FEMA's New Import Rules, 2026: What Changes for CXOs from 1 October 2026

Regulatory Guide · Foreign Exchange & Trade Compliance · October 2026

Quick Answer: With effect from 1 October 2026, the Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026 (Notification No. FEMA 23(R)/2026-RB) place import of goods and services, for the first time, in the same gazetted FEMA Regulation as export, a space earlier governed only by the Current Account Transactions Rules, 2000 and RBI's administrative Master Direction 17.

By the LexComply Advisory & Compliance Team

Last updated: 12 October 2026 · Content current as of 1 October 2026

For importers, the headline changes are: the fixed 6-month import payment rule is replaced by a contract-based timeline; advance-remittance thresholds move from RBI-fixed dollar figures to each Authorised Dealer's own board-approved policy; advance remittance for gold and silver is presumptively barred; third-party import payments and same-AD routing of advance payments are now expressly codified; and the ₹10 lakh small-value IDPMS self-certification threshold is written directly into the Regulation. This article covers only the import side, a companion article covers what changes for exporters.

What Are the Key Takeaways From the FEMA Import Regulations, 2026?

• Import of goods and services is, for the first time, governed by a dedicated gazetted FEMA Regulation rather than only the Current Account Transactions Rules, 2000 plus RBI's administrative Master Direction 17.
• The old blanket 6-month import payment deadline is gone. Authorised Dealers now track payment against the due date in the underlying commercial contract, with AD-level extension on request.
• Advance-remittance thresholds for imports (e.g., the old USD 200,000 / USD 5 million bank-guarantee triggers) are no longer fixed by RBI in the Regulation; each AD bank must now set its own thresholds in a board-approved internal policy.
• Advance remittance for gold or silver is now presumptively prohibited under Regulation 11, subject to a 'save as otherwise provided' carve-out whose scope for existing IIBX/Qualified-Jeweller schemes is not yet free of doubt.
• Routing of advance import payments and subsequent payments through the same AD bank, and the conditions for third-party import payments, are now expressly set out in the Regulation itself (Regulations 8 and 10), not just AD practice.
• Import-not-materialised consequences (mandatory repatriation of unused advance, standby LC/guarantee requirement for future advances) are now expressly codified in Regulation 12.
• AD banks are barred for the first time from levying any charge or penalty on an importer for a regulatory delay that is the AD's own, a new customer-protection safeguard (Regulation 19(3)).
• The ₹10 lakh small-value self-certification threshold for closing IDPMS entries (already live via an October 2025 RBI circular) is now written directly into the Regulation, with a quarterly bulk-declaration route formalised alongside it.
• An unpaid import does not automatically become External Commercial Borrowing (ECB), but deferred-payment terms running beyond 180 days sit under RBI's separate Trade Credit/ECB framework, with a 3-year ceiling for capital goods and a 1-year (or operating-cycle) ceiling for non-capital goods, independent of the import-payment timeline under Regulation 9.
• RBI's Master Direction 17 (Import of Goods and Services) has not yet been reissued to match the new Regulation. Expect a revised Master Direction and updated AD-bank SOPs to follow.

Why Did RBI Put Imports Into a Gazetted FEMA Regulation?

The Reserve Bank of India notified the Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026 (FEMA 23(R)/2026-RB) on 13 January 2026, bringing it into force from 1 October 2026. Until now, import of goods and services into India has run on the Foreign Exchange Management (Current Account Transactions) Rules, 2000 (a Government of India Rule under Section 5 of FEMA) read with RBI's Master Direction No. 17/2016-17, an administrative Direction to Authorised Dealer banks, not a Regulation in its own right. The new Regulations change that: for the first time, import sits in the same statutory Regulation as export, issued under Sections 7, 8, 10(6) and 47(2) of FEMA. FEDAI (the Foreign Exchange Dealers' Association of India) has already circulated clarifications to member banks on operational points under the new framework, and Authorised Dealer banks are expected to revise their internal SOPs in line with Regulation 19. This article focuses specifically on what changes for importers: what is different, which sectors feel it most, and what CXOs, treasury and compliance teams should action before and after 1 October 2026. The export-side changes (realisation period, EDF filing, unrealised-export consequences) are covered in a separate companion article.

