RBI FEMA Export-Import Amendment 2026: Key Changes

RBI FEMA Export-Import Amendment 2026: Key Changes. The Reserve Bank of India has introduced significant amendments to the Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026. Issued through a notification dated September 22, 2026, the amendment will come into force from October 1, 2026. It is particularly relevant for exporters, importers, Authorised Dealers and businesses involved in merchanting trade, as it changes important timelines and introduces new transitional provisions for certain cross-border transactions.
The amendment reduces specified timelines under Regulation 5, continues the earlier treatment of exporters appearing on the Caution List as of September 30, 2026, and empowers Authorised Dealers to handle certain transactions undertaken before October 1, 2026 that previously required RBI approval. Businesses involved in international trade should therefore review pending transactions, update their FEMA compliance calendars and coordinate with their Authorised Dealer banks to ensure that applicable transactions are handled correctly under the revised regulatory.
Background of the FEMA Amendment Regulations, 2026
The amendment has been issued by the Reserve Bank of India through its Foreign Exchange Department. The RBI has exercised its powers under Section 7, Section 8, Section 10(6) and Section 47(2) of the Foreign Exchange Management Act, 1999 to introduce these changes. The notification amends the Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026, which were originally notified through Notification No. FEMA 23(R)/2026-RB dated January 13, 2026.
The amendment should therefore be understood as a modification of the existing 2026 regulations rather than a completely new regulatory. Businesses already following the principal regulations must now identify the specific provisions that have been altered by the September 2026 notification.
Effective Date of the Amendment
The amendment regulations will come into force from October 1, 2026. The effective date is important because one of the newly inserted provisions specifically deals with transactions undertaken before October 1, 2026. As a result, businesses should distinguish between transactions undertaken before the effective date and those undertaken after the new becomes operational.
Any pending export, import or merchanting trade transaction should therefore be reviewed carefully to determine whether it falls within the transitional arrangement provided under the amendment.
Key Changes Introduced by the RBI
The RBI amendment introduces three significant changes. The first change relates to Regulation 5, where specified periods have been reduced from 15 months to 9 months and from 18 months to 12 months. The second change relates to Regulation 13, where a new proviso has been inserted concerning exporters appearing on the Caution List as of September 30, 2026.
The third change is the insertion of a new Regulation 20, titled “Powers to Authorised Dealers,” which deals with transactions undertaken before October 1, 2026 that previously required RBI approval. These three changes together create a revised compliance and transitional for cross-border trade transactions.
Amendment to Regulation 5
One of the most significant parts of the notification is the amendment to Regulation 5 of the principal regulations. In Regulation 5(1), the RBI has substituted the words “fifteen months” with “nine months” in clauses (a) and (b). It has also replaced “eighteen months” with “twelve months” in the first proviso.
The change can be summarised as follows:

