Export realisation period: 9 months, not 15
From 1 October 2026, an Indian exporter of services must receive the full export value in India within 9 months of the invoice date, or 12 months if the export is invoiced or settled in rupees. Many articles still say 15 months: that figure was replaced before the new rules took effect.
Last updated 09 Oct 2026 · Not legal or tax advice
The rule
- 9 months from the invoice date to realise and repatriate the full export value of services (FEMA 23(R)/2026-RB, Reg. 5(1) as amended by FEMA 23(R)/(1)/2026-RB).
- 12 months if the export is invoiced or settled in Indian rupees, within RBI's rupee-trade framework.
- Your bank can extend it on request, with reasons (FEMA 23(R)/2026-RB, Reg. 5(1), second proviso (extension by the AD)). Ask before the deadline.
- The same rule applies whether your client pays you directly or through a platform such as Deel, Upwork or Wise.
Work out the date for any invoice with the EDF due date and payment deadline calculator.
Why some sources say 15 months
The period changed several times in a year. Under the earlier rules the clock ran from the date of export, which for software was the invoice date.
| Exports dated | Period | Rule |
|---|---|---|
| Until 13 Nov 2025 | 9 months | FEMA 23(R)/2015-RB, the earlier regulations |
| 14 Nov 2025 to 4 Jun 2026 | 15 months | FEMA 23(R)/(7)/2025-RB, a temporary relief |
| 5 Jun to 30 Sep 2026 | 9 months | FEMA 23(R)/(8)/2026-RB restored the earlier period |
| From 1 Oct 2026 | 9 months (12 in rupees) | FEMA 23(R)/2026-RB, Reg. 5(1). Published with 15 months (18 in rupees), amended to 9 (12) on 22 Sep 2026 by FEMA 23(R)/(1)/2026-RB, before it came into force |
For invoices dated in the 15-month window (14 November 2025 to 4 June 2026), how the June 2026 change applies isn't settled. easylancing reminds you at 9 months and treats 15 months as the outer limit; confirm with your bank.
If the money is late or short
- Ask for an extension before the deadline if you expect payment later.
- Fees or a short payment: record the difference and the reason. For invoices up to ₹10 lakh your bank can accept the lower amount, or close the entry, on your declaration (FEMA 23(R)/2026-RB, Reg. 6 (reduction / non-realisation)).
- No penalty from the bank for a regulatory delay: Regulation 19(3) bars the bank from charging or penalising you for it. Penalties under section 13 of FEMA are imposed only through adjudication.
- Unpaid for over a year after the deadline: under Regulation 13 your future exports must be against full advance payment or an irrevocable letter of credit. The regulation sets no end date for this; ask your bank.
GST: the one-year rule for LUT exporters
If you are GST-registered and export under a Letter of Undertaking (LUT), there is a second clock. If the payment hasn't arrived by the later of one year from the invoice date or the FEMA period (including any extension), you must pay the IGST with interest within 15 days after that (CGST Rules, Rule 96A, sub-rule (1)(b)). With the FEMA period at 9 months, that is usually one year and 15 days from the invoice date. The FEMA deadline comes first.
Questions
Is the export realisation period 9 months or 15 months?
9 months. For exports of services from 1 October 2026, the full export value must be realised and repatriated within 9 months of the invoice date (Regulation 5(1) of FEMA 23(R)/2026-RB, as amended by FEMA 23(R)/(1)/2026-RB of 22 September 2026). The regulations as first published said 15 months, but that was changed before they took effect, so articles quoting 15 months are out of date.
When does the clock start for services?
On the invoice date. The 9 months run from the date of the invoice, not from when the work was done or when the client was told.
What if I invoice in rupees?
If the export is invoiced or settled in Indian rupees, the period is 12 months (first proviso to Regulation 5(1)). Rupee invoicing to a foreign client must follow RBI's rupee-trade framework. Whether a platform's local rupee payout counts as 'settled in rupees' isn't settled, so easylancing uses 9 months unless the invoice itself is in rupees.
Can the period be extended?
Yes. Your AD bank can extend it on your request, with reasons (second proviso to Regulation 5(1)). Ask before the deadline passes.
What if less arrives because of fees, or the client doesn't pay?
Record the shortfall and the reason. For invoices up to ₹10 lakh your bank can accept the lower amount, or close the entry, on your own declaration (Regulation 6); above that it needs the bank's approval.
What happens under GST if I'm paid late?
If you export under a Letter of Undertaking (LUT) and the payment hasn't arrived by the later of one year from the invoice date or the FEMA period (including any extension), you must pay the IGST with interest within 15 days after that (CGST Rule 96A(1)(b)). With the FEMA period at 9 months, that usually means one year and 15 days from the invoice date.
What if an export stays unpaid for over a year after the deadline?
Under Regulation 13, your future exports must then be against full advance payment or an irrevocable letter of credit. The regulation sets no end date for this; ask your bank.