Old Position vs New Position: What Changes for Importers From 1 October 2026?

The table below compares the position that applied up to 30 September 2026 (under the Current Account Transactions Rules, 2000 and RBI's Master Direction 17 on Import of Goods and Services) against the position from 1 October 2026 under the new FEMA 23(R)/2026-RB Regulations, for import-related provisions specifically.

What Has Not Changed for Importers?

• Import licensing and Foreign Trade Policy conformity requirements (negative list, DGFT licences); these sit outside FEMA and are untouched.
• Documentary evidence-of-import mechanics (Bill of Entry, Postal Appraisal Form, Customs Assessment Certificate) and the IDPMS reporting workflow. These continue as detailed in Master Direction 17 until RBI revises it.
• Sector-specific advance-remittance schemes for rough diamonds, aircraft/helicopters and shipping vessels (Master Direction 17, paras C.1.2–C.1.3). These continue to operate as the AD's threshold framework under the new Regulation's principle-based approach.
• The Online Payment Gateway Service Provider (OPGSP) route for small-value import payments (goods/software up to USD 2,000) under Master Direction 17, para C.15, untouched by the new Regulation.
• Replacement-import guarantees, BPO-equipment-remittance, import-factoring and settlement of import transactions in currencies without a direct exchange rate. All remain governed by Master Direction 17 as operational detail the new Regulation does not independently address.
• The separate RBI framework for External Commercial Borrowings, Trade Credits and Structured Obligations, under which import payment terms running beyond 180 days from shipment become reportable Trade Credit (ceiling: 3 years for capital goods; 1 year, or the operating cycle if shorter, for non-capital goods), and anything structured beyond that ceiling must be raised as ECB from inception, is untouched by the new Regulation and continues to apply alongside it.

Note: RBI's Master Direction 17 on file is dated as updated on 12 January 2026, a day before the new Regulations were notified, and well before their 1 October 2026 effective date. RBI is expected to reissue it to reflect the new framework; until then, apply the new Regulation wherever the two conflict and the Master Direction for everything the new Regulation does not address.

Which Sectors Are Most Affected by the New FEMA Import Rules?

The changes do not land evenly across import-dependent sectors. Some gain real flexibility in payment terms and bank thresholds; gold and silver importers face a near-term compliance question that needs resolving before 1 October 2026 payment cycles run.

Capital Goods, Electronics, Auto Components and Machinery Importers

• The shift from a fixed 6-month RBI deadline to a contract-based import payment timeline (Regulation 9) gives genuine room to negotiate supplier payment terms on high-value machinery and component purchases, but it also removes the bright-line RBI backstop finance teams have relied on for internal escalation triggers.
• Advance-remittance limits for high-value capital equipment imports will now depend on each AD's own board-approved policy rather than a uniform RBI figure. Expect differences in appetite and documentation requirements across banking relationships, and build that into supplier negotiations and banking-partner selection.
• The new same-AD routing rule for advance and subsequent payments (Regulation 10(1)–(2)) matters most here, given multi-tranche capital goods payments often span many months. Confirm internal treasury workflows route every tranche through the originally notified AD.
• Aircraft, helicopter and shipping-vessel importers continue under the existing sector-specific USD 50 million advance-remittance dispensation in Master Direction 17, unaffected by the general principle-based shift.
• Deferred-payment terms beyond 180 days on capital goods imports are Trade Credit, not an ordinary import payment, they sit under RBI's separate ECB/Trade Credit framework (3-year ceiling, reportable on Form TC) rather than Regulation 9, and should be tracked separately, especially for long-gestation machinery or project imports where supplier credit terms commonly run past 180 days.