Earlier Period

Revised Period

15 months

9 months

18 months

12 months

Both periods have therefore been shortened by six months.
Significance of the Revised Timelines
The reduction in timelines is an important compliance development because affected businesses will now have less time to complete the requirements associated with the relevant provisions of Regulation 5. A compliance process that was previously monitored over a 15-month period may now need to be completed within nine months, while an obligation linked to an 18-month period will now need to be completed within 12 months where the amended provision applies.
Businesses should therefore immediately review internal calendars, pending transactions and compliance tracking systems. However, an important point must be noted. The amendment notification itself does not reproduce the complete text of Regulation 5(1)(a), Regulation 5(1)(b) or the first proviso. Therefore, while the notification clearly changes the periods from 15 months to 9 months and from 18 months to 12 months, the exact obligations to which these timelines apply must be read together with the principal regulations. Businesses should avoid applying the new timelines in isolation without checking the underlying provisions of Regulation 5.
Need for Stronger Internal Compliance Monitoring
The reduction in timelines makes effective compliance monitoring more important. Businesses involved in cross-border transactions often deal with multiple departments, including finance, legal, treasury, accounts, logistics and banking teams. Where a regulatory period has been shortened, delays in coordination between these teams may increase the risk of non-compliance.
Companies should therefore maintain an internal compliance register containing relevant transaction dates, applicable regulatory timelines, pending documentation and communication with Authorised Dealers. Periodic internal reviews may also help businesses identify transactions approaching the revised deadline. A structured monitoring system becomes particularly important where a company handles a high volume of export or import transactions.
Amendment to Regulation 13
The RBI has also introduced an important transitional provision at the end of Regulation 13. Under the newly inserted proviso, exporters who are on the Caution List as of September 30, 2026 pursuant to RBI orders issued under Regulation 16 of the Foreign Exchange Management (Export of Goods & Services) Regulations, 2015 will continue to be governed by those orders until they are removed from the Caution List. This provision ensures continuity in the treatment of exporters who were already subject to caution-list restrictions immediately before the new regulations take effect.
Impact on Exporters Appearing on the Caution List
The transitional provision is particularly important for exporters who were already included on the Caution List before the amended regulations became operational. An exporter appearing on the Caution List as of September 30, 2026 should not assume that the commencement of the amendment on October 1, 2026 automatically removes the earlier restriction.
The notification expressly provides that the earlier RBI order will continue to govern such exporters until they are removed from the Caution List. Accordingly, the status of the exporter remains relevant even after the amended regulations take effect. Businesses in this position should continue maintaining proper transaction records and comply with the applicable RBI order until their status is formally changed.
Why September 30, 2026 Is Important
September 30, 2026 is a critical cut-off date under the amendment. The notification specifically refers to exporters who are on the Caution List as on September 30, 2026. This means that the transitional treatment is tied to the exporter's status on that particular date.
Businesses should therefore check their regulatory position as of September 30, 2026 and ensure that internal records accurately reflect any caution-list status or RBI order applicable to them.
Insertion of New Regulation 20
Another major change is the insertion of a new Regulation 20, titled “Powers to Authorised Dealers.” This provision states that Authorised Dealers will handle transactions relating to the export and import of goods and services, as well as merchanting trade, that were undertaken before October 1, 2026 and previously required RBI approval under the earlier regulatory. This is an important transitional provision because it changes the route through which certain older transactions may now be handled.
Transactions Covered Under Regulation 20
The new Regulation 20 covers three broad categories of transactions.
Export of Goods and Services
Export transactions relating to goods and services undertaken before October 1, 2026 may fall within the scope of Regulation 20 where such transactions previously required RBI approval under the earlier regulations or Master Directions.
Businesses with pending export matters should therefore identify whether the transaction was undertaken before the effective date and whether it previously required RBI approval. Where the conditions are satisfied, the Authorised Dealer will handle the transaction under the newly inserted provision.
Import of Goods and Services
Import transactions are also expressly covered under Regulation 20. Businesses with pending import-related matters undertaken before October 1, 2026 should review whether those matters were previously subject to direct RBI approval.
If so, the new provision may permit the Authorised Dealer to handle the transaction. Importers should therefore maintain proper records regarding the date, nature and regulatory treatment of the transaction.
Merchanting Trade Transactions
Merchanting trade has also been specifically included in the new Regulation 20. Businesses engaged in merchanting trade should identify pending transactions undertaken before October 1, 2026 that were previously subject to RBI approval. The amendment provides a route for Authorised Dealers to handle such transactions under the transitional.
