Quarterly Insights — FEMA and RBI
The single biggest cross-border compliance shift this quarter: FEMA 23(R)/2026 will replace the legacy export framework and, for the first time, also govern imports, with a unified EDF, revised realization timelines, and a redesigned merchanting trade window. The Guarantees Regulations have also been rewritten.
Inside this briefing:
FEMA 23(R)/2026 — Export and Import of Goods and Services Regulations, 2026 (effective 1 October 2026): unified EDF (SOFTEX subsumed), 15-month realisation window for exports (18 months for INR-settled exports), set-off liberalised, gold and silver advance remittance withdrawn, and an MTT framework that caps the inward-outward gap at 6 months.
FEMA 8(R)/2026 — Guarantees Regulations (effective 1 April 2026): new Form GRN reporting (Issue / Modification / Invocation), defined timelines and Late Submission Fee.
RBI FLA FAQs (25 March 2026): new positions on CCDs, GIFT City entities, repatriable vs non-repatriable shareholdings, and Ind AS transition.
ECB returns: Form ECB-1 and ECB-2 mandatory through AD banks from 1 April 2026; LSF for delayed filing.
NBFC and Bank disclosures: new related-party lending disclosures, capital markets exposure tables, DICGC premium disclosure, and DLG treatment under Ind AS ECL.