A practical comparison of the FEMA export-import framework taking effect on 1 October 2026, including the latest RBI amendment notified on 22 September 2026.
| Particulars | Existing / Current Position | Revised Position from 1 October 2026 |
| Regulatory framework | FEMA framework for export and import transactions operates through separate regulations, Master Directions and RBI circulars. | FEMA 23(R)/2026-RB consolidates export and import of goods and services. The 22 September 2026 amendment further revises selected provisions before commencement. |
| Systems in focus | EDPMS tracks export declarations and realisation; IDPMS tracks import-related reporting and payment/import evidence. | The new framework continues system-based reporting through EDPMS and IDPMS, with stronger emphasis on timely reconciliation, declarations and AD-bank processes. |
| Effective date | Existing provisions apply until 30 September 2026, subject to applicable transition provisions. | The 2026 Regulations and Directions take effect on 1 October 2026. |
Key message for EXIM businesses
The latest 22 September 2026 amendment changes the export realisation period from the 15-month rule originally notified in January to 9 months, and the special INR-linked period from 18 months to 12 months. Exporters already on the Caution List as on 30 September 2026 remain governed by their existing RBI orders until removal.
Prepared for exporters, importers, finance teams, trade operations and compliance professionals.
EDPMS: What Changes for Exporters
Export Data Processing and Monitoring System — reporting, realisation and closure considerations under the 2026 framework.
| Particulars | Existing / Current Position | Revised Position from 1 October 2026 |
| Export declaration | Goods exports use the applicable export declaration process; software reporting has historically used SOFTEX in relevant cases. | A single Export Declaration Form (EDF) framework applies to goods, services and software. For EDI goods exports, the EDF is submitted with the shipping bill; service/software exports can be covered by a monthly EDF subject to the prescribed timeline. |
| Services & software | Service/software export reporting has followed separate processes. | Services and software are brought into the unified EDF structure. The monthly EDF for services/software is generally due within 30 days from the end of the month in which the invoice is raised, subject to the detailed rules. |
| Export realisation timeline | The applicable period before 1 October 2026 is governed by the prevailing rules for the transaction/date concerned. | The latest 22 September 2026 amendment changes Regulation 5 to 9 months. For exports invoiced/settled in INR under the specified proviso, the period becomes 12 months. |
| Low-value EDPMS closure | Since 1 October 2025, export entries up to ₹10 lakh have had a simplified declaration-based closure route. | The 2026 framework retains this approach: for shipping bills/invoices up to ₹10 lakh, EDPMS closure may be based on an exporter declaration. A quarterly declaration can be used for bulk closure, subject to the regulation and bank process. |
| Reduction / non-realisation | Value reduction and write-off processes depend on applicable RBI provisions, bank review and supporting records. | For export values up to ₹10 lakh, the regulations provide a declaration-based route for reduction of export value, including non-realisation of the full export value, subject to the prescribed conditions. |
Practical EDPMS checklist
1. Download the open EDPMS list from the Authorised Dealer (AD) bank and reconcile each shipping bill/invoice against books and bank receipts.
2. Identify transactions that will cross the applicable realisation deadline after 1 October 2026 and address extensions or other permitted routes with the AD bank.
3. Review small-value open entries up to ₹10 lakh for declaration-based closure where eligible.
4. Align service/software export workflows with the EDF process and ensure invoice, GST and banking data are consistent.
IDPMS: What Changes for Importers
Import Data Processing and Monitoring System — payment matching, evidence and small-value closure under the new framework.
