Export Services India

Stripe, PayPal or Razorpay: What FEMA and GST Rules Mean for a Startup's First Foreign Customer

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Short answer

A startup paid by a first foreign customer via Stripe, PayPal or Razorpay in 2026 follows the RBI's FEMA export regulations. It files an EDF within 30 days of the invoice month end and realises the payment within nine months. Each receipt carries a purpose code and usually a FIRA or FIRC. GST zero rates the export under an LUT.

How do Stripe, PayPal and Razorpay compare for a startup's first foreign customer?

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.

Which RBI and GST rules apply to startups receiving payment from a first foreign customer?

A startup's first foreign invoice is an export of services under FEMA and, when the five conditions are met, under GST. From October 01, 2026 the FEMA (Export and Import of Goods and Services) Regulations, 2026 set the EDF, realisation and EDPMS rules, and the RBI Master Direction on Payment Aggregators governs platforms that collect cross-border payments for merchants. For GST, IGST section 2(6) defines export of services and section 16 makes it a zero rated supply. These rules apply whichever gateway, aggregator or bank collects the money.

Which purpose code applies to startups receiving payment from a first foreign customer?

A technology startup selling software or SaaS usually looks at P0807 or P0802 in group 08 of the FETERS list, and a consulting startup may fall under P1006. The code follows what the startup sold, whichever platform collects it. DGFT's e-BRC guidelines allow only P0802, P0803, P0807 and P0103 for IT services, so confirm the code with your AD bank or platform before the first receipt.

Which option costs a startup least on $500, $2,000 and $5,000 from a first foreign customer?

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.

For example, on a $2,000 invoice Skydo pays about ₹1,87,601 and PayPal about ₹1,74,403 at today's reference rate, a difference of ₹13,198.

What documents follow each payment from a startup's first foreign customer (FIRA, e-BRC, EDF, LUT)?

Each foreign payment to a startup is backed by an export invoice, a FIRA or FIRC, an EDF and, for GST, an LUT filed before the export. From October 01, 2026 the EDF under Regulation 3(2) also covers software, because Circular No. 20 superseded the SOFTEX circulars. An e-BRC can be self-generated on DGFT from bank remittance data under the e-BRC guidelines.

What changes in 2026 for startups receiving payment from a first foreign customer?

In 2026 a startup's first foreign sale falls under new FEMA export regulations, a nine-month realisation period and a new income tax law. The FEMA Regulations 2026 took effect on October 01, 2026, and the September 2026 amendment, in force from the same date, set the realisation period at nine months. The GST rules on LUT and zero rating continue to apply.

  • New regulations: The FEMA (Export and Import of Goods and Services) Regulations, 2026 apply from October 01, 2026, and Circular No. 20 superseded the export Master Direction and SOFTEX circulars from the same date.
  • Nine months: The amendment notification FEMA 23(R)/(1)/2026-RB replaced the fifteen months first notified in the 2026 Regulations with nine months for realisation, and eighteen with twelve months for INR invoices, from October 01, 2026.
  • Aggregator rules: Since September 15, 2025 the Master Direction on Payment Aggregators has repealed the earlier online payment gateway export circulars, with a saving for PA-CB applicants that applied by April 30, 2024 and await a decision.
  • Income tax: The Income-tax Act, 1961 stands repealed on April 01, 2026 and the Income-tax Act, 2025 applies, with income from FY 2026-27 called Tax Year 2026-27 (Income Tax Department FAQ).
  • Faster credit: RBI asked banks in April 2026 to endeavour to credit inward payments received in forex market hours on the same business day, effective six months from the April 09, 2026 circular.

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.