Meaning of the Transition to Authorised Dealers
The insertion of Regulation 20 is significant because it gives Authorised Dealers a specific role in dealing with certain legacy transactions. Under the earlier, some transactions relating to exports, imports or merchanting trade required approval from the Reserve Bank of India. For qualifying transactions undertaken before October 1, 2026, the new provision allows Authorised Dealers to handle matters that previously required RBI approval.
This may simplify the processing for businesses dealing with old or pending transactions. However, businesses should not assume that every historical transaction automatically falls under Regulation 20. The provision applies specifically to the transactions described in the amendment.
Earlier Regulatory Structure Referred to in Regulation 20
The new Regulation 20 refers to transactions that previously required RBI approval under certain earlier regulatory instruments. These include the Foreign Exchange Management (Export of Goods and Services) Regulations, 2015. The provision also refers to the Master Direction – Export of Goods and Services, dated January 1, 2016 and updated until July 17, 2026.
It further refers to the Master Direction – Import of Goods and Services, dated January 1, 2016 and updated until January 12, 2026. Businesses reviewing historical transactions should therefore identify the earlier regulatory provision under which RBI approval was originally required.
Role of Authorised Dealers After October 1, 2026
Authorised Dealers will have an important operational role under the transitional. Where a qualifying transaction was undertaken before October 1, 2026 and previously required RBI approval, the Authorised Dealer may handle the matter under Regulation 20. Businesses should therefore coordinate with the relevant Authorised Dealer and provide complete transaction information and documentation.
The amendment itself does not prescribe a detailed document checklist for every transaction. Accordingly, documentation requirements may depend on the nature of the particular export, import or merchanting trade matter.
Impact on Export-Oriented Businesses
Exporters should review the amendment from three different perspectives. First, businesses affected by Regulation 5 should assess how the revised timelines impact their existing compliance processes. Second, exporters appearing on the Caution List as of September 30, 2026 should continue complying with the applicable earlier RBI order until formally removed.
Third, businesses with older export transactions that previously required RBI approval should examine whether Regulation 20 allows the Authorised Dealer to handle the pending matter. This makes a complete review of pending export transactions particularly important before October 1, 2026.
Impact on Import-Oriented Businesses
Importers should identify all transactions undertaken before the effective date that remain pending from a foreign exchange compliance perspective. Where the transaction previously required RBI approval, businesses should determine whether it can now be handled by the Authorised Dealer under Regulation 20.
Importers should also ensure that transaction documents are complete and easily available. This may include commercial and banking documents relevant to the transaction, although the amendment itself does not provide a detailed list of documents required for every case.
Impact on Merchanting Trade Businesses
Businesses engaged in merchanting trade should pay close attention to the amendment because Regulation 20 expressly includes merchanting trade transactions. Any merchanting trade transaction undertaken before October 1, 2026 that previously required RBI approval should be reviewed.
Businesses should determine the date of the transaction, the earlier approval requirement and whether the transaction falls within the scope of Regulation 20. Maintaining an accurate transaction history will make this review easier.
Importance of Proper Transaction Classification
One of the practical consequences of the amendment is that transaction dates have become particularly important. Businesses should classify transactions according to whether they were undertaken before or after October 1, 2026. Transactions undertaken before October 1, 2026 may qualify for the transitional arrangement under Regulation 20 where the other conditions are satisfied.
Transactions undertaken from October 1, 2026 onward will need to be assessed under the regulatory applicable from that date. Proper classification will help businesses avoid applying the wrong compliance process.
Internal Compliance Review Businesses Should Conduct
Businesses affected by the amendment should conduct a structured internal review. The first step should be to identify all pending export, import and merchanting trade transactions. The second step should be to determine the date on which each transaction was undertaken.
The third step should involve checking whether any matter previously required RBI approval. Businesses should also identify exporters within the organisation, if any, who were subject to a Caution List order as of September 30, 2026. Finally, internal compliance calendars should be updated to reflect the revised nine-month and twelve-month timelines under Regulation 5.
Documentation and Record-Keeping
Proper record-keeping remains essential under any foreign exchange compliance. Businesses should maintain transaction records, banking correspondence and documents relevant to export, import and merchanting trade matters. Where Regulation 20 is being relied upon, records demonstrating that the transaction was undertaken before October 1, 2026 may become particularly important.
Companies should also maintain copies of earlier RBI communication or approvals connected with pending transactions where applicable. Well-organised documentation can make communication with Authorised Dealers more efficient.
