GST, LUT and FIRC: What Actually Has to Be on an Export Invoice from India
- Author:
- Manoj Sharma
- Verified by:
- Editorial team
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- Last modified:
Short answer
In 2026, CGST Rule 46 requires an export invoice from India to show your GSTIN, client name and address, country of destination and an export endorsement. An LUT lets the invoice carry zero IGST under IGST section 16. RBI's FEMA Regulations 2026 require payment within nine months of the invoice date. Your bank's FIRC or FIRA proves receipt.
| Applies to | Rules involved | Platforms compared | Last verified |
|---|---|---|---|
| GST-registered freelancers, agencies and companies in India that invoice clients outside India for services, in foreign currency or in Indian rupees where the RBI permits it. | CGST Rule 46, CGST Rule 47, CGST Rule 96A, IGST Act section 2(6) and section 16, and the FEMA (Export and Import of Goods and Services) Regulations, 2026, Regulations 3, 4, 5 and 18. | Skydo, Razorpay | 6 Oct 2026 |
How do payment options compare for receiving an export invoice payment from a foreign client into India?
Platforms named in the question are shown alongside the 2 highest payouts among the platforms this site covers, ranked by the INR received on a $5,000 invoice. Fees were checked on 30 Sept 2026.
| Platform | Best for | Fee | FX markup | Settlement | FIRA | RBI PA-CB status | INR on $5,000 | Source |
|---|---|---|---|---|---|---|---|---|
| Skydo | Indian freelancers and exporters receiving mid to large B2B invoices | $19 up to $2,000, $29 to $10,000, 0.3% above + GST | States zero FX margin at live rate | States under 24 hours; FAQ timelines vary by rail | States instant, free FIRA per payment | RBI authorised PA-CB Inward and Outward; on RBI list | ₹4,69,893 | Skydo pricing (checked 6 Oct 2026) |
| Razorpay | Indian businesses and freelancers on Razorpay invoicing foreign clients | 1% per bank transfer (Rs 1,000 flat below Rs 1,00,000) + GST | States 0% markup on MoneySaver at live rate | States 1 day (T+1 after invoice shared) | FIRS within 24 hours of settlement; no charge listed | RBI authorised PA-CB inward and outward, plus PA-O | ₹4,67,549 | Razorpay pricing (checked 6 Oct 2026) |
Which RBI and GST rules govern an export of services invoice from India in 2026?
Two sets of rules govern an export invoice from India. GST law decides what the invoice must show and whether IGST is charged, through CGST Rule 46 and IGST section 16. FEMA decides what happens after the invoice is raised: the FEMA Regulations, 2026 in force from 1 October 2026 set the EDF deadline, the nine-month realisation period and the bank's reporting. For example, a designer billing a US client USD 2,000 under an LUT shows zero IGST on the invoice and must receive the payment within nine months from the invoice date. See also the export invoice format guide.