Gems, Jewellery, Bullion and Precious Metals Importers

• The sector most exposed to the change: Regulation 11's default bar on advance remittance for gold/silver sits awkwardly against the live IIBX/Qualified-Jeweller/TRQ-holder advance-payment schemes in Master Direction 17.
• Nominated banks, nominated agencies, Qualified Jewellers and India-UAE CEPA TRQ holders should seek explicit confirmation from their AD bank or RBI before routing any advance remittance for gold or silver on or after 1 October 2026. Do not assume the old schemes continue automatically.
• Rough-diamond advance remittance (GJEPC-recommendation route) is not gold or silver and is not directly affected by Regulation 11, but should still be re-confirmed against the AD's revised internal policy under Regulation 19.
• Platinum, palladium and rhodium import financing (Suppliers'/Buyers' Credit, 90-day usance cap) continues under Master Direction 17, which Regulation 11 does not touch.

Pharma, Chemicals and Life Sciences: API and Raw Material Importers

• Benefit from the contract-based import payment timeline where overseas API/raw-material suppliers offer longer credit terms than the old 6-month default allowed without special extension.
• Regulation 12's codified import-not-materialised consequences matter here given the sector's exposure to regulatory/customs delays on specialised or temperature-sensitive consignments. Track advance payments against contract delivery windows more tightly than before.
• Third-party payment provisions (Regulation 8) are relevant where API imports route through global procurement/group-company structures rather than a direct bilateral contract. Confirm documentation matches Master Direction 17's continuing conditions.

IT Hardware, Software Licensing and BPO/ITES Equipment Imports

• Software, data and drawings/designs received in non-physical form (internet/datacom, email/fax) continue to be evidenced by a Chartered Accountant certificate under Master Direction 17, para C.7.3, unaffected by the new Regulation.
• BPO companies importing and installing equipment at overseas International Call Centre sites continue under the existing Master Direction 17, para C.5 framework (CEO/auditor evidence certificate); the new Regulation does not independently address this.
• General hardware and licence-fee remittances benefit from the same AD-set advance-remittance thresholds and contract-based payment timeline as other goods imports.

MSME Importers

• The biggest practical relief: the ₹10 lakh IDPMS self-certification threshold (now in the Regulation itself) removes formal bank-realisation certificates for the bulk of a typical MSME's Bill-of-Entry-level transactions.
• Quarterly, consolidated self-declaration for bulk closure cuts recurring paperwork for high-volume, low-ticket importers, a direct time and cost saving for lean finance teams.
• The new Regulation 19(3) bar on AD banks penalising customers for the AD's own regulatory delays protects MSME importers specifically, who are least able to absorb unexplained bank charges.

E-Commerce, D2C and Marketplace-Dependent Importers

• The Online Payment Gateway Service Provider (OPGSP) route for import payments up to USD 2,000 per transaction (Master Direction 17, para C.15) is untouched by the new Regulation. Still the fastest route for low-value, high-frequency inventory or dropshipping-style imports.
• Above that threshold, the ₹10 lakh IDPMS self-certification and quarterly bulk-closure routes reduce the realisation-evidence burden for D2C brands importing components or finished goods in bulk.

Trading Companies: Import Leg of Merchanting Trade

• The import leg of a Merchanting Trade Transaction (goods acquired that do not enter the Domestic Tariff Area) now has an explicit Regulation-level anchor (Regulation 16) alongside Master Direction 17's detailed 9-month overall completion and 6-month inter-leg conditions, which continue to apply.
• Letters of Credit to the overseas supplier for the import leg remain permitted against a confirmed export order, subject to the existing six-month foreign-exchange-outlay and nine-month MTT-completion conditions in Master Direction 17.
• Import-leg payments from balances parked in EEFC or an interest-bearing INR account (pending the import leg) continue to be governed by Master Direction 17's existing conditions.

