RBI and FEMA

How long does a service exporter have to realise export proceeds?

Author:: Editorial team, serviceexportguide.com
Verified by:: Editorial team
Published: 28 October 2026
Last modified: 30 October 2026
Reading time: 8 min read

Short answer

For services invoiced from 1 October 2026, the full invoice value must be realised within nine months of the invoice date.¹² Exports invoiced or settled in rupees get twelve months.¹² Your AD bank can extend the period if you give reasons.¹ After a year past the due date, further exports need full advance or an irrevocable letter of credit.¹

Applies to	Governed by	Deadline	Penalty	Last verified
Every exporter of services invoicing in foreign currency	FEMA (Export and Import of Goods and Services) Regulations, 2026, regulation 5, as amended on 22 September 2026¹²	Nine months from the invoice date¹²	Further exports only against full advance or an irrevocable letter of credit after one year past the due date¹	28 October 2026
Exports invoiced or settled in Indian rupees	Regulation 5, first proviso¹²	Twelve months from the invoice date¹²	Same as above¹	28 October 2026

Every Indian exporter of services has to bring the payment for that export into India within a fixed time.¹ This is a rule under the Foreign Exchange Management Act, 1999 (FEMA), set out in regulations issued by the Reserve Bank of India (RBI). It applies to a solo video editor invoicing a YouTube channel in Canada just as it does to an IT company billing a US client.

The period changed three times between November 2025 and October 2026, so older blog posts are often wrong.²³⁴ This guide covers the position as of October 2026.

What is the export realisation period from 1 October 2026?

The export realisation period for services from 1 October 2026 is nine months from the date of invoice, or twelve months if the export is invoiced or settled in Indian rupees.¹² The Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026 came into force on 1 October 2026 and replaced the 2015 export regulations.¹ Regulation 5, as amended on 22 September 2026, sets the periods below.¹²

Type of export	Period	Clock starts from	Best for
Services (including software)	Nine months	Date of invoice	Freelancers, agencies and IT firms billing in foreign currency
Goods (other than to a warehouse abroad)	Nine months	Date of shipment	Goods exporters
Goods sent to a warehouse outside India	Nine months	Date of sale from the warehouse	Exporters using overseas warehouses
Project exports	As per contract payment terms	As per contract	Project exporters
Any of the above invoiced or settled in Indian rupees	Twelve months	Same start dates as above	Exporters billing in rupees where RBI permits

Realised: includes settlement by set-off under regulation 7.¹
Target value: the full export value, or a reduced value your bank has accepted under regulation 6.¹

Note: The 2026 Regulations as first notified in January 2026 said fifteen months (eighteen months for rupee exports). The amendment dated 22 September 2026, effective 1 October 2026, changed these to nine and twelve months before the rules took effect.¹²

Who does the export realisation period apply to?

The export realisation period applies to every Indian exporter of services, from a solo freelancer to an IT company, whatever channel the client pays through.¹

Entity type	Applicable	Why	Best for
Freelancer invoicing in foreign currency	Yes	Regulation 5 sets nine months from the invoice date¹²	Short payment terms
Agency or company invoicing in rupees	Yes	Rupee exports get twelve months¹²	Clients settling in rupees where RBI permits
Exporter paid through PayPal or another platform	Yes	Money is repatriated only when it reaches the Indian bank account¹	Regular withdrawals to India
Exporter with invoices raised before 1 October 2026	Ask your bank	Regulation 20 lets banks handle older transactions that earlier needed RBI approval¹	Written confirmation from the bank

How do you get an extension of the export realisation period?

You get an extension of the export realisation period by asking your Authorised Dealer (AD) bank, which can extend it under regulation 5 if it is satisfied with your reasons.¹ The Regulations do not prescribe a form, so follow your bank's process.¹

Write to the bank branch or trade desk that handles your export receipts before the nine months end.
Give the invoice number, date and amount, and explain why payment is late, for example a client dispute, the client's insolvency, or delayed acceptance of deliverables.
Attach supporting evidence such as emails, the contract or a revised payment schedule.
Keep the bank's written approval with your export records.

Each bank must have a documented internal policy and standard operating procedure covering extensions, list its charges, and publish the main features of the procedure on its website (regulation 19).¹ See extension of export realisation period for more detail.

How did the export realisation period change in 2025 and 2026?

The export realisation period went from nine months to fifteen months and back to nine months within a year, as the table shows.²³⁴⁵

Date	Instrument	Effect	Best for
Before November 2025	2015 Regulations, regulation 9	Nine months from date of export	Checking older invoices
Notification dated 13 November 2025, effective on publication in the Official Gazette	FEMA 23(R)/(7)/2025-RB	Extended to fifteen months	Invoices raised while it applied
Notification dated 5 June 2026, effective on publication in the Official Gazette	FEMA 23(R)/(8)/2026-RB	Reduced back to nine months	Invoices raised from June 2026
1 October 2026	2026 Regulations as amended by FEMA 23(R)/(1)/2026-RB	Nine months from invoice date for services; twelve months for rupee exports	All invoices from 1 October 2026

If you have invoices raised before 1 October 2026 that are still unpaid, ask your bank which period it is applying to them. The 2026 Regulations supersede the 2015 ones "except in respect of things done or omitted to be done before such supersession", and regulation 20 gives banks the power to handle older transactions that earlier needed RBI approval.¹

What does the export realisation period mean in practice?