| Rule | Source | Clause | Plain meaning | Best for |
|---|---|---|---|---|
| Export invoice contents | CGST Rule 46 | Clauses (a) to (q) and the proviso on export | The invoice shows your GSTIN, a serial number unique for the financial year, date, client name and address, address of delivery, country of destination, Harmonised System of Nomenclature (HSN) code for the service, value, IGST rate and amount, place of supply and the export endorsement. | Anyone drafting an export invoice template |
| Time to issue the invoice | CGST Rule 47 | Main rule | A tax invoice for services is issued within 30 days from the date the service is supplied. | Monthly retainers and milestone billing |
| Exchange rate for GST value | CGST Rule 34(2) | Sub-rule (2) | The rupee value of a foreign currency service invoice uses the exchange rate under generally accepted accounting principles for the date of time of supply. | Invoices raised in USD, EUR or GBP |
| Definition of export of services | IGST Act section 2(6) | Clauses (i) to (v) | Supplier in India, recipient outside India, place of supply outside India, payment in convertible foreign exchange or rupees where the RBI permits, and supplier and recipient are not merely establishments of a distinct person. | Checking whether a contract qualifies as an export |
| Zero-rated supply and LUT | IGST Act section 16 | Sub-sections (1) and (3) | Export of services is a zero-rated supply. Under a bond or LUT it is made without IGST, and unused input tax credit can be refunded. | Exporters who want to avoid paying IGST upfront |
| LUT condition | CGST Rule 96A(1)(b) | Sub-rule (1)(b) | The LUT in FORM GST RFD-11 is filed before export. If payment is not received within one year from the invoice date or the FEMA period with any RBI-allowed extension, whichever is later, tax with interest is due within 15 days after that, unless the Commissioner allows a further period. | Exporters with slow-paying clients |
| EDF for services | FEMA Regulations, 2026 | Regulation 3(2) | An EDF showing the full export value is filed with the AD bank within 30 days from the end of the month of the invoice. One EDF can cover all of a month's invoices. | Every service exporter from 1 October 2026 |
| Realisation period | FEMA Regulations, 2026 | Regulation 5(1)(a) and provisos | The full value is realised within nine months from the invoice date, or twelve months if invoiced or settled in rupees. The AD bank may extend the period. | Clients on long payment terms |
| EDPMS closure | FEMA Regulations, 2026 | Regulation 4(2) and first proviso | The AD bank closes the EDPMS entry after crediting the payment. Invoices up to Rs 10 lakh can be closed on the exporter's declaration. | Small and frequent invoices |
Which option costs least to receive a $500, $2,000 or $5,000 export invoice payment in India?
Each row applies the platform's published fee, FX markup and 18% GST on the fee to the XE mid-market rate for 4 Nov 2026. Platforms without full published pricing are not included.
| Platform and invoice | Fee | FX markup | GST | INR received | Cost | Best for |
|---|---|---|---|---|---|---|
| Skydo, $500 | ₹1,798 | ₹0 | ₹324 | ₹45,192 | 4.48% | Indian freelancers and exporters receiving mid to large B2B invoices |
| Skydo, $2,000 | ₹1,798 | ₹0 | ₹324 | ₹1,87,131 | 1.12% | Indian freelancers and exporters receiving mid to large B2B invoices |
| Skydo, $5,000 | ₹2,744 | ₹0 | ₹494 | ₹4,69,893 | 0.68% | Indian freelancers and exporters receiving mid to large B2B invoices |
| Razorpay, $500 | ₹1,000 | ₹0 | ₹180 | ₹46,133 | 2.49% | Indian businesses and freelancers on Razorpay invoicing foreign clients |
| Razorpay, $2,000 | ₹1,893 | ₹0 | ₹341 | ₹1,87,019 | 1.18% | Indian businesses and freelancers on Razorpay invoicing foreign clients |
| Razorpay, $5,000 | ₹4,731 | ₹0 | ₹852 | ₹4,67,549 | 1.18% | Indian businesses and freelancers on Razorpay invoicing foreign clients |
For example, on a $2,000 invoice Skydo pays about ₹1,87,131 and Razorpay about ₹1,87,019 at today's reference rate, a difference of ₹112.
What documents and GST apply to export invoice payments received from foreign clients?
Four documents surround each export invoice payment: the LUT before invoicing, the invoice itself, the EDF after invoicing, and the FIRC, FIRA or e-BRC after payment. GST is zero under an LUT, and the invoice must say so in the Rule 46 endorsement. For a GST refund of unused input tax credit, CGST Rule 89(2)(c) asks for a statement of invoices with the matching Bank Realisation Certificates or Foreign Inward Remittance Certificates. Read FIRC vs FIRA vs e-BRC for the differences.