Banks, NBFCs and Trade-Finance Intermediaries

• Compliance lift for Authorised Dealers: Regulation 19 requires a comprehensive, board-approved internal policy and SOP covering import documentation, timelines, charges, extension criteria, delegation of authority, and a formal customer-grievance escalation mechanism.
• The bar on penalising customers for the bank's own regulatory delay (Regulation 19(3)) is a new conduct obligation that compliance and operations teams at AD banks need to build into import-related customer-charging logic before 1 October 2026.
• Expect divergence in advance-remittance thresholds, evidence requirements and extension practices across AD banks until market practice settles, a relationship-banking consideration for corporates with multiple banking partners for import financing.

What Are the FEMA Import Compliance Action Points for CXOs?

Organised by function, so each owner can work from their own list.

Treasury and Finance

• Review outstanding and planned advance remittances for imports. Confirm current and post-1-October thresholds directly with each AD bank rather than assuming the old USD 200,000/5 million figures still apply.
• If the business imports or deals in gold or silver in any form, pause and confirm the applicable advance-remittance position with the AD bank and, if needed, RBI before processing any further advance payment.
• Flag the loss of the fixed 6-month import-payment backstop to internal treasury controls. Replace it with contract-due-date tracking per vendor.
• Confirm every advance and subsequent import payment for a given transaction is routed through the same AD bank as required by Regulation 10(1)–(2), and update internal payment workflows/vendor master data accordingly.
• Re-check interest computations on any usance or delayed import payment against the Borrowing and Lending Regulations' all-in-cost ceiling, and confirm with the AD whether the old 3-year outer duration limit still applies in practice.
• Track deferred-payment import terms against the separate Trade Credit/ECB tenor ceilings (3 years for capital goods; 1 year, or the operating cycle if shorter, for non-capital goods). Crossing these triggers Form TC or full ECB compliance, independent of the import-payment timeline under Regulation 9.

Legal and Compliance

• Map every FEMA-linked SOP, delegation-of-authority matrix and vendor contract clause that currently references the old 6-month import rule or the old RBI-fixed advance-remittance figures, and update the cross-references.
• Request each AD banking partner's revised internal policy and SOP (mandatory under Regulation 19) as soon as it is published, and compare import-related thresholds across banking relationships.
• Review third-party import payment documentation (irrevocable purchase orders, tripartite agreements, invoice/Bill-of-Entry narration) against Master Direction 17's continuing conditions, now sitting under Regulation 8's general principle.
• Brief the board or audit committee on Regulation 19(3) (the new bar on AD banks charging customers for the bank's own regulatory delays), so any wrongly levied import-related charge is challenged, not absorbed.
• Maintain a dated compliance file evidencing which framework (old Master Direction vs new Regulation) governed a given import transaction, given the transition straddles 30 September/1 October 2026.

Trade, Procurement and Vendor Management

• Renegotiate import payment terms with overseas suppliers now that timelines are contract-driven rather than RBI-capped at 6 months. Longer terms may be commercially available where they were not before.
• For multi-tranche capital goods or project imports, align payment-tranche scheduling with the same-AD routing requirement so advance and subsequent payments are not inadvertently split across banking relationships.
• Where imports route through group/associate companies or a global procurement entity, review the arrangement against Regulation 8's third-party payment principle and Master Direction 17's documentary conditions.
• Review the import leg of any Merchanting Trade structure against the newly codified Regulation 16 to ensure documentation is consistent with the Regulation text, not just historical practice.

IT, ERP and Systems

• Confirm ERP/trade-finance system logic for IDPMS closure reflects the ₹10 lakh threshold and the quarterly bulk-declaration option, rather than older manual processes.
• Update internal alerts and dashboards that trigger on the old fixed 6-month import-payment clock to the new contract-based due-date logic per vendor/contract.
• Build a tracking field for "advance remittance: gold/silver" transactions specifically, pending clarity on Regulation 11's scope, so these can be isolated for manual sign-off rather than auto-processed.
• Add a same-AD validation check for advance and subsequent import payments against a given transaction/vendor, to flag any payment about to be routed through a different bank without the required intimation.