Importance of Coordination with Authorised Dealers
The amendment increases the importance of communication between businesses and Authorised Dealer banks. Businesses with legacy transactions should not wait until a matter becomes overdue or complicated before contacting the Authorised Dealer.
Early coordination can help determine whether the transaction falls within Regulation 20 and what information or documentation may be required. Similarly, businesses affected by revised regulatory timelines should ensure that their banking and internal compliance teams are working with the same set of dates.
Key Dates Under the Amendment
Several dates are particularly important under the RBI notification. September 22, 2026 is the date on which the amendment notification was issued. September 30, 2026 is the relevant date for determining the transitional treatment of exporters appearing on the Caution List. October 1, 2026 is the date from which the amendment regulations come into force. October 1, 2026 is also the cut-off used under Regulation 20 for identifying qualifying legacy export, import and merchanting trade transactions.
Key Compliance Takeaways
The RBI amendment introduces a number of practical compliance considerations for businesses. The most immediate change is the reduction in specified periods under Regulation 5 from 15 months to 9 months and from 18 months to 12 months.
Businesses should therefore review whether any pending matter falls under the affected provisions. Exporters appearing on the Caution List as of September 30, 2026 should remember that their earlier RBI order continues to apply until removal from the list. Businesses with transactions undertaken before October 1, 2026 should also examine whether those matters can now be handled by their Authorised Dealer under Regulation 20.
Conclusion
The Foreign Exchange Management (Export and Import of Goods and Services) (Amendment) Regulations, 2026 introduce important regulatory changes for exporters, importers, Authorised Dealers and businesses engaged in merchanting trade. The amendment will become effective from October 1, 2026 and brings three major changes. It reduces specified timelines under Regulation 5 from 15 months to 9 months and from 18 months to 12 months. It continues the existing treatment of exporters who remain on the Caution List as of September 30, 2026. It also introduces Regulation 20, enabling Authorised Dealers to handle qualifying legacy transactions that previously required RBI approval.
Businesses should carefully review pending transactions, update internal FEMA compliance systems and coordinate with their Authorised Dealer banks wherever necessary. Particular attention should be given to the October 1, 2026 effective date and the revised regulatory timelines. A structured compliance review can help businesses identify affected transactions early, avoid missed deadlines and ensure a smoother transition to the amended regulatory.
Frequently Asked Questions
Q1. What is the RBI FEMA Amendment Regulations, 2026?
Ans. The amendment modifies certain provisions of the Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026. It changes specified timelines, addresses exporters on the Caution List and introduces new powers for Authorised Dealers concerning qualifying legacy transactions.
Q2. When will the amendment become effective?
Ans. The Foreign Exchange Management (Export and Import of Goods and Services) (Amendment) Regulations, 2026 will come into force from October 1, 2026. Businesses should review relevant pending transactions and internal compliance processes before the revised provisions become operational.
Q3. What change has been made to the 15-month period?
Ans. In Regulation 5(1), the RBI has replaced the words “fifteen months” with “nine months” in the relevant clauses. As a result, the prescribed period under those provisions has been reduced by six months.
Q4. What change has been made to the 18-month period?
Ans. The amendment replaces the earlier 18-month period contained in the first proviso to Regulation 5(1) with a 12-month period. Businesses affected by this provision should accordingly revise their compliance calendars and monitoring systems.
Q5. What happens to exporters on the Caution List?
Ans. Exporters who are on the Caution List as of September 30, 2026 will continue to be governed by the relevant earlier RBI order. The order will remain applicable until the exporter is formally removed from the Caution List.
Q6. What is Regulation 20?
Ans. Regulation 20 is a newly inserted provision titled “Powers to Authorised Dealers.” It allows Authorised Dealers to handle certain export, import and merchanting trade transactions undertaken before October 1, 2026 that previously required RBI approval.
Q7. Are import transactions covered by Regulation 20?
Ans. Yes. Qualifying import transactions undertaken before October 1, 2026 are included within the new Regulation 20 where they previously required approval under the regulatory instruments referred to in the amendment.
Q8. Are merchanting trade transactions covered?
Ans. Yes. Merchanting trade transactions are expressly covered under Regulation 20. Businesses should review pending merchanting trade transactions undertaken before October 1, 2026 to determine whether the new Authorised Dealer applies.
Q9. Does the amendment automatically remove an exporter from the Caution List?
Ans. No. The notification specifically states that exporters appearing on the Caution List as of September 30, 2026 will continue to be governed by the relevant RBI order until they are removed from the Caution List.
Q10. What should businesses do before October 1, 2026?
Ans. Businesses should review pending export, import and merchanting trade transactions, update internal compliance timelines, identify legacy matters that previously required RBI approval and coordinate with their Authorised Dealers regarding transactions that may fall within the transitional.