| Document | Who issues it | When needed | Best for |
|---|---|---|---|
| LUT in FORM GST RFD-11 | The exporter files it on the GST portal (GST portal guide) | Before the first export invoice of the financial year; it is valid for the whole financial year in which it is tendered | Invoicing without IGST |
| Export tax invoice | The exporter | Within 30 days of supplying the service, with the Rule 46 export endorsement | Every foreign client |
| EDF (Export Declaration Form) | The exporter files it with the AD bank | Within 30 days from the end of the invoice month; services other than software may file on or before the date of receipt of payment | All service exports from 1 October 2026 |
| FIRC or FIRA | The AD bank that receives the payment | After the money is credited; CGST Rule 89(2)(c) names the Foreign Inward Remittance Certificate as proof for a GST refund on export of services | GST refunds and proof of export of services |
| e-BRC | DGFT, based on bank data (DGFT eBRC FAQ) | After realisation, generated on the DGFT portal against the bank's inward remittance message | Foreign trade policy benefits and audits |
| Purpose code | The AD bank, which reports a purpose code for each foreign exchange transaction under FETERS | With each inward remittance; confirm the code with your AD bank | Correct classification of the receipt as export of services |
What changed in India's export invoice and payment realisation rules in 2026?
The FEMA side changed on 1 October 2026, when the FEMA (Export and Import of Goods and Services) Regulations, 2026 came into force. A.P. (DIR Series) Circular No. 20 superseded the Master Direction on Export of Goods and Services and the circulars listed in its Annex from the same date. The CBIC texts of CGST Rule 46 and Rule 96A show no amendment after 2024.
- New regulations: The 2026 Regulations replaced the 2015 export regulations from 1 October 2026.
- Realisation: An amendment dated 22 September 2026 set the period at nine months, or twelve months for rupee invoicing, replacing the fifteen and eighteen months first notified (Regulation 5 footnotes).
- Software: The 2026 Regulations treat software as a service, so software exporters also file an EDF, with an AD bank or STPI as the specified authority. See the EDF guide.
- Small invoices: Invoices up to Rs 10 lakh can be closed in EDPMS on the exporter's declaration, including in quarterly bulk (Regulation 4(2)).
- Superseded circulars: The Annex to Circular No. 20 lists older circulars, including the one on certification of SOFTEX forms, that stopped applying on 1 October 2026.
How did we verify this?
Every rule is linked to its official source below with the date it was checked. Platform figures come from each platform's own pages; the full method is on the methodology page.
- CGST Rules, 2017: Rule 46, Tax invoice, Clauses (a) to (q); proviso on export invoices (endorsement, recipient name and address, address of delivery, country of destination); proviso on signature for electronic invoices (checked 6 Oct 2026)
- CGST Rules, 2017: Rule 47, Time limit for issuing tax invoice, Main rule, 30 days for services (checked 6 Oct 2026)
- CGST Rules, 2017: Rule 34, Rate of exchange of currency, Sub-rule (2) and footnote 1 (substituted by Notification 17/2017-CT) (checked 6 Oct 2026)
- CGST Rules, 2017: Rule 96A, Export under bond or Letter of Undertaking, Sub-rules (1)(b), (3) and (4); as substituted by Notification 12/2024-CT dated 10.07.2024 (checked 6 Oct 2026)
- CGST Rules, 2017: Rule 89, Application for refund, Sub-rule (2)(c) (checked 6 Oct 2026)
- IGST Act, 2017: Section 2, Definitions, Clause (6), export of services (checked 6 Oct 2026)
- IGST Act, 2017: Section 16, Zero rated supply, Sub-sections (1) and (3) (checked 6 Oct 2026)
- CBIC Circular No. 8/8/2017-GST: Bond/LUT for exports, Para 2(b), validity of LUT for the whole financial year (checked 6 Oct 2026)
- GST Portal user guide: Furnishing of Letter of Undertaking (FORM GST RFD-11), FAQs 1 and 2 (checked 6 Oct 2026)