What Are the Common Mistakes to Avoid Under the New Import Rules?

Every point below restates an obligation already set out above; none of them adds a new rule.

• Assuming the old USD 200,000 and USD 5 million advance-remittance figures still bind. Those numbers now live in each Authorised Dealer's own internal policy, so they have to be confirmed bank by bank.
• Leaving the fixed 6-month import-payment clock in treasury dashboards and ERP alerts. Payment is now tracked against the due date in the underlying contract.
• Processing a gold or silver advance remittance on the assumption that the IIBX and Qualified-Jeweller schemes carried over. Regulation 11 states a default prohibition, and the carve-out needs AD or RBI confirmation first.
• Splitting advance and subsequent payments for one import across two banks. Regulation 10(1) to (2) requires the same Authorised Dealer unless both banks have been informed.
• Treating a long-overdue supplier payment as External Commercial Borrowing by default. ECB and Trade Credit treatment is tenor-based, not default-based.
• Absorbing a bank charge levied for the bank's own regulatory delay. Regulation 19(3) bars it.
• Reading Master Direction 17 as superseded in full. It continues to apply for everything the new Regulation does not address, until RBI reissues it.

Legal Disclaimer

This article summarises RBI's FEMA 23(R)/2026-RB Regulations and is independent commentary, not legal advice. Confirm transaction-specific positions, especially on gold and silver advance remittance and AD-bank thresholds, with your Authorised Dealer bank or RBI before acting.

Frequently Asked Questions

What exactly changed for importers on 1 October 2026?

The Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026 (FEMA 23(R)/2026-RB) came into force, placing import of goods and services in a dedicated FEMA Regulation for the first time. Import payment timelines, advance-remittance rules, gold/silver advance remittance, third-party import payments, same-AD routing, import-not-materialised consequences, and IDPMS closure thresholds are all affected. See the comparison table above for the detail.

Does the new Regulation override RBI's Master Direction 17 on Import of Goods and Services?

Where the two cover the same ground differently, yes; the new Regulation is a gazetted statutory instrument and takes precedence over the Master Direction, which is an administrative Direction issued under Sections 10(4) and 11(1) of FEMA. Where the new Regulation is silent (documentation mechanics, IDPMS operational procedure, sector-specific schemes, the OPGSP route), the Master Direction continues to apply until RBI formally revises it.

Is there still a fixed deadline for paying for imports?

No single RBI-fixed period applies any more. Payment is now tracked against the due date specified in the underlying import contract, with the Authorised Dealer following up and extending time on request where satisfied of the reasons cited (Regulation 9).

Are the old advance-remittance limits (USD 200,000 / USD 5 million) still valid for imports?

Not as fixed Regulation-level figures. The new framework asks each Authorised Dealer to set its own thresholds for import advance remittance in a board-approved internal policy (Regulation 19). Businesses should confirm current thresholds directly with their AD bank rather than relying on the old Master Direction numbers.

Can we still make advance payments for importing gold or silver?

Regulation 11 states a default prohibition on advance remittance for gold or silver, subject to a carve-out for anything "otherwise provided" under the Act, Rules, Regulations or Directions. Whether the existing IIBX/Qualified-Jeweller/TRQ-holder advance-payment schemes survive as a saved exception is not yet settled on the text alone. Confirm the current position with your AD bank or RBI before processing any such advance remittance.

Must advance and subsequent import payments go through the same bank?

Yes, Regulation 10(1)–(2) now expressly requires an importer to route the advance payment and all subsequent payments for that import through the same Authorised Dealer, unless both AD banks have been informed of a change. This was previously more a matter of AD practice than a standalone codified rule.

What are the rules on paying a third party for an import, instead of the actual overseas supplier?