The Reserve Bank of India has introduced significant amendments to the Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026. Issued through a notification dated September 22, 2026, the amendment will come into force from October 1, 2026. It is particularly relevant for exporters, importers, Authorised Dealers and businesses involved in merchanting trade, as it changes important timelines and introduces new transitional provisions for certain cross-border transactions.

The amendment reduces specified timelines under Regulation 5, continues the earlier treatment of exporters appearing on the Caution List as of September 30, 2026, and empowers Authorised Dealers to handle certain transactions undertaken before October 1, 2026 that previously required RBI approval. Businesses involved in international trade should therefore review pending transactions, update their FEMA compliance calendars and coordinate with their Authorised Dealer banks to ensure that applicable transactions are handled correctly under the revised regulatory.

Background of the FEMA Amendment Regulations, 2026

The amendment has been issued by the Reserve Bank of India through its Foreign Exchange Department. The RBI has exercised its powers under Section 7, Section 8, Section 10(6) and Section 47(2) of the Foreign Exchange Management Act, 1999 to introduce these changes. The notification amends the Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026, which were originally notified through Notification No. FEMA 23(R)/2026-RB dated January 13, 2026.

The amendment should therefore be understood as a modification of the existing 2026 regulations rather than a completely new regulatory. Businesses already following the principal regulations must now identify the specific provisions that have been altered by the September 2026 notification.

Effective Date of the Amendment

The amendment regulations will come into force from October 1, 2026. The effective date is important because one of the newly inserted provisions specifically deals with transactions undertaken before October 1, 2026. As a result, businesses should distinguish between transactions undertaken before the effective date and those undertaken after the new becomes operational.

Any pending export, import or merchanting trade transaction should therefore be reviewed carefully to determine whether it falls within the transitional arrangement provided under the amendment.

Key Changes Introduced by the RBI

The RBI amendment introduces three significant changes. The first change relates to Regulation 5, where specified periods have been reduced from 15 months to 9 months and from 18 months to 12 months. The second change relates to Regulation 13, where a new proviso has been inserted concerning exporters appearing on the Caution List as of September 30, 2026.

The third change is the insertion of a new Regulation 20, titled “Powers to Authorised Dealers,” which deals with transactions undertaken before October 1, 2026 that previously required RBI approval. These three changes together create a revised compliance and transitional for cross-border trade transactions.

Amendment to Regulation 5

One of the most significant parts of the notification is the amendment to Regulation 5 of the principal regulations. In Regulation 5(1), the RBI has substituted the words “fifteen months” with “nine months” in clauses (a) and (b). It has also replaced “eighteen months” with “twelve months” in the first proviso.

The change can be summarised as follows:

Earlier Period	Revised Period
15 months	9 months
18 months	12 months

Both periods have therefore been shortened by six months.

Significance of the Revised Timelines

The reduction in timelines is an important compliance development because affected businesses will now have less time to complete the requirements associated with the relevant provisions of Regulation 5. A compliance process that was previously monitored over a 15-month period may now need to be completed within nine months, while an obligation linked to an 18-month period will now need to be completed within 12 months where the amended provision applies.

Businesses should therefore immediately review internal calendars, pending transactions and compliance tracking systems. However, an important point must be noted. The amendment notification itself does not reproduce the complete text of Regulation 5(1)(a), Regulation 5(1)(b) or the first proviso. Therefore, while the notification clearly changes the periods from 15 months to 9 months and from 18 months to 12 months, the exact obligations to which these timelines apply must be read together with the principal regulations. Businesses should avoid applying the new timelines in isolation without checking the underlying provisions of Regulation 5.

Need for Stronger Internal Compliance Monitoring

The reduction in timelines makes effective compliance monitoring more important. Businesses involved in cross-border transactions often deal with multiple departments, including finance, legal, treasury, accounts, logistics and banking teams. Where a regulatory period has been shortened, delays in coordination between these teams may increase the risk of non-compliance.

