Reserve Bank of India (RBI) issues the Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026 (EXIM Guidelines)

RBI issues the EXIM Guidelines ^[1], introducing a consolidated framework governing exports and imports post public consultation on the draft Export and Import Regulations and Directions released in July 2024 and thereafter, in April 2025. 

The EXIM Guidelines consolidate and update India’s cross-border trade framework by bringing goods, services and software under a unified structure, introduce uniform reporting requirements and outline revised norms for payments, documentation and operational processes.

The key highlights have been summarized below:

Payment and realization timelines

• Imports: The earlier 6-month timeline for import payments has been removed, and the payment timeline needs to be aligned with the agreed contractual terms.
• Exports: Export realization timeline of 15 months from date of shipment (goods) and date of invoice (services) continues in line with the existing guidelines.
• Exports invoiced and/or settled in Indian Rupees (INR): Realization period for INR extended to 18 months.

Delay in export realization beyond one year: The export proceeds remaining unrealized beyond one year from the due date of realization or any extended period granted by AD Bank or RBI, the exporter may undertake future exports only against (i) full advance payment or (ii) an irrevocable Letter of Credit (LC).

 Advance and delayed payments for exports and imports: The existing USD 200,000 cap on import advances will be replaced by an AD bank determined threshold, beyond which a standby LC or bank guarantee may be required.

All‑in‑cost ceiling prescribed for trade credit now applies on any interest payable on export advances or delayed import payments as prescribed under ECB guidelines.

Import advances not adjusted: Where an importer is unable to complete the import within the original contract period or any extended period, the importer is required to repatriate the advance.

In case of failure to repatriate the advance payment, or if the Import Data Processing and Monitoring System (IDPMS) entry remains unmarked, any future advance import payments may be permitted only against an unconditional and irrevocable LC/bank guarantee.

Permissions for closing advance transactions: AD Banks may close respective IDPMS or Export Data Processing and Monitoring System (EDPMS) entries relating to advance transactions where no export or import has been materialized, provided they are satisfied that:

• refund is not possible, and
• the request is bona fide

Reduction in export invoice value: EXIM Guidelines authorize AD Banks to permit reduction in realization of invoice value on account of under-realization or non-realization of full export value subject to bona fides of the transaction and supporting documentation.

Where the invoice value is up to INR 10 lakh per shipping bill or invoice (as may be applicable), AD Banks may allow reduction based on a self‑declaration from the exporter.

Set-off of import and export transactions: Set-off flexibility has been expanded, export receivables against goods can now also be set off against import payables towards services, and vice versa.

Import of gold and silver

• Advance remittance is no longer permitted for the import of gold and silver.
• The restriction of 90‑day credit period on suppliers’/buyers’ credit and LC usance period for import of gold, has been relaxed.
• Other precious and semi‑precious metals be governed as per the general timelines for import applicable for other than Gold and Silver.

Merchanting Trade Transactions (MTT)

• MTT means where goods are bought from one foreign country and sold to another foreign country without the goods entering the Domestic Tariff Area (DTA).
• The entire MTT was required to be completed within 9 months, with an additional condition that no outlay of foreign exchange could remain outstanding beyond 6 months.
• The earlier overall 9-month timeline for completion of MTT has been removed under the EXIM Guidelines.
• Under the EXIM Guidelines, the maximum gap between the outward remittance and the corresponding inward remittance, or vice versa should not exceed 6 months, in line with the existing guidelines.
• While third‑party payments and receipts have not been permitted under existing guidelines on MTT, the EXIM Guidelines allow AD Banks, upon being satisfied with the reasons cited, to permit receipt from and/or payment to a third party under MTT.

Uniform Reporting–Export Declaration Form (EDF): A single consolidated EDF shall apply to exports of goods, services and software, replacing the existing form for reporting software exports i.e. SOFTEX form. The form should be submitted to the relevant specified authorities, i.e., Customs, AD Banks, Software Technology Park of India (STPI) and Special Economic Zone (SEZ) authority. Corresponding entries may be generated in the EDPMS by the specified authority.

         Timeline for submission of EDF:

• Goods: Submitted as part of the shipping bill, in line with extant guidelines, for goods exported through an Electronic Data Interchange (EDI) port.
• Services and software: One EDF can cover all service and software exports made in the month and to be submitted within 30 days from end of month in which invoice is raised.
•  Services (other than software): EDF may be submitted on or before the date of receipt of payment.

Internal Policy and Standard Operating Procedure (SOP): EXIM Guidelines direct the AD Banks to formulate an Internal Policy and SOP for handling trade transactions and should capture the following:

• List of documents, timelines and charges for each process and approval.
• Extensions for export realization and import payments;
• Reduction in export value (including under/over/non-realization adjustments);
• Set-off of export receivables against import payables;
• Third party receipts and payments; and
•  Permission for export/import advances, subject to internal risk thresholds
•  Export factoring and import factoring.

The EXIM Guidelines shall come into force on 1 October 2026.

^[1] Source: Notification No. FEMA 23(R)/2026 RB dated 13 January 2026; A.P. (DIR Series) Circular No. 20 dated 16 January 2026.