Three examples show the export realisation period in practice, each invoiced in foreign currency unless stated.¹

For example, a graphic designer: invoices a London agency on 15 October 2026. The money must be in India by 15 July 2027.¹
For example, a content writer: bills a US client on 1 November 2026 on 60-day terms. Payment is due by 1 January 2027, well inside the nine months, so there is nothing to do unless the client defaults.¹
For example, a consulting firm: invoices a Singapore client in rupees through an arrangement permitted by RBI. It has twelve months.¹

What happens if you miss the export realisation period?

If you miss the export realisation period and proceeds stay unrealised for more than one year after the due or extended date, regulation 13 says you can make further exports only against full advance payment or an irrevocable letter of credit.¹ Exporters already on RBI's caution list on 30 September 2026 stay under those orders until removed.¹

EDPMS: the open invoice stays outstanding in the Export Data Processing and Monitoring System (EDPMS), and your bank will follow up. See EDPMS for service exporters.
GST: export of services requires payment in convertible foreign exchange (or rupees where RBI permits), so unpaid invoices can affect zero-rating and refunds.⁶ See GST on export of services.
Records: without a realisation you will not have a FIRA or e-BRC to support the invoice. See FIRC vs FIRA vs e-BRC.
Bank charges: regulation 19 says the bank cannot levy charges or a penalty on you for a regulatory delay or violation on your part.¹

What can you do if a foreign client pays less than the invoice or never pays?

If a foreign client pays less or never pays, you can ask your bank for a reduction in the export value under regulation 6, or a set-off under regulation 7.¹

Reduction: the bank can allow a reduction if you explain the under-realisation or non-realisation and it accepts your reasons; for invoices up to ₹10 lakh (or the foreign currency equivalent), on your declaration alone.¹
Set-off: the bank can allow set-off of what a foreign client owes you against what you owe the same party or its group companies for imports, within the realisation period.¹

Which RBI rule sets the export realisation period?

Regulation 5 of the FEMA (Export and Import of Goods and Services) Regulations, 2026, as amended by FEMA 23(R)/(1)/2026-RB dated 22 September 2026, sets the export realisation period.¹²

Rule	Clause	Date	Plain meaning
FEMA 23(R)/2026-RB	Regulation 5	In force from 1 October 2026¹	Realise the full export value within the period; bank can extend
FEMA 23(R)/(1)/2026-RB	Amends regulation 5	22 September 2026²	Nine months, or twelve for rupee exports
FEMA 23(R)/2026-RB	Regulations 6 and 7	From 1 October 2026¹	Reduction and set-off
FEMA 23(R)/2026-RB	Regulation 13	From 1 October 2026¹	Advance or letter of credit after one year past due
FEMA 23(R)/2026-RB	Regulation 19	From 1 October 2026¹	Bank policy and SOP; no bank penalty on you

What are the common mistakes with the export realisation period?

The common mistakes with the export realisation period are relying on old figures, leaving money abroad and not tracking invoices by date.¹²³⁴

Quoting fifteen months: the period has been nine months for services from 1 October 2026.¹²
Leaving balances abroad: money in a foreign wallet or platform balance is not repatriated until it reaches your Indian bank account.¹
No invoice list: keep a list of every export invoice with its date and the nine-month due date, and match each receipt in your bank statement or FIRA to the invoice it pays.¹
Late follow-up: chase any invoice that is unpaid at six months, and request an extension before nine months if needed.¹
Skipping small-invoice declarations: file quarterly declarations with your bank for invoices up to ₹10 lakh if it uses that route to close EDPMS entries (regulation 4).¹
Loose records: keep contracts, invoices, receipts and bank approvals together for at least as long as your tax and GST records.

How these consequences apply depends on your facts, so confirm with a chartered accountant if you have an invoice close to or past its deadline.

How did we verify this?

We checked this page against the sources below on 30 October 2026. Read our methodology or report an error.

Frequently asked questions

When does the realisation clock start for a service export from India?+

Under the FEMA (Export and Import of Goods and Services) Regulations, 2026, the nine-month realisation period for services runs from the date of invoice.¹ For goods it runs from the date of shipment.¹ So the date you put on a service export invoice is the date that starts the clock, whatever the payment term agreed with the client.

Is the export realisation period still 15 months?+

No. The 15-month period introduced in November 2025 was reduced back to nine months for the 2015 Regulations on 5 June 2026.³⁴ The 2026 Regulations were amended to nine months on 22 September 2026, before they took effect on 1 October 2026.² Older blog posts quoting fifteen months are out of date.

Who grants an extension of the export realisation period?+

Your Authorised Dealer bank grants an extension of the export realisation period. Under regulation 5 of the 2026 Regulations, it can extend the period on your request if it is satisfied with the reasons you give.¹ The Regulations do not prescribe a form, so follow your own bank's written process.

What if a foreign client pays only part of an export invoice?+

You can ask your bank to allow a reduction in the export value under regulation 6, with reasons for the shortfall.¹ For invoices up to ₹10 lakh or the foreign currency equivalent, the bank can allow the reduction on your declaration alone.¹ Keep the client's correspondence about the short payment with your records.

Does the realisation period apply to freelancers paid through PayPal or other platforms?+

The realisation requirement in regulation 5 applies to the export of services whatever payment channel the client uses.¹ Money in a foreign wallet or platform balance is not repatriated until it reaches your Indian bank account. Avoid leaving balances in a foreign wallet for months, because the nine-month clock keeps running.

Can an Indian bank charge a penalty for a late export realisation?+

No. Regulation 19 of the 2026 Regulations says the bank cannot levy charges or a penalty on you for a regulatory delay or violation on your part.¹ Each bank must still have a documented policy covering extensions, list its charges and publish the main features of its procedure on its website.¹

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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