Written 26 August 2026, updated 5 September and 8 October. Correction, 8 October: this post originally said the Ship-to GSTIN rule took effect on 1 August. It did not — NIC put it on hold on 30 July, before the start date. The section below now says so.
Three dates landed within ten weeks of each other. They come from three different regulators, they are unrelated to one another, and between them they touch almost every exporter in the country.
1 August 2026 — Ship-to GSTIN: announced, then put on hold
GSTN advisories in May and June 2026 said the Ship-to GSTIN would become a required field in the e-Invoice and e-Way Bill (by IRN) APIs whenever ship-to details are given. On 30 July 2026, before it took effect, the NIC e-Invoice and e-Way Bill portals marked those changes as withdrawn and put them on hold — together with the new e-Way Bill Closure feature. As of 8 October 2026 they are still on hold, so an invoice is not rejected today for leaving the field out.
It is still worth capturing the consignee's GSTIN now, because the rule can come back and the field has always been accepted:
- If the consignee is registered, their GSTIN goes in the field.
- If the consignee is not registered, the field carries
URP— unregistered person. Under the paused rule a blank would be refused with NIC error 5002.
Exports are the common case for URP: a foreign consignee has no GSTIN. The case to watch is a domestic drop-shipment — goods billed to a head office and shipped to a registered branch or a customer's site — where the consignee does have a GSTIN and it never gets captured. Declaring that consignee as URP would be a misdeclaration, not a workaround.
Watch the release notes on the NIC e-Invoice and e-Way Bill developer portals for a new start date.
31 August 2026 — the DGFT export-obligation extension has now expired
This date has passed. When this brief was first written it was the following Monday; it is now behind us, and as of 5 September no further extension has been announced.
Public Notice 51/2025-26, dated 6 March 2026, automatically extended the export-obligation period to 31 August 2026 for Advance Authorisations — including Annual and Special — and for EPCG authorisations whose EO period was expiring, or had already expired, between 1 March and 31 May 2026. The relief was granted automatically: no application, no composition fee.
It was also written as a one-time extension to a fixed date, with no rolling grace attached. So if you were relying on it, the position today is that the extended period has run out. That is a conversation to have with your Regional Authority about your EODC position now, rather than one to discover at redemption — and it is worth confirming against dgft.gov.in, since a later notice would not be reflected here.
Background on the underlying obligation is in our guide to the Advance Authorisation scheme.
1 October 2026 — the new FEMA export-import regulations take effect
This is the one still ahead of you, and the only one on this list you can still prepare for.
Notification FEMA 23(R)/2026-RB, dated 13 January 2026, replaces the old framework and consolidates the export and import provisions into a single set of regulations. It comes into force on 1 October 2026. Three changes matter for day-to-day operations:
- Nine months to realise export proceeds. As first issued in January the regulations said 15 months; RBI amended that to nine before they took effect (Notification FEMA 23(R)/(1)/2026-RB, 22 September 2026). Corrected 8 October 2026 — an earlier version of this brief said 15 months.
- Twelve months where the export is invoiced and/or settled in Indian Rupees (18 months as first issued, amended by the same notification).
- EDPMS and IDPMS entries up to ₹10 lakh closable on your own declaration — and closable in bulk, quarterly, rather than one entry at a time.
The self-declaration threshold is the quiet one. If you have a tail of small unclosed EDPMS entries that has been accumulating because each one costs more in bank correspondence than it is worth, that tail becomes clearable. It is worth pulling the list before October so you know how big it is.
Realisation tracking is what this regulation is really about; our note on the FIRC and how proceeds get evidenced covers the document side.
Sources
- GSTN advisories dated 20 May 2026 and 17 June 2026 — Ship-to GSTIN in the e-Invoice and e-Way Bill APIs, announced for 1 August 2026.
- NIC e-Invoice and e-Way Bill release notes dated 30 July 2026 — those changes withdrawn and kept on hold.
- DGFT Public Notice 51/2025-26 dated 6 March 2026 — automatic EO extension to 31 August 2026.
- RBI Notification FEMA 23(R)/2026-RB dated 13 January 2026 — Export and Import of Goods and Services Regulations, 2026, in force 1 October 2026.
- RBI Notification FEMA 23(R)/(1)/2026-RB dated 22 September 2026 — amendment to those regulations: realisation period nine months (twelve for rupee invoicing), in force 1 October 2026.
Deadlines and portal behaviour change. Check the source before acting on any date in this post.
Eximly writes the Ship-to block on e-invoices for you — export consignees go out as URP with the state derived from the GSTIN, and domestic customers carry a Consignee GSTIN field so a registered consignee is declared properly instead of being flattened to URP. Start free.
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