The Reserve Bank of India (“RBI”), through a notification dated 13 November 2025, has amended the Foreign Exchange Management (Export of Goods and Services) Regulations, 2015 vide the Foreign Exchange Management (Export of Goods and Services) (Second Amendment) Regulations, 2025 (“Amended Regulations”).

The Amended Regulations seek to provide exporters with greater operational flexibility while maintaining oversight on foreign exchange realisation and repatriation. Rather than overhauling the export regime, the changes reflect a calibrated relaxation of timelines and procedural requirements, aimed at aligning India’s foreign exchange controls with contemporary trade practices.

Key Changes: At a Glance

The Amended Regulations extend the permissible timeline for realisation and repatriation of export proceeds from 9 months to 15 months from the date of export, shipment or rendering of services, as applicable. The period for shipment of goods or rendering of services against advance payments has also been extended from 1 year to 3 years from the date of receipt of the advance payment. In addition, exporters maintaining foreign currency accounts with banks in an International Financial Services Centre (“IFSC”) may retain export proceeds in such accounts for up to 3 months before repatriation to India is required.

Detailed Analysis of Key Changes

Extension of Time Period for Realisation and Repatriation of Export Proceeds

One of the most significant changes introduced by the RBI is the extension of the period for realisation and repatriation of export proceeds. The permissible timeline has been increased from nine months to fifteen months from the date of export, shipment or rendering of services, as applicable.

This extension applies uniformly across exporters, including units operating from Special Economic Zones, Export Oriented Units, and entities engaged in the export of software and services. The relaxation recognises the longer receivable cycles faced by exporters, particularly in cross-border services and project-based contracts, and reduces the need for routine extension approvals from authorised dealer (“AD”) banks, thereby minimising administrative burden.

Enhanced Flexibility for Advance Payments Against Exports

The RBI has also amended the framework governing exports against advance payments. Exporters are now permitted to complete shipment or rendering of services within three years from the date of receipt of the advance payment, subject to compliance with prescribed conditions including receipt of the advance payment through proper banking channels and maintenance of adequate documentation linking the advance to the underlying export order.

This change is particularly relevant for exporters involved in complex manufacturing arrangements, customised software development or long-term service contracts, where execution timelines may extend well beyond earlier regulatory limits. The Amended Regulations reduce transaction-level compliance friction while preserving safeguards against misuse of advance remittances.

Revised Treatment of Export Proceeds in Foreign Currency Accounts

Another important development concerns the treatment of export proceeds retained in foreign currency accounts. Exporters maintaining accounts with banks located in an IFSC are now permitted to retain export proceeds for up to three months before repatriation to India is required. However, for overseas accounts maintained outside IFSC jurisdictions, the existing shorter retention timelines continue to apply.

This measured relaxation supports India’s IFSC framework and provides exporters greater flexibility in managing foreign currency liquidity, particularly where receipts and payments are closely linked.

Continued Emphasis on Banking Channel Compliance

While the RBI has eased timelines, the Amended Regulations do not dilute the central role of AD banks. Export proceeds must continue to be routed through authorised banking channels, accompanied by appropriate declarations and purpose codes. AD banks remain responsible for monitoring realisation, ensuring consistency with export documentation and reporting non-compliance where timelines are breached.

Exporters must therefore ensure that internal processes and treasury functions remain aligned with the revised timelines to avoid inadvertent contraventions under the Foreign Exchange Management Act, 1999.

Practical Implications for Exporters

From a compliance perspective, the Amended Regulations offer tangible relief but also require recalibration of internal controls. Exporters should:

update internal receivables tracking systems to reflect the revised fifteen-month timeline;
review contracts involving advance payments to align shipment and service milestones with the extended three-year window;
assess the strategic use of IFSC banking arrangements for managing export proceeds; and
continue close coordination with AD banks to ensure accurate reporting and documentation.

Importantly, the extensions are permissive and do not operate as automatic waivers. Any delay beyond the revised timelines continues to attract regulatory scrutiny unless condoned in accordance with the Foreign Exchange Management Act, 1999.

Conclusion

The recent RBI amendments mark a notable shift in India’s export regulation framework. By extending timelines for realisation and shipment and offering greater flexibility in foreign currency account management, the RBI has responded to evolving trade realities without compromising the core objective of foreign exchange discipline.

For exporters, the amendments ease compliance pressure and improve cash flow management. However, effective implementation will depend on proactive compliance planning, updated internal controls and continued engagement with AD banks.

RBI’s Recent Amendments on Export of Goods, Software and Services: Key Compliance Takeaways