If you export services from India, you have 9 months from the date of each invoice to bring the full export value into India. That is the rule in Regulation 5(1)(a) of the 2026 export Regulations; where the invoice is raised or settled in Indian rupees, the period is 12 months. If a client is slow, your AD bank can extend the period on a reasoned request — but you have to ask, ideally before the deadline passes.
Key takeaways
- The clock starts on the invoice date, not the EDF filing date and not the end of the month.
- 9 months for foreign-currency invoices; 12 months for rupee invoices or settlement.
- "Full export value" means the whole invoice amount, so short payments leave a gap to explain.
- Extensions are granted by your AD bank on a reasoned request with evidence.
- Unrealised invoices stay open in EDPMS, which can block eBRCs and complicate GST refunds.
Where the rule comes from
The Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026 came into force on 1 October 2026. Regulation 5(1)(a) sets the period within which the full export value must be realised and repatriated. For services, that period is nine months from the date of the invoice. Where the invoice is in Indian rupees, or settlement happens in rupees, it is twelve months.
You also commit to this in writing. Part 4 of the EDF asks you to state the date by which full value will be received. That date should sit inside the 9-month window for each invoice.
Counting the 9 months: worked dates
Count calendar months from the invoice date. Here is how it looks for a fictional exporter, Tarang Analytics Pvt Ltd, invoicing through autumn 2026:
| Invoice no. | Invoice date | Currency | Amount | Realise by |
|---|---|---|---|---|
| TA/026 | 02-Oct-2026 | USD | 9,500 | 02-Jul-2027 |
| TA/027 | 19-Oct-2026 | GBP | 4,000 | 19-Jul-2027 |
| TA/028 | 30-Nov-2026 | USD | 12,000 | 30-Aug-2027 |
| TA/029 | 14-Dec-2026 | INR | ₹6,80,000 | 14-Dec-2027 (12 months) |
Notice that TA/026 and TA/027 are on the same October EDF, but they have different realisation deadlines. Track each invoice on its own line. A single "realise by" date for the whole month only works if you pick the earliest.
Where a date doesn't exist in the target month (an invoice dated 31 May, say, nine months later lands in February), take a conservative view and use the last day of that month or earlier. Ask your bank if you are cutting it close.
What "realised" means in practice
Realisation happens when the money is credited to your account in India in respect of that invoice and the bank can match it. A few practical consequences:
- Bank charges abroad. If USD 9,500 is invoiced and USD 9,470 lands because an intermediary bank took USD 30, the invoice is not fully realised on paper. Banks deal with such small differences in their own way; ask yours how it wants them treated, and look at whether your NRV in Part 2B already reflected expected deductions.
- Partial payments. If a client pays in instalments, the invoice is realised only when the last instalment arrives.
- Payment platforms. If your client pays through a platform, the date the money reaches your Indian bank is what matters, not the date the client clicked "pay".
When the client is late
Nothing in the rule punishes a slow client; it asks you to manage them. A sensible timeline for a USD invoice dated 1 March 2027 (deadline 1 December 2027):
| Month after invoice | Action |
|---|---|
| Month 1–2 | Normal reminders under your payment terms |
| Month 3–4 | Escalate to the client's finance contact; get a written payment date |
| Month 5–6 | Formal demand; note the dispute or delay in your records |
| Month 7 | If payment is not certain, prepare an extension request with evidence |
| Month 8 | Submit the extension request to your AD bank |
| Month 9 | Deadline; the request should already be with the bank |
Our realisation extension request letter gives you a ready format. Explain why the money is late, attach correspondence showing you are chasing it and give a realistic new date. The bank decides; there is no automatic extension.
For a detailed playbook on slow payers, see protecting your 9-month window when a client pays late.
What happens if you miss it
Missing the deadline does not turn into a fine overnight, but it leaves loose ends:
- The invoice stays open in EDPMS, so your bank keeps seeing an unrealised export against your name.
- An eBRC cannot be generated until realisation is matched, which can hold up GST refunds where you exported with IGST paid.
- Your bank may ask more questions about new transactions until old entries are cleared.
- Persistent non-compliance can expose you to proceedings under FEMA, including Section 13 penalties.
If a client will never pay, speak to your bank and CA about write-off. That is a separate process with its own conditions, and our guide to bad debts on exports explains the options.
Rupee invoices and the 12-month window
Some exporters invoice foreign clients in Indian rupees, for example through special rupee vostro arrangements. For these, Regulation 5(1)(a) gives 12 months instead of 9. Don't assume the longer window applies just because you converted the amount to rupees in your books — it applies where the invoice is raised or settled in INR. If you are unsure which applies, ask your bank.
This is general information, not legal or tax advice. Your bank's reading of a specific case takes priority.
Making the 9 months easy to manage
Three habits make realisation tracking almost automatic:
- Add a "realise by" column to your invoice register and fill it the day you raise the invoice.
- Close entries as money arrives. For invoices up to ₹10 lakh, your bank may close them on a periodic declaration, which our ₹10 lakh realisation declaration tool prepares.
- Review open invoices monthly when you prepare the EDF. Anything past month 6 deserves a phone call, not just an email.
Frequently asked questions
When does the 9-month realisation period start for services?
It starts on the date of the invoice. It does not start from the EDF filing date or from the end of the month. Each invoice on a monthly EDF can therefore have a different deadline.
Is the realisation period different for invoices in rupees?
Yes. Where the invoice is raised or settled in Indian rupees, the period is 12 months from the invoice date under Regulation 5(1)(a). Foreign-currency invoices have 9 months.
Can I get more than 9 months if my client is slow to pay?
Your AD bank can extend the period on a reasoned request. Submit the request before the deadline with evidence that you are pursuing payment and a realistic expected date. Extensions are at the bank's discretion.
Does a small shortfall due to bank charges count as non-realisation?
Technically the full value has not arrived, but banks handle small charge-related differences in their own way. Ask your bank how it treats them, and consider whether your declared NRV should reflect deductions you knew about in advance.
What happens to my EDPMS entry if the client never pays?
It stays open until it is realised, extended, written off or otherwise closed by the bank under the rules. Talk to your bank and CA early rather than letting the entry age.
Bottom line
The 9-month rule is simple to state and easy to miss: every invoice carries its own clock from its own date. Put the realise-by date in your register, chase early and ask for an extension before month nine. Our free EDF due date calculator shows filing dates alongside, so both clocks stay in view.
This guide is general information for Indian businesses, not legal or tax advice. Rules and bank processes change — confirm specifics with your AD bank or chartered accountant.