Companies should therefore maintain an internal compliance register containing relevant transaction dates, applicable regulatory timelines, pending documentation and communication with Authorised Dealers. Periodic internal reviews may also help businesses identify transactions approaching the revised deadline. A structured monitoring system becomes particularly important where a company handles a high volume of export or import transactions.

Amendment to Regulation 13

The RBI has also introduced an important transitional provision at the end of Regulation 13. Under the newly inserted proviso, exporters who are on the Caution List as of September 30, 2026 pursuant to RBI orders issued under Regulation 16 of the Foreign Exchange Management (Export of Goods & Services) Regulations, 2015 will continue to be governed by those orders until they are removed from the Caution List. This provision ensures continuity in the treatment of exporters who were already subject to caution-list restrictions immediately before the new regulations take effect.

Impact on Exporters Appearing on the Caution List

The transitional provision is particularly important for exporters who were already included on the Caution List before the amended regulations became operational. An exporter appearing on the Caution List as of September 30, 2026 should not assume that the commencement of the amendment on October 1, 2026 automatically removes the earlier restriction.

The notification expressly provides that the earlier RBI order will continue to govern such exporters until they are removed from the Caution List. Accordingly, the status of the exporter remains relevant even after the amended regulations take effect. Businesses in this position should continue maintaining proper transaction records and comply with the applicable RBI order until their status is formally changed.

Why September 30, 2026 Is Important

September 30, 2026 is a critical cut-off date under the amendment. The notification specifically refers to exporters who are on the Caution List as on September 30, 2026. This means that the transitional treatment is tied to the exporter's status on that particular date.

Businesses should therefore check their regulatory position as of September 30, 2026 and ensure that internal records accurately reflect any caution-list status or RBI order applicable to them.

Insertion of New Regulation 20

Another major change is the insertion of a new Regulation 20, titled “Powers to Authorised Dealers.” This provision states that Authorised Dealers will handle transactions relating to the export and import of goods and services, as well as merchanting trade, that were undertaken before October 1, 2026 and previously required RBI approval under the earlier regulatory. This is an important transitional provision because it changes the route through which certain older transactions may now be handled.

Transactions Covered Under Regulation 20

The new Regulation 20 covers three broad categories of transactions.

Export of Goods and Services

Export transactions relating to goods and services undertaken before October 1, 2026 may fall within the scope of Regulation 20 where such transactions previously required RBI approval under the earlier regulations or Master Directions.

Businesses with pending export matters should therefore identify whether the transaction was undertaken before the effective date and whether it previously required RBI approval. Where the conditions are satisfied, the Authorised Dealer will handle the transaction under the newly inserted provision.

Import of Goods and Services

Import transactions are also expressly covered under Regulation 20. Businesses with pending import-related matters undertaken before October 1, 2026 should review whether those matters were previously subject to direct RBI approval.

If so, the new provision may permit the Authorised Dealer to handle the transaction. Importers should therefore maintain proper records regarding the date, nature and regulatory treatment of the transaction.

Merchanting Trade Transactions

Merchanting trade has also been specifically included in the new Regulation 20. Businesses engaged in merchanting trade should identify pending transactions undertaken before October 1, 2026 that were previously subject to RBI approval. The amendment provides a route for Authorised Dealers to handle such transactions under the transitional.

Meaning of the Transition to Authorised Dealers

The insertion of Regulation 20 is significant because it gives Authorised Dealers a specific role in dealing with certain legacy transactions. Under the earlier, some transactions relating to exports, imports or merchanting trade required approval from the Reserve Bank of India. For qualifying transactions undertaken before October 1, 2026, the new provision allows Authorised Dealers to handle matters that previously required RBI approval.

This may simplify the processing for businesses dealing with old or pending transactions. However, businesses should not assume that every historical transaction automatically falls under Regulation 20. The provision applies specifically to the transactions described in the amendment.

Earlier Regulatory Structure Referred to in Regulation 20

The new Regulation 20 refers to transactions that previously required RBI approval under certain earlier regulatory instruments. These include the Foreign Exchange Management (Export of Goods and Services) Regulations, 2015. The provision also refers to the Master Direction – Export of Goods and Services, dated January 1, 2016 and updated until July 17, 2026.