  1. RBI, Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026 (FEMA 23(R)/2026-RB, amended up to September 22, 2026), Regulations 1(2), 2(1)(f), 3(2), 4(2), 5(1), 10(1) and 13 (checked 6 Oct 2026)
  2. RBI, FEMA (Export and Import of Goods and Services) (Amendment) Regulations, 2026 (FEMA 23(R)/(1)/2026-RB), Nine and twelve months in Regulation 5(1) (checked 6 Oct 2026)
  3. RBI, A.P. (DIR Series) Circular No. 20 dated January 16, 2026, Export and Import of Goods and Services, Paragraphs 4 and 7 and Annex (SOFTEX circulars superseded) (checked 6 Oct 2026)
  4. RBI, Master Direction on Regulation of Payment Aggregator (PA), RBI/DPSS/2025-26/141, September 15, 2025, Paragraph 4(i)(ii) and Notes; paragraphs 11(d), 11(h), 11(i); paragraph 19 (checked 6 Oct 2026)
  5. RBI, Purpose codes for reporting under FETERS (Annex to A.P. (DIR Series) Circular No. 84, 2012), Receipts: P0103, P0802, P0803, P0807, P1006 (checked 6 Oct 2026)
  6. RBI, A.P. (DIR Series) Circular No. 84 dated February 29, 2012, Reporting under FETERS, Paragraph 3 (checked 6 Oct 2026)
  7. IGST Act, 2017, Section 2 (Definitions), Section 2(6), export of services (checked 6 Oct 2026)
  8. IGST Act, 2017, Section 13 (Place of supply where supplier or recipient is outside India), Section 13(2) (checked 6 Oct 2026)
  9. IGST Act, 2017, Section 16 (Zero rated supply), Section 16(1)(a), 16(3) and 16(4) (checked 6 Oct 2026)
  10. CGST Rules, 2017, Rule 96A (Export under bond or Letter of Undertaking), Rule 96A(1) and (1)(b) (checked 6 Oct 2026)
  11. GST Portal user manual, Filing of Letter of Undertaking (FORM GST RFD-11), Filing steps (checked 6 Oct 2026)
  12. DGFT, Self-Certified eBRC Generation Guidelines, Version 1.0 (10 November 2023), Rules 1, 2 and 10 (checked 6 Oct 2026)
  13. Income Tax Department, Objective and scope of the New Act (Income-tax Act, 2025 FAQs), FAQ 2 (repeal on 01.04.2026) and FAQ 9 (Tax Year) (checked 6 Oct 2026)
  14. RBI, Guidelines to facilitate faster cross-border inward payments (April 09, 2026), Paragraphs 3 and 4 (checked 6 Oct 2026)
  15. Skydo homepage (pricing and fee calculator), Know what you pay; calculator showing GST 18% of transaction fee (checked 6 Oct 2026)
  16. 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)
  17. Kotak Everyday Savings Account fees and charges, Foreign Inward Remittance certificate (Branch Request) INR 100/Request; GST on Foreign Currency Conversion; fees exclusive of GST (checked 6 Oct 2026)
  18. Stripe India pricing, International cards with USD/other currency presentment 4.3% + 2% if currency conversion is required; Mastercard and Visa cards issued outside India 3% + 2%; American Express outside India 3.5% + 2%; dispute received INR 1,000.00 (checked 7 Oct 2026)
  19. PayPal India Merchant Fees, Receiving international transactions; Currency Conversions (3.0% converting balance and payments received; 4.00% all other cases); Withdrawals Out of PayPal; Dispute Fees; Other Fees (Last Updated 28 March 2024) (checked 6 Oct 2026)

Frequently asked questions

Does a startup need an RBI-authorised PA-CB to accept international payments through Stripe, PayPal or Razorpay in 2026?

PA-CB authorisation is a requirement on the provider. The RBI Master Direction defines a PA-CB as an entity that aggregates cross-border payments for onboarded merchants in e-commerce mode. A card transaction settled by a card network, where the aggregator receives local currency, is outside PA-CB activity. A startup can check each provider's status as explained in checking RBI authorisation.

Is a FIRC or FIRA needed for a startup's export of services paid through Stripe, PayPal or Razorpay for GST LUT purposes?

IGST section 2(6) treats a supply as an export only when payment is received in convertible foreign exchange or permitted INR. The FIRA or FIRC from the bank or provider that credits INR is the usual record of that receipt. Under Rule 96A, IGST with interest becomes payable if the payment is not received in time.

Does a startup need GST registration and an LUT before its first foreign invoice in 2026?

An LUT can only be filed by a registered person, and Rule 96A requires it before the export. It is filed in FORM GST RFD-11 through Services, User Services on the GST portal. Without an LUT or bond, IGST is charged, and section 16(4) covers refund of IGST paid. Check registration thresholds with a GST adviser.

Which RBI purpose code does a SaaS startup use for Stripe or PayPal export receipts, P0807 or P0802?

The FETERS list describes P0807 as "Off-site Software Exports", which fits subscriptions to software built in India. P0802 covers software consultancy and implementation. A startup selling both can invoice them separately. See purpose codes for software exports and confirm the code with the AD bank before the first receipt.

What is the Rs 25 lakh PA-CB limit for a startup's export payments through a payment aggregator?

Paragraph 11(d) of the Master Direction on Payment Aggregators caps each inward or outward transaction processed by a PA-CB at Rs 25 lakh. A single payment above that amount cannot go through a PA-CB, so a startup should check other routes, such as a direct transfer to its AD bank. See PA-CB transaction limits for how the limit works.

What is the FEMA export realisation period for a startup's first foreign invoice in 2026?

The period is nine months from the invoice date, or twelve months for INR invoices, under Regulation 5(1). The September 2026 amendment replaced the fifteen and eighteen months first notified in the 2026 Regulations. The AD bank may extend the period on reasons given. See the export realisation period guide for extensions.

Can a startup keep its first foreign customer's payment in USD when collected through a PA-CB in 2026?

Paragraph 11(i) of the RBI Master Direction allows settlement in non-INR currencies only to Indian exporters directly onboarded by the PA-CB facilitating inward transactions. Other exporters receive INR settlement. A startup that wants foreign currency should ask its provider how it is onboarded and confirm options with its AD bank.

Does a software startup file SOFTEX or an EDF for its first foreign customer in 2026?

From October 01, 2026 the startup files an EDF, because Circular No. 20 superseded the SOFTEX circulars. Under Regulation 3(2) the EDF is due within 30 days from the end of the invoice month and is filed with the AD bank, STPI or SEZ. See EDF form filing.