The Principal Regulations originally prescribed strict timelines for both export realisation and advance-payment shipments. Under Regulation 9(1) and Regulation 9(2)(a), exporters were required to realise and repatriate the full export value “within nine months” from the date of export, including for SEZ/EOU/Status Holder/EHTP/STP/BTP units. These specific words—“within nine months”—are exactly the parts now substituted with “fifteen months”.

Likewise, Regulation 15(1)(i) mandated that when an exporter received an advance payment, the shipment of goods had to be completed “within one year” from the date of receipt of the advance. The proviso to Regulation 15(1) used the same “one year” period when restricting refunds of unutilised advances, stating that no remittance towards refund or interest could be made after the expiry of one year without RBI’s approval. The same “one year” phrase appeared again in Regulation 15(2) for export agreements providing for shipments extending beyond one year. All these references to “one year” in Regulation 15 have now been substituted with “three years” through this amendment.

The Reserve Bank of India (RBI), under Sections 7, 8 and sub-section (2) of Section 47 of FEMA, has issued further amendments to the Export of Goods & Services Regulations, 2015

• Amendment to Regulation 9 of the Principal Regulations:
  (i) In sub-regulation (1): the existing timeline of “nine months” has been substituted with “fifteen months”.
  (ii) In sub-regulation (2), clause (a): the timeline “nine months” is replaced by “fifteen months”.
• Amendment to Regulation 15 of the Principal Regulations:
  (i) In sub-regulation (1), clause (i): the timeline “one year” has been replaced by “three years”.
  (ii) In the proviso to sub-regulation (1): “one year” is substituted by “three years”.
  (iii) In sub-regulation (2): “one year” is replaced by “three years”.