From 1 October, one rulebook replaces the 2015 export regulations, the separate export and import Master Directions and 167 circulars. The headline shift is that more first-level decisions move from RBI to Authorised Dealer (AD) banks. RBI remains the regulator.
What changes
1. Shorter realisation deadlines. A 22 September amendment cut the general period from fifteen months to nine, and the period for specified rupee exports from eighteen months to twelve. For goods sent to an overseas warehouse, the clock runs from the date of sale from the warehouse. AD banks can extend the period on request.
2. One declaration form. The Export Declaration Form (EDF) now covers goods, services and software, replacing the separate SOFTEX form. Service exporters must file monthly.
3. More power for AD banks. Banks may approve reduction or non-realisation of export value, permit set-off of export receivables against import payables, and allow third-party receipts. Set-off between goods and services is now allowed as well. Goods exported without consideration can be declared at nil value.
4. Merchanting trade. The nine-month completion limit is gone. Instead, the gap between outward and inward remittance must not exceed six months, and the AD bank can extend it.
5. Legacy cases. AD banks can now handle transactions undertaken before 1 October 2026 that earlier needed RBI approval. This is the route for clearing old open entries.
6. Caution-listed exporters. Those on the Caution List as on 30 September 2026 stay under the earlier orders until removed.
What it does not mean
This is not a relaxation of substance. Banks can refuse requests, and proceeds still have to come home. Documentation and contract quality now matter more, because the bank is the first decision-maker.
What to do now
- Calendar every open export against its nine- or twelve-month deadline.
- Reconcile your books with the bank’s export and import monitoring records.
- Ask your AD bank for its internal checklist on extensions, write-offs, set-offs and third-party payments.
- Update contracts with clear payment terms and third-party payer clauses.
- Set up a monthly EDF routine if you export services.
FCA, CWM (AAFM-US), CBV, CIFRS, R-ID, B.COM (H), RV* (IBBI)
Managing Partner at Ankit Gulgulia & Associates, Chartered Accountants. The Firm was setup in 2011 and has offices in Delhi NCR. AGA provides professional services to a large number of Clients both in India and Internationally.
AGA is supported by a well experienced team which include Chartered Accountants, Management Graduates, Company Secretaries, Cost Accountants, Valuers etc.