RBI and FEMA

RBI's 9-Month Realisation Rule After the 15-Month Window: What GST, LUT and eBRC Mean for Service Exporters

Author:: Editorial team, serviceexportguide.com
Verified by:: Editorial team
Published: 31 October 2026
Last modified: 31 October 2026
Fees checked on: 28 October 2026
Reading time: 7 min read

Short answer

RBI extended the realisation period for exports to 15 months from 14 November 2025.¹ It returned to nine months from 5 June 2026.² Under the FEMA (Export and Import of Goods and Services) Regulations, 2026, services must be realised within nine months of the invoice, or twelve months in rupees.³ Rule 96A ties LUT relief to that period.⁴

Applies to	Rules involved	Platforms compared	Last verified
Every Indian exporter of services invoicing in foreign currency	Regulation 5 of the 2026 Regulations as amended on 22 September 2026³⁵; CGST rule 96A and LUT⁴⁶; DGFT e-BRC⁷	Razorpay, Karbon Business, Skydo (lowest estimated cost on USD 2,000 from published fees)⁸⁹¹⁰	28 October 2026³

Searches for the realisation rule still turn up two numbers, 9 months and 15 months, because both have applied within the last year. RBI raised the period for export proceeds to 15 months by Notification No. FEMA 23(R)/(7)/2025-RB dated 13 November 2025, effective on its Gazette publication on 14 November 2025.¹ It brought the period back to nine months from 5 June 2026 by Notification No. FEMA 23(R)/(8)/2026-RB.² For services, the rule in force today is nine months from the date of invoice under regulation 5 of the FEMA (Export and Import of Goods and Services) Regulations, 2026, as amended on 22 September 2026.³

This page therefore corrects the "9-vs-15" framing: there is one current rule (nine months), and the 15-month window is history that matters only for older invoices.²³ The full rule is on export realisation period. Confirm your own position with a chartered accountant (CA) or your bank.

How do the lowest-cost receiving options compare for service exporters?

The providers with the lowest estimated cost on a USD 2,000 receipt from published fees are Razorpay, Karbon Business and Skydo, and each pays INR to the exporter's Indian bank and issues a receipt record.⁸⁹¹⁰ The table is ordered by that estimate, cheapest first.

Platform	Best for	Fee	FX markup	Settlement	FIRA	RBI PA-CB status	Source
Razorpay	Local transfers from the US, UK and eurozone¹³	1% per MoneySaver bank transfer plus GST, with a flat fee of ₹1,000 below ₹1,00,000; international cards up to 3% plus GST⁸¹⁴	Razorpay says 0% FX markup on MoneySaver bank transfers; card conversion markup not published⁸¹⁵	T+1 for push bank transfers (ACH, FPS, SEPA, SWIFT); around T+5 business days for ACH debit Flash Links¹³¹⁶	Foreign Inward Remittance Statement (FIRS) emailed within 24 hours after settlement for bank transfers¹³¹⁷	Razorpay Payments Private Limited is listed as PA-CB for inward and outward transactions¹⁸	Razorpay pricing and docs; RBI list⁸¹³¹⁴¹⁵¹⁶¹⁷¹⁸
Karbon Business	US bank transfers and marketplace payouts¹⁹	1% transaction fee, listed on Karbon's PayPal alternative page⁹	0% (freelancer page); 0.5% to 1.0% (PayPal alternative page)¹⁹⁹	Karbon says 24 to 48 hours¹⁹	FIRA for every transaction from an unnamed banking partner; cost not published¹⁹	Not on the RBI list itself; its terms run export receipts under a partner the RBI lists as a PA-CB¹⁸²⁰	Karbon pages and terms; RBI list⁹¹⁸¹⁹²⁰
Skydo	Local bank transfers from major markets²¹	USD 19 plus GST up to USD 2,000; USD 29 plus GST from USD 2,001 to USD 10,000; 0.3% plus GST above USD 10,000¹⁰²²	0% markup on the mid-market rate (product page); retail rate set by Skydo or its partner banks (terms)²³²⁴	Skydo's terms say T+1 to T+3 business days, depending on currency and corridor²⁴	Free FIRA on every payment received, Skydo says²³²⁵	Skydo Technologies Private Limited is listed as PA-CB-I and O, authorised 8 January 2026¹⁸	Skydo FAQs and terms; RBI list¹⁰¹⁸²²²³²⁴²⁵

A faster settlement does not change the realisation deadline, which runs from the invoice date, but it shortens the gap between the client paying and the bank recording the export as realised.³ The platform cost comparison covers more providers.

Which RBI and GST rules apply to service exporters on realisation?