- RBI: FEMA (Export and Import of Goods and Services) Regulations, 2026, Notification FEMA 23(R)/2026-RB, as amended by FEMA 23(R)/(1)/2026-RB, Regulations 1(2), 2(1)(f) and Explanation, 3(2), 4(2), 5(1), 18(2); footnotes 2 to 4 (checked 6 Oct 2026)
- RBI A.P. (DIR Series) Circular No. 20 dated 16 January 2026: Export and Import of Goods and Services, Paras 4 and 7; Annex A (checked 6 Oct 2026)
- RBI A.P. (DIR Series) Circular No. 84 dated 29 February 2012: Reporting under FETERS (purpose codes), Para 3 (checked 6 Oct 2026)
- DGFT FAQs on Self-Generation of eBRC (Version 1.0, March 2024), Q1, Q2 and Q10 (checked 6 Oct 2026)
- Skydo homepage (pricing and fee calculator), Know what you pay; calculator showing GST 18% of transaction fee (checked 6 Oct 2026)
- Razorpay MoneySaver Export Account (International Bank Transfers) pricing, Standard Plan: 0% FX markup, 1% fee, FlashLinks 2%, GST applicable, flat fee of INR 1,000 on transactions below INR 1,00,000, setup and AMC INR 0 (checked 6 Oct 2026)
Frequently asked questions
What exact endorsement goes on an export of services invoice under LUT in India?
Under CGST Rule 46, an invoice under LUT carries the words "SUPPLY MEANT FOR EXPORT/SUPPLY TO SEZ UNIT OR SEZ DEVELOPER FOR AUTHORISED OPERATIONS UNDER BOND OR LETTER OF UNDERTAKING WITHOUT PAYMENT OF INTEGRATED TAX". If you pay IGST instead, the endorsement ends "ON PAYMENT OF INTEGRATED TAX". The invoice also names the country of destination.
Does a foreign client need a GSTIN on an India export invoice in 2026?
No GSTIN is needed for a foreign client. For exports, CGST Rule 46 asks for the recipient's name and address, the address of delivery and the name of the country of destination in place of the usual State details. Your own GSTIN, name and address must still appear on the invoice.
Which exchange rate applies when a GST export invoice is raised in US dollars?
For services, CGST Rule 34(2) uses the exchange rate under generally accepted accounting principles for the date of time of supply. The older wording that pointed to the RBI reference rate was replaced in 2017. Keep the rate you used on file, and record the rupee value in your GST returns.
Is payment in Indian rupees from a foreign client still an export of services for GST?
It can be. IGST section 2(6) accepts payment in convertible foreign exchange or in Indian rupees wherever permitted by the RBI. Under FEMA Regulation 5, exports invoiced or settled in rupees have twelve months for realisation instead of nine. Confirm the rupee route with your AD bank first.
What happens to the LUT if a foreign client pays an export invoice late?
Under CGST Rule 96A(1)(b), tax with interest becomes payable if payment is not received within one year from the invoice date or the FEMA period with any RBI extension, whichever is later, plus 15 days. The Commissioner may allow a further period. Keep the client's payment record with each invoice. See the realisation period guide.
When must the EDF be filed for an export of services invoice from 1 October 2026?
Regulation 3(2) of the FEMA Regulations, 2026 requires the EDF within 30 days from the end of the month in which the invoice was raised. One EDF can cover all invoices of that month. Exporters of services other than software may submit it on or before the date of payment. The AD bank can extend the deadline.
Do I need a FIRC for every foreign inward remittance against an export invoice?
A FIRC or BRC is the proof named in CGST Rule 89(2)(c) for a GST refund on export of services, so keep one for each payment if you plan to claim a refund. Your AD bank issues it. To compare it with a FIRA, see what a FIRA is.
Is a purpose code written on the export invoice for an RBI inward remittance?
The purpose code is not an invoice field under CGST Rule 46. Your AD bank records it when the payment arrives and reports it under FETERS as Regulation 18(2) requires. Use the RBI purpose codes list to pick the right code.