RBI's 2 November 2026 second amendment to the FEMA Export and Import Regulations introduces deemed Export Declaration Form submission for resident individuals and certain small-value service exporters. It also narrows when Authorised Dealer banks enter service-import details in IDPMS. The notification explicitly takes effect from 1 October 2026.
Why this RBI change matters to authorised dealer banks
The Reserve Bank of India (RBI) issued the Foreign Exchange Management (Export and Import of Goods and Services) (Second Amendment) Regulations, 2026 through Notification No. FEMA 23(R)/(2)/2026-RB dated 2 November 2026. The amendment is expressly effective from 1 October 2026. It changes specified declaration requirements for exporters of services and reporting obligations of Authorised Dealer (AD) banks processing imports of services.
The notification’s text was examined in a reproduced version published by TaxGuru and in Gazette Tracker’s reproduction, and its substance cross-checked against The Indian Express and Reuters. The original RBI notification page was identified but was inaccessible directly during this check; this report therefore does not claim that original website page was read. The reproduced text identifies the legal instrument, operative wording and gazette date.
First change: Who is a resident individual?
The amended Regulation 2(1) defines a resident individual as a natural person resident in India. A company, partnership firm or other non-natural person is not a resident individual for this specific distinction even if it operates in India. This classification matters for the different Export Declaration Form (EDF) treatment and import monitoring conditions below.
Service exports: When is an EDF treated as submitted?
- Resident individual exporters of services: an EDF is deemed submitted when the individual furnishes the information required about receipt of payment for the services to the AD bank for crediting the exporter’s account. This inserted proviso does not state a monetary limit for that category.
- Exporters other than resident individuals: the corresponding deemed-submission provision applies where the inward remittance for the service is not more than ₹10 lakh or its foreign-currency equivalent, and the necessary payment information is given to the AD bank. An amount of exactly ₹10 lakh is within ‘not more than’; above the threshold this particular relief does not apply.
Deemed submission is not unconditional freedom from giving the bank transaction details. The required information still must be supplied, and other applicable foreign-exchange obligations are not automatically waived. The text does not support treating ₹10 lakh as an annual turnover ceiling or advising clients to split payments to evade reporting.
Service imports: Which IDPMS entries remain mandatory?
The amendment replaces Regulation 18(1)(d) on service-import reporting. Under the revised clause, AD banks must enter information into the Import Data Processing and Monitoring System (IDPMS) when both conditions are met: the importer is a person other than a resident individual, and the invoice or contract value is more than ₹10 lakh or its equivalent in foreign currency. Entry is to be made within five working days of receipt of the relevant details from the importer.
The previous clause referred more generally to entering service-import details within five working days of receipt of documents. This revision narrows the circumstances covered by that specific duty; it does not erase every other FEMA compliance requirement or the need for valid checks on cross-border payments.
Practical implications for forex and branch teams
AD-bank forex operations and trade-service teams should check the correct exporter/importer classification before using the amended EDF and IDPMS pathways. An individual’s payment-information submission should not be judged against a ₹10 lakh cap that the individual proviso does not contain. Conversely, for other service exporters, the specific value of inward remittance matters.
Compliance, internal audit and technology teams may need to review transaction-check rules, exception handling and reporting queues in light of the amendment’s 1 October effective date. The exact bank-level implementation should follow authenticated institutional instructions and the operative consolidated FEMA text, rather than assumptions from a news summary. Staff should preserve evidence of payment information and follow the remaining applicable scrutiny requirements.
What this amendment does not change
It is a targeted amendment to Regulations 2, 3 and 18 of the 2026 framework. It does not itself replace all foreign-exchange regulations, remove due diligence for cross-border services, or alter every export realisation timeline. The earlier first amendment dated 22 September 2026 remains a separate instrument. For difficult legacy or split-payment situations, bank staff should rely on the complete current regulations and their authorised compliance channel.
Sources and References
- TaxGuru (RBI notification reproduced) — RBI Relaxes FEMA EDF and IDPMS Reporting Rules for Services from October 2026 (2026-11-03)
- The Indian Express — RBI eases export-import reporting for individuals, sets Rs 10 lakh threshold (2026-11-03)
- Reuters — India eases forex reporting rules for small value service exports, imports (2026-11-03)
- Gazette Tracker (Gazette text reproduced) — In exercise of the powers conferred by Sections 7, 8, 10 and 47 of FEMA (2026-11-02)
Please consult the cited sources and check the exact applicability of any legal or employment change. Corrections are welcomed.
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