Regulation 8 states the principle at the Regulation level; an AD may permit third-party receipts and payments for import transactions provided it is satisfied of the bonafides. Master Direction 17's detailed documentary conditions (an irrevocable purchase order or tripartite agreement, FATF checks, named-third-party narration on the invoice and Bill of Entry) continue to apply as the operating detail under this principle.

What is the ₹10 lakh IDPMS threshold, and is it new?

It is the value (per Bill of Entry/invoice) up to which an import entry can be closed on the importer's own declaration, without further realisation proof. It was already introduced by RBI circular effective 1 October 2025; the new Regulation simply writes it directly into the Regulation text, and formalises a quarterly consolidated-declaration route for bulk closure.

What happens if goods are not imported after an advance payment is made?

Under Regulation 12, if the advance payment is not repatriated within the contract period (or any extension allowed by the AD), or the IDPMS entry is not marked off, any future advance payment by that importer will require an unconditional, irrevocable standby Letter of Credit or an equivalent bank guarantee from an international or Indian bank of repute.

Can an AD bank charge us a penalty for its own delay in processing a regulatory matter?

No. Regulation 19(3) expressly bars an Authorised Dealer from levying any charge or penalty on an importer, exporter or merchant trader for a regulatory delay or violation that is the AD's own.

Is the small-value import payment route through online payment gateways (OPGSPs) still available?

Yes. The Online Payment Gateway Service Provider route for import of goods and software up to USD 2,000 per transaction (Master Direction 17, para C.15) is untouched by the new Regulation and continues to operate as before.

Is the Chapter 95 ITC-HS (toys) notification of March 2026 related to this change?

No. That notification (DGFT S.O. 1410(E), 18 March 2026) amends an import policy condition for toys under the Foreign Trade (Development & Regulation) Act, a Ministry of Commerce import-licensing matter, not an RBI/FEMA foreign-exchange control. It should be tracked separately from the FEMA changes covered here.

What should importers do first?

Identify every live or planned transaction that depends on the old 6-month import timeline, the old advance-remittance figures, or gold/silver advance remittance, and route those specifically to your AD bank for confirmation of the post-1-October position before processing. Everything else can follow the general action points set out above on its normal compliance cycle.

If we do not pay an overseas supplier for a long time, does the unpaid import automatically become External Commercial Borrowing (ECB)?

Not automatically. ECB/Trade Credit treatment is tenor-based, not default-based. Deferred import payment terms up to 180 days from shipment are an ordinary import payment, monitored under the import-payment framework (Regulation 9). Terms running beyond 180 days and up to the Trade Credit ceiling (3 years for capital goods, 1 year (or the operating cycle, if shorter) for non-capital goods) are "Trade Credit" under RBI's separate External Commercial Borrowings, Trade Credits and Structured Obligations framework, reportable on Form TC, whether bank-arranged (Buyers' Credit) or a direct supplier credit term (Suppliers' Credit). Anything structured for longer than the Trade Credit ceiling must be raised as ECB from the outset, with full ECB compliance: eligible lender, minimum average maturity, all-in-cost ceiling, end-use conditions, Form ECB reporting. A plain overdue payment that was never structured for a longer tenor does not convert to ECB merely by running late, it stays a delayed import payment requiring AD-bank follow-up, and becomes a FEMA contravention requiring compounding if left unresolved. The one place the two frameworks do connect under the new Regulation: the interest permitted on delayed import payments (Regulation 10(4)) is capped with reference to the Borrowing and Lending Regulations, 2018 all-in-cost ceiling, the same ceiling used for ECB/Trade Credit pricing.

How Does LexComply Track FEMA Compliance Requirements for Companies in India?

A regulatory transition that touches treasury, legal, procurement and IT at the same time is exactly where a compliance platform and hands-on advisory need to work together, not separately.

