 13 November 2025 nor the 2026 Regulations reach backwards to it. The practical consequence is that the bill has been overdue since roughly December 2023, and the question worth asking is not which period applies but whether the entry needs an extension, a write-off or a realisation you have not reported.

Is there one date that tells me which rules governed my export?

No, and that is the single most useful thing on this page. Different rules key off different dates. The realisation period keys off the date of shipment for goods and the date of invoice for services. The window to ship against an export advance keys off the date you received the advance, which may be a year or more before the shipment. The declaration form keys off the date the declaration was filed. So a single export can sit on one side of one cut-over and the other side of another, and an exporter who picks one date and applies it to everything will get at least one of them wrong.

Do the 2026 Regulations move my outstanding bills onto fifteen months?

No. Notification No. FEMA 23(R)/2026-RB dated 13 January 2026 comes into force on 1 October 2026 and keys off the date of shipment, so a bill shipped on or before 30 September 2026 is not caught by it. This is the trap worth naming, because the new period is longer than the old one and the instinct is that a longer period must be good news for everything outstanding. It is not. A bill shipped on 15 September 2026 still runs nine months and still runs out in June 2027, and an exporter who marks it forward by six months has manufactured an overdue EDPMS entry they will hear about from their bank.

The realisation period changed twice in a year. Which shipments does each version bind?

Four versions, each keyed to the date of shipment. Shipped up to 13 November 2025: nine months, under FEMA 23(R)/2015-RB Regulation 9(1) and 9(2)(a). Shipped 14 November 2025 to 4 June 2026: fifteen months, under the substitution made by Notification No. FEMA 23(R)/(7)/2025-RB dated 13 November 2025. Shipped 5 June 2026 to 30 September 2026: back to nine months, under Notification No. FEMA 23(R)/(8)/2026-RB dated 5 June 2026. Shipped on or after 1 October 2026: fifteen months under Regulation 5(1)(a) of the 2026 Regulations, and eighteen where the export is invoiced or settled in Indian Rupees.

I received an advance in 2024 and have not shipped. Which window am I on?

Three years from the date you received the advance, not one. The period in FED Master Direction No. 16/2015-16 para C.2(1) was substituted from one year to three years vide Notification No. FEMA 23(R)(7)/2025-RB dated 13 November 2025. Because this rule keys off the date of receipt of the advance rather than the date of shipment, an advance received in 2024 and still unshipped is inside the current three-year text rather than outside a lapsed one-year text. Two conditions ride along with the period: interest on the advance, if any, must not exceed the reference rate plus 100 basis points, and the shipping documents must be routed through the Authorised Dealer Category-I bank through whom the advance was received.

My bank is applying a period I do not recognise. What do I do?

Ask the bank which instrument and which paragraph it is applying, and give it the date your shipment or advance falls on. Banks run their own monitoring triggers alongside the statutory period (a 360-day follow-up on an export advance is a common one, and no RBI provision uses 360 days for that purpose) so being past the bank's trigger is not the same as being in breach of FEMA. Where the two genuinely differ, the instrument and the date settle it. Where the bank is right and this page's table does not fit your case, the likeliest reason is that your export keys off a date other than the one you assumed.

What should I read next?

• What changes for Indian exporters on 1 October 2026. The cut-over in full
• When does the realisation clock actually start. Which date on which document
• Advance received, shipment still pending. The three-year window and the refund route
• Writing off an unrealised export bill. The limits and who approves them
• SOFTEX to EDF. What the 2026 Regulations do to a software export declaration

Know which clock every open bill is running on

Seasaw keeps the date of shipment beside every outstanding export entry and the payout that closes it. So when a period changes, you can see which bills are affected and which ones simply are not.

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Update history

• 2026-09-23 First published.