It further refers to the Master Direction – Import of Goods and Services, dated January 1, 2016 and updated until January 12, 2026. Businesses reviewing historical transactions should therefore identify the earlier regulatory provision under which RBI approval was originally required.

Role of Authorised Dealers After October 1, 2026

Authorised Dealers will have an important operational role under the transitional. Where a qualifying transaction was undertaken before October 1, 2026 and previously required RBI approval, the Authorised Dealer may handle the matter under Regulation 20. Businesses should therefore coordinate with the relevant Authorised Dealer and provide complete transaction information and documentation.

The amendment itself does not prescribe a detailed document checklist for every transaction. Accordingly, documentation requirements may depend on the nature of the particular export, import or merchanting trade matter.

Impact on Export-Oriented Businesses

Exporters should review the amendment from three different perspectives. First, businesses affected by Regulation 5 should assess how the revised timelines impact their existing compliance processes. Second, exporters appearing on the Caution List as of September 30, 2026 should continue complying with the applicable earlier RBI order until formally removed.

Third, businesses with older export transactions that previously required RBI approval should examine whether Regulation 20 allows the Authorised Dealer to handle the pending matter. This makes a complete review of pending export transactions particularly important before October 1, 2026.

Impact on Import-Oriented Businesses

Importers should identify all transactions undertaken before the effective date that remain pending from a foreign exchange compliance perspective. Where the transaction previously required RBI approval, businesses should determine whether it can now be handled by the Authorised Dealer under Regulation 20.

Importers should also ensure that transaction documents are complete and easily available. This may include commercial and banking documents relevant to the transaction, although the amendment itself does not provide a detailed list of documents required for every case.

Impact on Merchanting Trade Businesses

Businesses engaged in merchanting trade should pay close attention to the amendment because Regulation 20 expressly includes merchanting trade transactions. Any merchanting trade transaction undertaken before October 1, 2026 that previously required RBI approval should be reviewed.

Businesses should determine the date of the transaction, the earlier approval requirement and whether the transaction falls within the scope of Regulation 20. Maintaining an accurate transaction history will make this review easier.

Importance of Proper Transaction Classification

One of the practical consequences of the amendment is that transaction dates have become particularly important. Businesses should classify transactions according to whether they were undertaken before or after October 1, 2026. Transactions undertaken before October 1, 2026 may qualify for the transitional arrangement under Regulation 20 where the other conditions are satisfied.

Transactions undertaken from October 1, 2026 onward will need to be assessed under the regulatory applicable from that date. Proper classification will help businesses avoid applying the wrong compliance process.

Internal Compliance Review Businesses Should Conduct

Businesses affected by the amendment should conduct a structured internal review. The first step should be to identify all pending export, import and merchanting trade transactions. The second step should be to determine the date on which each transaction was undertaken.

The third step should involve checking whether any matter previously required RBI approval. Businesses should also identify exporters within the organisation, if any, who were subject to a Caution List order as of September 30, 2026. Finally, internal compliance calendars should be updated to reflect the revised nine-month and twelve-month timelines under Regulation 5.

Documentation and Record-Keeping

Proper record-keeping remains essential under any foreign exchange compliance. Businesses should maintain transaction records, banking correspondence and documents relevant to export, import and merchanting trade matters. Where Regulation 20 is being relied upon, records demonstrating that the transaction was undertaken before October 1, 2026 may become particularly important.

Companies should also maintain copies of earlier RBI communication or approvals connected with pending transactions where applicable. Well-organised documentation can make communication with Authorised Dealers more efficient.

Importance of Coordination with Authorised Dealers

The amendment increases the importance of communication between businesses and Authorised Dealer banks. Businesses with legacy transactions should not wait until a matter becomes overdue or complicated before contacting the Authorised Dealer.

Early coordination can help determine whether the transaction falls within Regulation 20 and what information or documentation may be required. Similarly, businesses affected by revised regulatory timelines should ensure that their banking and internal compliance teams are working with the same set of dates.

Key Dates Under the Amendment

Several dates are particularly important under the RBI notification. September 22, 2026 is the date on which the amendment notification was issued. September 30, 2026 is the relevant date for determining the transitional treatment of exporters appearing on the Caution List. October 1, 2026 is the date from which the amendment regulations come into force. October 1, 2026 is also the cut-off used under Regulation 20 for identifying qualifying legacy export, import and merchanting trade transactions.

