How should an Indian freelancer handle recurring invoices to foreign clients?

Recurring clients are the backbone of many freelance businesses: a monthly retainer for a social media manager, a fixed fee for a bookkeeper serving a UK firm, or a standing arrangement for a developer maintaining a US client's site. The work repeats, and so does the paperwork. Getting the routine right once saves time every month and keeps your GST and bank records aligned.¹³

This guide covers the invoicing side. For how to structure retainers, prepayments and subscriptions commercially, see retainer and subscription billing for exports.

What is a recurring international invoice?

A recurring international invoice is one of a series of export invoices raised to the same foreign client on a schedule, and each one is a separate export with its own number and realisation period.¹⁵ Where the contract runs for more than three months with periodic payments, GST treats the arrangement as a continuous supply of services.²

• Continuous supply: section 2(33) of the CGST Act defines it as a supply provided continuously or on a recurrent basis under a contract for more than three months with periodic payment obligations.²
• Full invoice each time: for a GST-registered freelancer, every invoice repeats each rule 46 particular, including the client's name and address, country of destination and the export endorsement.¹
• Separate realisation: each invoice has its own realisation deadline.⁵

Update the service description each time so it names the period, for example "SEO retainer for November" rather than "monthly services". A specific description helps the bank match each payment to its invoice. See the international invoice template.

Who do the recurring invoice rules apply to?

The GST timing rules for recurring invoices apply to GST-registered suppliers, while the FEMA rules on the EDF and realisation apply to every exporter of services.¹³⁵

If you are unregistered, pick a fixed invoicing day and stick to it.

How do you run recurring international invoices?

You run recurring international invoices by fixing the invoice date, checking the LUT, numbering in sequence, and filing the month's EDF.¹²³⁴

1. Fix the invoicing day: decide whether the arrangement is a continuous supply and set the date by section 31(5) or rule 47 (table below).¹²
2. Check the LUT: the Letter of Undertaking (LUT) is furnished in FORM GST RFD-11 for each financial year, and rule 96A requires it to be in place before the export.⁴⁶
3. Number the invoice: rule 46(b) requires a consecutive serial number of up to 16 characters, using letters, numbers, hyphens or slashes, unique for the financial year.¹
4. Name the period: describe the service with the month it covers.
5. File the EDF: regulation 3(2) of the FEMA (Export and Import of Goods and Services) Regulations, 2026 sets the deadline at 30 days from the end of the month in which the invoice was raised, and allows one EDF to cover a month's exports to multiple recipients.³
6. Update the tracker: record what arrived and when (see the tracker table below).

For a continuous supply, section 31(5) of the CGST Act sets the invoice date as follows.²

For other services, rule 47 of the CGST Rules requires the invoice within 30 days from the date of supply.¹ In practice, many freelancers invoice on the first working day of each month for the month ahead (if paid in advance) or the month just ended (if paid in arrears), and write that into the contract.

A separate series for exports, such as EXP/26-27/001, makes it easier to list export invoices for returns and refund claims. Avoid reusing the same number each month with a date suffix that pushes past 16 characters, and never reuse a cancelled number.¹ If an amount changes after issue, use a credit note. See credit notes on export invoices.

What deadlines apply to recurring export invoices?

The deadlines for recurring export invoices are the GST invoice date, the LUT each April, the monthly EDF and the realisation period for each invoice.¹³⁴⁵ Each invoice has its own realisation deadline: nine months from its date for foreign-currency invoices, twelve months for rupee invoices, from 1 October 2026.⁵

A simple tracker with one row per invoice works well. The deadlines in it follow regulation 5 of the 2026 Regulations and rule 96A.⁵⁶

For a freelancer with three monthly retainers, the EDF rule can mean one EDF a month covering all three invoices. Exporters of non-software services may instead file it on or before the date payment is received.³ See EDF for service exporters.

What is the timeline for recurring export invoices each year?

The timeline for recurring export invoices runs from the LUT in April, through monthly invoices and EDFs, to each invoice's realisation date.³⁴⁵

• April: file the LUT for the new financial year before the first April invoice; with recurring clients, the April invoice is the one most often issued before the new LUT is filed.⁴ Set a reminder to file the LUT for 2027-28 before your first invoice in April 2027. See LUT renewal and validity.
• Each month: issue the invoice and file the EDF within 30 days from the end of the month of invoicing.³
• Nine months after each invoice: the realisation deadline for a foreign-currency invoice.⁵

What happens if a recurring export invoice goes wrong?

If payment for a recurring export invoice under an LUT arrives too late, rule 96A makes the integrated tax with interest payable.⁶ That applies if payment is not received within one year of the invoice date, or the period allowed under FEMA including any RBI-permitted extension if that is later (or a further period the Commissioner allows), and the tax is payable within 15 days after that.⁶

• Short or combined payments: when a client pays two months together, or pays one invoice short, record which invoice each amount settles.
• Wrong amount on an issued invoice: use a credit note rather than reissuing the number.¹

See FIRC, FIRA and e-BRC and what to do when a foreign client is not paying.

What are the common mistakes with recurring international invoices?

The common mistakes with recurring international invoices are issuing April invoices before the new LUT, reusing numbers, and vague descriptions.¹⁴

• April before the LUT: the LUT is furnished for each financial year.⁴
• Reused or overlong numbers: the serial number must be unique for the financial year and up to 16 characters.¹
• Vague descriptions: "monthly services" makes it harder for the bank to match a payment.
• Missing the export endorsement: check that invoicing software lets you add the rule 46 export endorsement and the country of destination, and that it handles the currency you bill in.¹

Invoicing software can generate a recurring invoice on a schedule, apply your numbering series and send reminders; see invoicing software for exporters. Automation does not replace the monthly checks. If your recurring arrangement includes prepayments or usage-based charges, ask a chartered accountant how to time the invoices.