GCMS: the compliance management layer

• Import payment tracking: GCMS can hold the contract-based due date for every import payment per vendor/transaction, flagging approaching deadlines before they become overdue-payment events that need AD extension.
• IDPMS closure workflow: the ₹10 lakh self-certification and quarterly bulk-declaration routes can be built into GCMS as a standard workflow, rather than a manual finance-team exercise repeated every quarter.
• AD-bank threshold register: since advance-remittance thresholds now vary by AD bank under each bank's own policy, GCMS can maintain a single register of current import-advance thresholds by banking relationship, so treasury is not relying on memory or scattered emails.
• Same-AD routing checks: GCMS can flag an advance or subsequent import payment that would route through a different AD bank than the one originally used for that transaction, before it triggers a Regulation 10 compliance gap.
• Trade Credit/ECB tenor tracking: GCMS can flag any deferred-payment import term approaching the 180-day mark, and separately the 3-year (capital goods) or 1-year (non-capital goods) Trade Credit ceiling, so Form TC or full ECB compliance is triggered proactively rather than discovered during an audit.
• Audit trail: the basis for every advance remittance, import-not-materialised event and third-party payment (transaction type, AD bank, applicable Regulation, supporting documents) is stored with version history, ready if RBI, the AD bank or an auditor later queries a transaction.
• Circular and Master Direction monitoring: as RBI reissues Master Direction 17 and AD banks publish revised SOPs under Regulation 19, GCMS surfaces the update against the relevant compliance task instead of requiring the compliance team to track it separately.

FEMA and trade-regulation advisory

• Transaction-specific interpretation support: for open questions such as the Regulation 11 gold/silver advance-remittance carve-out, LexComply's advisory team tracks the AD-bank and RBI clarification and advises on the position to take in the interim.
• AD-bank SOP review: assessing a client's current banking relationships against each AD's revised internal policy under Regulation 19, and flagging where thresholds or documentation requirements differ enough to matter commercially.
• Contract and SOP realignment: updating internal treasury/compliance SOPs, vendor contract clauses and delegation-of-authority matrices that still reference the old 6-month import rule or the old RBI-fixed advance-remittance figures.
• Representation and liaison: assisting with AD-bank and RBI queries on transition-specific import issues, including the treatment of in-flight import transactions that straddle 30 September/1 October 2026.
• Continuous monitoring: tracking RBI circulars, FEDAI clarifications and the expected revised Master Direction 17, so advisory guidance stays current rather than frozen at the date of this article.

Sources

• Reserve Bank of India, Notification No. FEMA 23(R)/2026-RB: Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026, dated 13 January 2026, effective 1 October 2026
• Foreign Exchange Dealers' Association of India (FEDAI), SPL-07/Trade/2026, 23 September 2026, Clarifications on implementation of the Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026, including import-side points on Bill of Entry due dates (Regulation 9) and imports not materialised (Regulation 12).
• Reserve Bank of India, Master Direction No. 17/2016-17, Master Direction on Import of Goods and Services (updated as on 12 January 2026)
• Foreign Exchange Management (Current Account Transactions) Rules, 2000 (Notification No. G.S.R. 381(E) dated 3 May 2000), the underlying Government Rule on which import permissibility rested prior to the new Regulations.
• Reserve Bank of India, Master Direction – External Commercial Borrowings, Trade Credits and Structured Obligations (RBI/FED/2018-19/67, FED Master Direction No. 5/2018-19, 26 March 2019, as updated), the separate framework governing Trade Credit tenor ceilings and ECB treatment of deferred import payments referenced in this article.
• Foreign Trade (Development & Regulation) Act, 1992: DGFT Notification No. 64/2025-26, S.O. 1410(E), 18 March 2026 (Chapter 95 ITC-HS import policy condition), a separate DGFT trade-policy matter, referenced here only to distinguish it from the FEMA changes covered in this article.
• A companion article covering the export-side changes under FEMA 23(R)/2026-RB (realisation period, EDF filing and unrealised-export consequences) is planned separately.