My foreign client paid after nine months. What now?

When a foreign client pays after the realisation period, the money is still welcome and still export income. What is missing is permission for the delay, and from 1 October 2026 that permission comes from your bank.¹

What is the deadline that was missed?

Regulation 5 of the FEMA (Export and Import of Goods and Services) Regulations, 2026 (the 2026 Regulations) requires the full export value of services to be realised and repatriated within nine months from the date of invoice.¹² The period is twelve months if the export is invoiced or settled in Indian rupees.¹² A designer who invoiced a Dubai client on 10 October 2026 had until 10 July 2027.

How do you regularise a late payment?

Ask your Authorised Dealer (AD) bank to extend the realisation period. The second proviso to regulation 5(1) lets the bank, on a request from the exporter citing reasons for the delay, allow an extension if it is satisfied with the reasons.¹ A request normally includes:

1. The invoice number, date, amount and client.
2. The date and reference of the payment that finally arrived.
3. The reason it was late, such as a disputed milestone, a client's funding delay or a change in its payment system.
4. Evidence: emails, the contract, a revised schedule.

There is no prescribed form. Each bank must have an internal policy and procedure that covers extensions, lists documents and charges, and is published on its website.¹ If the bank declines, its policy must include an escalation and appeal route.¹

What can the bank charge?

The 2026 Regulations set no fee. Regulation 19(3) requires charges to be reasonable and proportional, and bars the bank from levying any charge or penalty on you for a regulatory delay on your part.¹

Is there a bigger risk if payment is very late?

Only if the money stays unpaid for a long time. Under regulation 13, if proceeds remain unrealised for more than one year after the due date of realisation or any extended date, further exports can be made only against full advance or an irrevocable letter of credit.¹ A tutor whose client paid in month eleven is far from that line once the payment is in. See RBI exporter caution list.

What else should you check?

If you file GST returns and exported under a Letter of Undertaking, late payment can also matter for GST, which has its own time limit. See GST on export of services. For invoices that will never be paid in full, the route is a reduction, not an extension: see export proceeds not realised.

For invoices raised before 1 October 2026, ask your bank which period it applies, since regulation 20 gives banks the cases that earlier needed RBI approval.¹ The full process is in the extension guide. Check large or disputed cases with a chartered accountant.