How must an Indian service exporter realise export proceeds — time limits, e-BRC/FIRA, purpose codes and the EDF that replaced SOFTEX?

Key facts

What changed on 1 October 2026

The RBI replaced the 2015 export and import regulations with a single consolidated set of Export and Import of Goods and Services Regulations, 2026, together with revised directions to banks. For service exporters the practical changes are:

• Realisation period. The 2026 regulations as originally notified in January had extended the period to fifteen months; the September 2026 amendment restored the standard period to nine months from the invoice date before the regulations took effect, and introduced twelve months for exports invoiced and settled in Indian rupees. The nine-month rule therefore continues without interruption from the old regime.
• One declaration for all services. SOFTEX, which applied only to software exports and ran through STPI or SEZ authorities, is discontinued for invoices raised from October 2026. In its place every service exporter — software, ITeS, consulting, design, freelancers — files a monthly Export Declaration Form with its bank, listing all export invoices of the month, within 30 days of the month end. SOFTEX continues for invoices issued up to 30 September 2026.
• Bank-centred monitoring. The EDF entries are matched against inward remittances in the bank's reporting system; unrealised entries beyond the period are flagged, and persistent defaults lead to caution-listing of the exporter, which blocks further export facilities until regularised.

The realisation clock

The period runs from the date of the invoice. Credit terms longer than nine months are therefore not permitted without prior extension. Where a receivable is genuinely delayed, the exporter applies to its bank for an extension before the period expires, with reasons; banks have delegated authority to extend within limits, beyond which the matter goes to the RBI. Part payments reduce the outstanding; bank charges deducted abroad are generally accepted as a reduction. Where the balance is uncollectable, the regulations allow write-off within prescribed limits (a small percentage self-write-off, a larger percentage with the bank's approval, subject to conditions such as the GST refund position and no pending investigation), beyond which RBI approval is needed.

FIRA, e-BRC and purpose codes

Each inward remittance is credited by the bank against a purpose code declared by the exporter — for example P0802 (software consultancy and implementation), P0807 (off-site software services), P0803 (data processing), P1006 (business and management consultancy) or P1007 (advertising and market research). The code should describe the service in the agreement and match the GST SAC and the transfer pricing description; reimbursements use a different code from service income. The bank issues a Foreign Inward Remittance Advice (FIRA) — the successor to the FIRC — for each credit, and the electronic e-BRC is generated on the DGFT platform once the remittance is matched to the export entry. These documents are the evidence for the GST refund under Rule 89(4), the GST Rule 96A condition, and the income-tax record of export turnover.

Monthly workflow for a service exporter

1. Raise export invoices within 30 days of the service period (GST section 31), with the correct description and currency.
2. By the 30th of the following month, file the EDF for the month's invoices with the bank.
3. On each receipt, give the bank the purpose code and invoice references; collect the FIRA; download the e-BRC once generated.
4. Monthly, age the receivables from invoice date against the nine-month (or twelve-month) clock; apply for extension before expiry where needed.
5. Quarterly, reconcile EDF entries, FIRAs and the GST export turnover for the refund application.

Interaction with GST and transfer pricing

GST's Rule 96A gives one year from the invoice date for receipt of export proceeds before IGST becomes payable with interest; FEMA's nine months bites first. For transfer pricing, receivables from the parent outstanding beyond normal credit terms are an international transaction on which arm's length interest is imputed — so a parent that pays at eight months is FEMA-compliant but creates a transfer pricing adjustment. Thirty to sixty-day terms solve all three.

Worked example

An Indian design studio invoices a US client USD 60,000 on 15 October 2026 and a Dutch client EUR 25,000 on 28 October 2026.

• EDF: one declaration for October filed with the bank by 29 November 2026, listing both invoices (no SOFTEX, even though some deliverables are software).
• Realisation deadline: 14 July 2027 and 27 July 2027 respectively (nine months from invoice date).
• Receipts: USD 59,960 received 2 December 2026 (bank charges USD 40 deducted abroad) — purpose code P1007 (advertising/market research) if the work is design for marketing, or P0802 if software implementation; FIRA issued; e-BRC generated. EUR 25,000 received 10 January 2027.
• GST: both invoices zero-rated under LUT; refund for the October–December quarter uses the USD receipt; the EUR receipt falls in the next quarter's claim.

Had the US client not paid by July 2027, the studio would apply to its bank for an extension in June, citing the client's payment schedule, and would note the one-year GST deadline of 14 October 2027 for Rule 96A.

Common mistakes we see

• Continuing to file SOFTEX for invoices raised after 30 September 2026, or filing no declaration at all because 'we are not a software company'.
• Agreeing payment terms with the parent of 120 or 180 days, which leave little margin before the nine-month FEMA limit and create interest imputation for transfer pricing.
• Using a generic purpose code for everything, so the bank's data does not match the GST SAC or the agreement.
• Not collecting FIRAs at the time of receipt and reconstructing them a year later for the GST refund.
• Letting unrealised invoices age past nine months without applying for extension, leading to caution-listing.

Frequently asked questions

Sources

Primary sources only. Statutory text is read from the official publication; where a provision has been renumbered, the pre-2026 reference is given alongside so older material can be reconciled.

• FEMA notifications — Reserve Bank of India
• RBI Master Directions — Reporting under FEMA; External Commercial Borrowings; Overseas Investment; Export of Goods and Services; LRS
• e-Gazette of India — Finance Act, 2026; Income-tax Rules, 2026; FEMA notifications
• CGST Act, IGST Act, CGST Rules and GST circulars — CBIC

Last reviewed on 1 November 2026 by Vidushi Jhunjhunwala, FCA, VMS Jhunjhunwala & Co. Law stated as at that date; the Income-tax Act, 2025 and Income-tax Rules, 2026 apply from 1 April 2026.

Related reading

• When does a service by an Indian subsidiary to its foreign parent qualify as an export of services under GST?
• Who must file a Letter of Undertaking (LUT) in Form GST RFD-11, when, and what happens if it is not filed?
• How is the refund of unutilised input tax credit on zero-rated exports of services computed and claimed under Rule 89?
• What should an intercompany services agreement for software development and IT support contain? A clause-by-clause checklist
• All revenue-account remittances pages in the hub
• Cross-Border Tax & Transfer Pricing — what the firm does