Key Compliance Takeaways

The RBI amendment introduces a number of practical compliance considerations for businesses. The most immediate change is the reduction in specified periods under Regulation 5 from 15 months to 9 months and from 18 months to 12 months.

Businesses should therefore review whether any pending matter falls under the affected provisions. Exporters appearing on the Caution List as of September 30, 2026 should remember that their earlier RBI order continues to apply until removal from the list. Businesses with transactions undertaken before October 1, 2026 should also examine whether those matters can now be handled by their Authorised Dealer under Regulation 20.

Conclusion

The Foreign Exchange Management (Export and Import of Goods and Services) (Amendment) Regulations, 2026 introduce important regulatory changes for exporters, importers, Authorised Dealers and businesses engaged in merchanting trade. The amendment will become effective from October 1, 2026 and brings three major changes. It reduces specified timelines under Regulation 5 from 15 months to 9 months and from 18 months to 12 months. It continues the existing treatment of exporters who remain on the Caution List as of September 30, 2026. It also introduces Regulation 20, enabling Authorised Dealers to handle qualifying legacy transactions that previously required RBI approval.

Businesses should carefully review pending transactions, update internal FEMA compliance systems and coordinate with their Authorised Dealer banks wherever necessary. Particular attention should be given to the October 1, 2026 effective date and the revised regulatory timelines. A structured compliance review can help businesses identify affected transactions early, avoid missed deadlines and ensure a smoother transition to the amended regulatory.

Frequently Asked Questions

Q1. What is the RBI FEMA Amendment Regulations, 2026?

Ans. The amendment modifies certain provisions of the Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026. It changes specified timelines, addresses exporters on the Caution List and introduces new powers for Authorised Dealers concerning qualifying legacy transactions.

Q2. When will the amendment become effective?

Ans. The Foreign Exchange Management (Export and Import of Goods and Services) (Amendment) Regulations, 2026 will come into force from October 1, 2026. Businesses should review relevant pending transactions and internal compliance processes before the revised provisions become operational.

Q3. What change has been made to the 15-month period?

Ans. In Regulation 5(1), the RBI has replaced the words “fifteen months” with “nine months” in the relevant clauses. As a result, the prescribed period under those provisions has been reduced by six months.

Q4. What change has been made to the 18-month period?

Ans. The amendment replaces the earlier 18-month period contained in the first proviso to Regulation 5(1) with a 12-month period. Businesses affected by this provision should accordingly revise their compliance calendars and monitoring systems.

Q5. What happens to exporters on the Caution List?

Ans. Exporters who are on the Caution List as of September 30, 2026 will continue to be governed by the relevant earlier RBI order. The order will remain applicable until the exporter is formally removed from the Caution List.

Q6. What is Regulation 20?

Ans. Regulation 20 is a newly inserted provision titled “Powers to Authorised Dealers.” It allows Authorised Dealers to handle certain export, import and merchanting trade transactions undertaken before October 1, 2026 that previously required RBI approval.

Q7. Are import transactions covered by Regulation 20?

Ans. Yes. Qualifying import transactions undertaken before October 1, 2026 are included within the new Regulation 20 where they previously required approval under the regulatory instruments referred to in the amendment.

Q8. Are merchanting trade transactions covered?

Ans. Yes. Merchanting trade transactions are expressly covered under Regulation 20. Businesses should review pending merchanting trade transactions undertaken before October 1, 2026 to determine whether the new Authorised Dealer applies.

Q9. Does the amendment automatically remove an exporter from the Caution List?

Ans. No. The notification specifically states that exporters appearing on the Caution List as of September 30, 2026 will continue to be governed by the relevant RBI order until they are removed from the Caution List.

Q10. What should businesses do before October 1, 2026?

Ans. Businesses should review pending export, import and merchanting trade transactions, update internal compliance timelines, identify legacy matters that previously required RBI approval and coordinate with their Authorised Dealers regarding transactions that may fall within the transitional.