The rules that govern realisation for service exporters are regulation 5 of the 2026 Regulations (the period and extensions), regulations 6, 7 and 13 (reduction, set-off and the one-year consequence) and CGST rule 96A, which links LUT relief to the FEMA period.⁴⁵

Rule	Best for (who it applies to)	Plain meaning	Source
Regulation 9, 2015 Regulations	Invoices before 14 November 2025	Nine months¹	RBI¹
FEMA 23(R)/(7)/2025-RB, 13 November 2025	Window from 14 November 2025	Realisation period raised to 15 months¹	RBI¹
FEMA 23(R)/(8)/2026-RB	From 5 June 2026	Period restored to nine months²	RBI²
Regulation 5, 2026 Regulations, as amended 22 September 2026	All service exports from 1 October 2026	Nine months from invoice, twelve months if invoiced or settled in rupees; the AD bank can extend³⁵	RBI³⁵
Regulations 6 and 7	Exporters with short payments or dues to offset	The AD bank can allow a reduction in export value (on declaration alone up to ₹10 lakh) and set-off⁵	RBI⁵
Regulation 13	Exporters with long-overdue proceeds	After more than one year past the due date, further exports only against full advance or an irrevocable letter of credit⁵	RBI⁵
CGST rule 96A(1)(b)	GST-registered exporters under an LUT	IGST with interest due if payment is not received within one year or the FEMA period with extensions, whichever is later⁴	CBIC⁴

For example, a services invoice dated 15 November 2026 must be realised by 15 August 2027 under the nine-month rule, unless the AD bank extends the period.³ The export realisation deadline calculator works out the date for any invoice.

Which purpose code applies to service exporters?

The purpose code depends on the service exported, and the AD bank records it for each receipt under RBI A.P. (DIR Series) Circular No. 84 of 29 February 2012.²⁶ The codes below are the ones service exporters use most often.²⁷

Code	Best for (transaction type)	Official RBI description	Source
P0802	Software development and IT implementation	Software consultancy/implementation (other than those covered in SOFTEX form)	HDFC²⁷
P0807	Software exports your bank treats as off-site	Off-site Software Exports	HDFC²⁷
P1006	Management consulting and public relations	Business and management consultancy and public relations services	HDFC²⁷
P1007	Advertising and marketing services	Advertising, trade fair service	HDFC²⁷
P1009	Architecture and building design	Architectural services	HDFC²⁷
P1101	Video, animation and post-production	Audio-visual and related services like Motion picture and video tape production, distribution and projection services.	HDFC²⁷

The purpose code finder matches other services to their codes.

Which option is cheapest at $500, $2,000 and $5,000?

The cheapest option for a service exporter changes with invoice size, because flat per-payment fees fall as a share of larger invoices while percentage fees stay the same.⁸¹⁰ The table below works out INR received at today's rate from published fees.

Platform	Best for	INR on USD 2,000	INR on USD 5,000	INR on USD 10,000	Cost on USD 5,000
SkydoMost INRTransfer to Skydo local account details or international SWIFT account	Local bank transfers from major markets	₹1,86,373	₹4,67,991	₹9,39,206	0.68%
Karbon BusinessBank transfer to a Karbon virtual USD account	US bank transfers and marketplace payouts	₹1,86,262 to ₹1,86,601	₹4,65,655 to ₹4,66,503	₹9,31,311 to ₹9,33,007	1.00 to 1.18%
RazorpayMoneySaver Export Account: bank transfer to virtual account details (Standard plan)	Local transfers from the US, UK and eurozone	₹1,86,262 to ₹1,86,601	₹4,65,655 to ₹4,66,503	₹9,31,311 to ₹9,33,007	1.00 to 1.18%

Ranked by INR received on USD 5,000. Reference rate: European Central Bank data for 13 November 2026. Fees, conversion markup, GST on fees and FIRA charges as published by each provider, checked 28 October 2026. Ranges appear where a provider publishes a range or does not state its GST rate. Intermediary bank charges are excluded. See the methodology.

For example, on a $2,000 invoice Razorpay's 1% MoneySaver fee plus GST costs 1.00 to 1.18% and Skydo's USD 19 plus GST costs about 1.12%; on $5,000, Skydo's USD 29 plus GST is about 0.68%.⁸¹⁰ Karbon lists a 1% transaction fee.⁹

What documents follow each payment?