| Particulars | Existing / Current Position | Revised Position from 1 October 2026 |
| Import reporting | Import transactions are reported and monitored through IDPMS with bill-of-entry and payment-related records. | The 2026 framework continues system-based IDPMS reporting and requires the AD bank to update/close the relevant entry when the genuineness of the transaction is established and payment/import evidence is available. |
| Small-value IDPMS entries | A simplified declaration route for transactions up to ₹10 lakh has applied from 1 October 2025, subject to conditions. | For eligible import transactions up to ₹10 lakh, the framework supports declaration-based closure by the importer. Quarterly consolidated declarations may be used, subject to the applicable bank process. |
| Import payment evidence | Banks reconcile outward remittances with the relevant import documentation and IDPMS records. | Importers should maintain a clean link between outward remittance, bill of entry/import evidence, invoice and supplier records so the AD bank can update or close IDPMS entries efficiently. |
| Advance payments | Advance import payments are subject to existing RBI requirements, documentation and bank monitoring. | The 2026 framework places greater operational responsibility with AD banks through internal policies/SOPs for handling advances, extensions, set-offs and related trade transactions. |
| AD-bank role | Certain approvals and exceptions have historically involved RBI processes and detailed circular-based requirements. | AD banks receive broader powers under the new framework, including handling specified pre-1 October 2026 transactions that previously required RBI approval, as provided by the 22 September amendment. |
Practical IDPMS checklist
1. Obtain the open IDPMS report from the AD bank and reconcile pending bills of entry against import records.
2. Match each outward remittance with the relevant bill of entry, invoice and supporting import evidence.
3. Review open entries up to ₹10 lakh for declaration-based closure where eligible.
4. For advance payments or delayed imports, discuss the applicable extension, refund, adjustment or closure route with the AD bank.
What Exporters & Importers Should Do Before 1 October 2026
A transition checklist based on the 2026 Regulations, Directions and the latest September 2026 amendment.
| Area | Action before / around 1 October 2026 | Why it matters |
| EDPMS | Reconcile all open shipping bills and service/software export entries; identify overdue or soon-to-be-due items. | The new realisation timeline is 9 months, with a 12-month INR-linked period under the specified provision. |
| IDPMS | Reconcile open bills of entry, outward remittances, refunds and import evidence. | Clean documentation helps the AD bank update and close IDPMS entries without avoidable exceptions. |
| EDF | Update export documentation workflows for goods, services and software; ensure responsible teams know the submission route. | The unified EDF framework expands reporting coverage and replaces the earlier separate software reporting structure. |
| ₹10 lakh entries | Identify eligible small-value open EDPMS/IDPMS items and prepare declarations where appropriate. | The framework permits simplified declaration-based closure for qualifying transactions. |
| Caution List | If an exporter is on the Caution List on 30 September 2026, review the applicable RBI order and continue complying with it until removal. | The September 2026 amendment expressly preserves existing Caution List orders for those exporters. |
| AD bank SOP | Obtain or review the AD bank’s updated policy/SOP for extensions, reductions, set-offs, third-party transactions and advances. | The new framework gives AD banks a stronger role in transaction-level handling and internal processes. |
Important regulatory update — 22 September 2026
The January 2026 FEMA 23(R)/2026-RB regulations originally provided a 15-month export realisation period (18 months for the specified INR case). The RBI’s 22 September 2026 Amendment Regulations change these figures to 9 months and 12 months respectively, effective 1 October 2026. The same amendment also preserves existing Caution List orders for exporters who remain on that list as of 30 September 2026 and gives ADs specified powers for certain pre-1 October 2026 transactions.
Curated Exim
For practical EXIM compliance support, transaction reviews and documentation guidance, visit www.curatedexim.com.
Sources
Reserve Bank of India — Foreign Exchange Management Act Notification / FEMA framework: www.rbi.org.in.
Reserve Bank of India — Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026, Notification No. FEMA 23(R)/2026-RB, 13 January 2026.
Reserve Bank of India — Foreign Exchange Management (Export and Import of Goods and Services) (Amendment) Regulations, 2026, Notification No. FEMA 23(R)/(1)/2026-RB, 22 September 2026.
This document is an informational summary and is not a substitute for the applicable FEMA regulations, RBI directions, bank-specific SOPs or professional legal/tax advice. Transaction-specific treatment should be confirmed with the relevant AD bank.
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