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India’s cross-border trade rules are changing — fundamentally.

DrJoshua Ebenezer
India's cross-border trade rules adopt a unified, principle-based regime enabling contractual timelines and bank-led verification. The RBI has introduced a unified, principle-based Foreign Exchange Management framework that consolidates prior export-import rules into single Regulations and Directions, shifting to a transaction-focused approach. Export realisation now runs 15 months from shipment or invoice (18 months if settled in INR) with overseas-warehouse sales measured from sale; project exports follow contractual milestones. EDF replaces multiple filings; AD banks enforce genuineness, grant extensions, approve reductions and small-value closures (up to Rs.10 lakh) and manage netting, set-offs and merchanting verification. Imports align payment timelines with contracts; special safeguards apply to advances and precious metal imports. Banks publish SOPs and report suspicious transactions under RBI supervision. (AI Summary)

The Reserve Bank of India has ushered in a transformative era for India's cross-border trade with the Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026, notified on January 13, 2026, and accompanied by detailed Directions issued on January 16, 2026. These rules take effect from October 1, 2026, marking the most comprehensive overhaul since FEMAs inception. By superseding the 2015 Export Regulations, the separate Master Directions on exports and imports, and over 160 outdated circulars, the RBI has consolidated everything into a single, unified, principle-based framework that covers goods, services (including software), project exports, and merchanting trade. The core philosophy represents a decisive shift away from rigid, document-driven timelines and micromanagement toward a transaction-focused approach that trusts commercial contracts, empowers authorised dealer (AD) banks to verify genuineness, and aligns Indias trade plumbing with the realities of modern global supply chains.

Under the old system, exporters often found themselves racing against arbitrary clocks tied to shipping dates, even when goods lingered unsold in overseas warehouses or payments followed deferred commercial terms. Importers faced similar constraints, with payments squeezed into fixed windows regardless of supplier credit agreements. Service providers dealt with fragmented reporting like SOFTEX forms, adding layers of complexity to software and consulting exports. This mismatch created artificial defaults in monitoring systems like EDPMS and IDPMS, froze incentives such as duty drawbacks, strangled working capital, and turned banks into compliance gatekeepers rather than trade enablers. The 2026 framework dismantles these barriers by prioritising the underlying transaction over paperwork, allowing businesses to structure deals as they do in competitive global markets.

For exporters, the changes are particularly liberating. Export realisation must now occur within 15 months from the date of shipment for standard goods, from the invoice date for services and software, or crucially from the date of sale for goods sent to overseas warehouses, a game-changer for e-commerce platforms, fulfilment models, and DDP (Delivered Duty Paid) sellers. If invoiced or settled in Indian Rupees, the timeline extends generously to 18 months. Project exports follow contractual milestones rather than fixed deadlines, with AD banks permitted to verify bona fides and allow temporary short-term investments of surpluses abroad for up to one year. The Export Declaration Form (EDF) becomes the unified reporting tool: goods exporters submit it at the time of shipment (deemed filed via shipping bill at EDI ports), while service providers file within 30 days of the invoice months end, with the flexibility to cover multiple invoices or clients in a single form. Non-software service exporters can even submit EDF on or before payment receipt if needed, and AD banks may extend deadlines on reasonable grounds.

Reductions in export value or write-offs for unrealised amounts become far more straightforward, with AD banks empowered to approve them based on satisfaction with the exporters explanation. For transactions up to Rs.10 lakh per shipping bill or invoice, closures, reductions, or adjustments rely solely on the exporters declaration—no RBI approvals or protracted litigation required, and quarterly bulk declarations are allowed for efficiency. Advances against exports route through one AD bank (with switches permitted on intimation), and third-party receipts or payments are acceptable if the bank is convinced of their genuineness. Imagine Priya, a Delhi-based e-commerce entrepreneur exporting artisanal jewelry to US warehouses on DDP terms: previously, she risked defaults if items sat unsold beyond rigid shipment-tied timelines; now, her realisation clock starts only when the goods sell, giving her breathing room to scale without compliance panic. Similarly, Raj, a Bengaluru SaaS founder bundling software with hardware exports, enjoys a single EDF for streamlined reporting and 15 months from invoice to realise payments, freeing him to focus on innovation rather than forms.

Importers benefit from equally rational alignment with commercial realities. Payment timelines now follow the underlying contract rather than arbitrary RBI-imposed caps, with AD banks monitoring via IDPMS and granting extensions if satisfied with the reasons. Advances are permitted after genuineness checks, potentially requiring standby letters of credit or guarantees for higher thresholds, while interest on delays or advances stays within trade credit ceilings. If imports fail to materialise, advances must be repatriated promptly; failure triggers stricter safeguards like irrevocable standby LCs for future advances. Special rules apply to gold and silver imports, prohibiting advances altogether. For Sneha, a Pune manufacturer importing deferred-payment machinery from Germany, this means her cash flow matches supplier terms without frantic extensions or penalties, enabling smoother capital investments and production ramps.

Powerful cash-flow tools further enhance flexibility across the board. Set-offs and netting allow export receivables to offset import payables with the same overseas party or their group/associates, including goods against services, without previous calendar-year restrictions. Third-party payments and receipts gain approval if bona fide. Merchanting trade transactions (buy abroad, sell abroad) shed old burdens: no mandatory profitability proof, no strict 9-month caps (now a 6-month remittance window between legs, extendable), commissions permitted, and third-party involvement allowed on verification. This opens India as a viable hub for global trading desks, commodity plays, and supply-chain orchestration, much like Singapore or Dubai. A Kolkata trader like Tara can now buy Indonesian spices and resell to Australia with greater ease, monitoring both legs through EDPMS/IDPMS without prohibitive hurdles.

Small-value transactions receive special relief, with declarations sufficing for closures and adjustments up to Rs.10 lakh, democratising access for MSMEs. Service providers like Lena, a Hyderabad freelance designer invoicing modest US projects, can declare partial realisations and close entries swiftly, claiming incentives without bureaucratic drag.

The most profound structural change hands primary regulatory responsibility to AD banks. The RBI sets the overarching principles and supervises, but banks now develop and publish internal SOPs covering approvals, extensions, set-offs, grievances, and charges, ensuring reasonable fees, delegation, appeals, and transparency via websites. Banks verify genuineness for every key step, update monitoring systems promptly, report suspicious activity to the Enforcement Directorate, and handle escalations efficiently. While this promises faster, commercially attuned decisions, it also means your choice of AD bank matters more than ever, as interpretations may vary.

From October 1, 2026, India evolves from a nation fixated on filing shipping bills to one that orchestrates sophisticated global supply chains, supporting overseas warehousing, digital services, treasury netting, hybrid SaaS-hardware models, and merchanting hubs. Transitional actions, reviewing open EDPMS/IDPMS entries, aligning contracts, and studying bank SOPs will smooth the shift, though clarifications may still emerge on legacy disputes, long-term contracts, or specialised trades. The RBI has delivered genuine freedom, backed by trust in businesses and banks. For exporters dreaming of borderless growth, importers seeking seamless procurement, and service providers building digital empires, this is the moment to seize: Indias trade playbook has been rewritten, and the world is now more open than ever. Dive into the official RBI notifications for the complete text, and let the new era propel your ambitions forward.

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