Each foreign payment to a service exporter is tracked through the EDF filed with the AD bank, the bank's inward remittance message, the self-certified e-BRC and, for registered exporters, the LUT and export invoice.⁵⁶⁷²⁸

Document	Best for	What it does	Source
EDF	Every service exporter from 1 October 2026	Declares the export to the AD bank within 30 days from the end of the invoice month; non-software exporters may file on or before the payment date⁵	RBI⁵
FIRA, e-FIRC or FIRS	Matching a receipt to its invoice	Provider or bank record of the foreign receipt¹⁷¹⁹²³	Provider pages¹⁷¹⁹²³
e-BRC	GST refunds and FTP benefits	Self-certified on DGFT from the bank's IRMs⁷¹²	DGFT⁷¹²
LUT	GST-registered exporters	FORM GST RFD-11 for each financial year, deemed accepted on ARN generation⁶²⁹	GST portal, CBIC⁶²⁹
IEC	Exporters claiming Foreign Trade Policy benefits	Necessary on the date of rendering services for availing FTP benefits¹¹	DGFT¹¹

See e-BRC on the DGFT portal and IEC for freelancers.

What changes in 2026 for service exporters?

The 2026 changes for service exporters are the end of the 15-month window, the new 2026 Regulations with the EDF, the end of SOFTEX, the PA-CB transaction cap and the new Income-tax Act.²⁵³⁰³¹³²

Nine months again: The 15-month period ended on 5 June 2026, and the 2026 Regulations keep nine months from the invoice date.²³
2026 Regulations: In force from 1 October 2026, replacing the 2015 export regulations.⁵
EDF for all services: Every exporter of services files an EDF from 1 October 2026, and Circular No. 20 supersedes the SOFTEX circulars.⁵³⁰
PA-CB cap: Each cross-border payment aggregator transaction is limited to ₹25 lakh.³¹
GST recommendation: The 57th GST Council meeting on 8 October 2026 recommended omitting condition (v) of section 2(6) of the IGST Act; this is not in force as of 28 October 2026.³³
Income tax: The Income-tax Act, 2025 applies from 1 April 2026.³²

The 2026 Regulations do not specifically address invoices raised before 1 October 2026 that are still unpaid, so ask your bank which due date it applies.⁵ See extension of export realisation period.

How did we verify this?

We checked this page against the sources below on 31 October 2026. Provider fees, conversion markups and RBI payment aggregator (PA-CB) status were checked on 28 October 2026. Rupee amounts use European Central Bank reference rates for 13 November 2026. Read our methodology or report an error.

Frequently asked questions

Is the export realisation period 9 months or 15 months in 2026?+

The export realisation period for services is nine months from the invoice date in 2026. RBI allowed 15 months from 14 November 2025, restored nine months from 5 June 2026, and the 2026 Regulations as amended on 22 September 2026 keep nine months, or twelve months for rupee invoices.¹²³

Does the 15-month rule still apply to invoices raised in early 2026?+

The rules do not say clearly how invoices raised during the 15-month window, and still unpaid, are treated after the change. An exporter with such invoices should ask its AD bank which due date it has recorded, and request an extension under regulation 5 if payment is likely to arrive late.²⁵

When does IGST become payable if my foreign client pays late?+

Under rule 96A(1)(b) of the CGST Rules, IGST with interest is payable within 15 days after one year from the invoice date, or after the period allowed under FEMA including any RBI-permitted extension, whichever is later. A bank extension of the realisation period therefore also extends the GST deadline.⁴

Can my bank extend the nine-month realisation period?+

Your AD bank can extend the realisation period for services under regulation 5 of the 2026 Regulations. Banks must publish a policy listing the documents, timelines and charges for such requests, so check your bank's website before you apply, and apply before the nine months run out.⁵

Do I need an IEC to export services and receive foreign payments?+

Paragraph 2.05(a) of the Foreign Trade Policy 2023 makes an IEC necessary for export of services on the date of rendering services only for availing benefits under the Foreign Trade Policy. Receiving payment for an export of services does not by itself call for an IEC under that paragraph.¹¹

How do I get an e-BRC for a service export payment?+

Since Trade Notice 33/2023-24 of 10 November 2023, the exporter self-certifies the e-BRC on the DGFT portal from the inward remittance messages (IRMs) its bank sends. The e-BRC links the realised payment to the export for GST refund and Foreign Trade Policy purposes.⁷¹²

What happens if an export payment stays unpaid for over a year after the due date?+

If export proceeds stay unrealised more than one year after the due date, regulation 13 of the 2026 Regulations allows further exports only against full advance payment or an irrevocable letter of credit. The AD bank can also allow a reduction in export value or a write-off in some cases.⁵

This page is general information for Indian service exporters, not tax or legal advice. Rules change and outcomes depend on your facts, so confirm with a chartered accountant before acting.

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