Stripe, PayPal or Razorpay: What FEMA and GST Rules Mean for a Startup's First Foreign Customer
- Author:
- Manoj Sharma
- Verified by:
- Editorial team
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- Last modified:
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.
| Applies to | Rules involved | Platforms compared | Last verified |
|---|---|---|---|
| Indian startups, including private limited companies and LLPs, that invoice their first customer outside India for software, SaaS or other services and collect through a payment gateway, a cross-border payment aggregator or a bank transfer. | FEMA Export and Import Regulations 2026 (Regs 3(2), 4(2), 5, 10 and 13), A.P. (DIR Series) Circular No. 20, RBI Master Direction on Payment Aggregators 2025 (paras 4 and 11), FETERS purpose codes, IGST Act s.2(6), s.13(2) and s.16, CGST Rule 96A, DGFT e-BRC guidelines | Skydo, Razorpay, Kotak Mahindra Bank, Stripe, PayPal | 6 Oct 2026 |
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.
| 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 | ₹4,71,073 | 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 | ₹4,68,722 | Razorpay pricing (checked 6 Oct 2026) |
| Kotak Mahindra Bank | Service exporters wanting a current account without inward remittance fees | No inward, FIRC, SWIFT fee on current accounts; GST on conversion | Card rate, markup not published; 1.71% below mid-market on 7 Oct 2026 | Not confirmed; no credit time published | Nil FIRC on current accounts; savings Rs 100 or nil | RBI-listed private sector bank; AD status not checked | ₹4,65,700 | Kotak Mahindra Bank pricing (checked 6 Oct 2026) |
| Stripe | Registered Indian businesses selling online to card-paying foreign customers | 4.3% intl cards; 3% Visa/Mastercard, 3.5% Amex; + 2% if converted | 2% if converted; Stripe says rate is generally mid-market | Daily INR payouts; card funds after five business days | Standard Chartered payment advice; FIRC cost not confirmed | Not confirmed | ₹4,39,058 | Stripe pricing (checked 7 Oct 2026) |
| PayPal | Card and PayPal-wallet payments from overseas PayPal buyers | 4.40% + USD 0.30 per international payment; fixed fee varies | 3.0% above PayPal's base rate on conversion | Not confirmed | Free weekly FIRA; custom Rs 100 + 18% GST each | PA-CB in-principle authorisation granted; final not confirmed | ₹4,36,056 | PayPal pricing (checked 6 Oct 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.
| Rule | Source | Clause | Plain meaning | Best for |
|---|---|---|---|---|
| Export Declaration Form (EDF) | FEMA Regulations 2026 | Reg 3(2) | Declare the full export value of services on an EDF within 30 days from the end of the month in which the invoice was raised. One EDF can cover all foreign customers in that month. | Startups raising their first foreign invoices |
| Realisation period | FEMA Regulations 2026, as amended | Reg 5(1) | Bring the full invoice value into India within nine months from the invoice date, or twelve months if invoiced or settled in INR. The AD bank may extend the period. | Startups giving customers credit terms |
| EDPMS closure for small invoices | FEMA Regulations 2026 | Reg 4(2) | For invoices up to Rs 10 lakh, the AD bank may close the EDPMS entry on the exporter's declaration, including a quarterly bulk declaration. | Early-stage startups with low-value invoices |
| Advance payments | FEMA Regulations 2026 | Reg 10(1) | Route an advance and the later export proceeds through the same AD bank, or inform both AD banks if the startup changes bank. | Startups taking annual or upfront subscription payments |
| Cross-border payment aggregator (PA-CB) | RBI Master Direction on Payment Aggregators | Para 4(i)(ii) and 11(d) | A PA-CB aggregates cross-border payments for onboarded merchants in e-commerce mode. Each inward transaction through a PA-CB is capped at Rs 25 lakh. | Startups collecting online from overseas buyers |
| Documents for EDPMS | RBI Master Direction on Payment Aggregators | Para 11(h) and 11(i) | The PA-CB must give the exporter's AD bank the documents needed to close EDPMS entries. Settlement in non-INR currencies is allowed only for exporters directly onboarded by the PA-CB. | Startups reconciling platform payouts with the bank |
| Export of services and place of supply | IGST Act s.2(6) and s.13(2) | Section 2(6); Section 13(2) | The supplier is in India, the customer and place of supply are outside India, payment is in convertible foreign exchange or permitted INR, and the two are not establishments of one entity. For most services the place of supply is the recipient's location. | Checking whether a first sale qualifies as an export |
| Zero rating under LUT | IGST Act s.16 and CGST Rule 96A | Section 16(1)(a), 16(3); Rule 96A(1)(b) | A registered person files an LUT in FORM GST RFD-11 before export and invoices without IGST. If payment is not received, IGST with interest is due within fifteen days after one year or the FEMA period, whichever is later. | GST-registered startups |
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.
| Code | Official RBI description (verbatim) | Source | Best for (transaction type) |
|---|---|---|---|
| P0807 | Off-site Software Exports | FETERS list | Software or a SaaS product built in India and delivered to a foreign customer |
| P0802 | Software consultancy/implementation (other than those covered in SOFTEX form) | FETERS list | Implementation, integration or software consulting fees |
| P0803 | Data base, data processing charges | FETERS list | Data processing, data migration or database work |
| P1006 | Business and management consultancy and public relations services | FETERS list | Non-software consulting or advisory startups |
| P0103 | Advance receipts against export contracts, which will be covered later by GR/PP/SOFTEX/SDF – other than Nepal and Bhutan | FETERS list | Upfront payments received before the service is invoiced |
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.
| Platform and invoice | Fee | FX markup | GST | INR received | Cost | Best for |
|---|---|---|---|---|---|---|
| Skydo, $500 | ₹1,802 | ₹0 | ₹324 | ₹45,305 | 4.48% | Indian freelancers and exporters receiving mid to large B2B invoices |
| Skydo, $2,000 | ₹1,802 | ₹0 | ₹324 | ₹1,87,601 | 1.12% | Indian freelancers and exporters receiving mid to large B2B invoices |
| Skydo, $5,000 | ₹2,751 | ₹0 | ₹495 | ₹4,71,073 | 0.68% | Indian freelancers and exporters receiving mid to large B2B invoices |
| Razorpay, $500 | ₹1,000 | ₹0 | ₹180 | ₹46,252 | 2.49% | Indian businesses and freelancers on Razorpay invoicing foreign clients |
| Razorpay, $2,000 | ₹1,897 | ₹0 | ₹342 | ₹1,87,489 | 1.18% | Indian businesses and freelancers on Razorpay invoicing foreign clients |
| Razorpay, $5,000 | ₹4,743 | ₹0 | ₹854 | ₹4,68,722 | 1.18% | Indian businesses and freelancers on Razorpay invoicing foreign clients |
| Kotak Mahindra Bank, $500 | ₹85 | ₹810 | ₹0 | ₹46,537 | 1.89% | Service exporters wanting a current account without inward remittance fees |
| Kotak Mahindra Bank, $2,000 | ₹261 | ₹3,240 | ₹0 | ₹1,86,227 | 1.85% | Service exporters wanting a current account without inward remittance fees |
| Kotak Mahindra Bank, $5,000 | ₹517 | ₹8,102 | ₹0 | ₹4,65,700 | 1.82% | Service exporters wanting a current account without inward remittance fees |
| Stripe, $500 | ₹2,988 | ₹0 | ₹538 | ₹43,906 | 7.43% | Registered Indian businesses selling online to card-paying foreign customers |
| Stripe, $2,000 | ₹11,953 | ₹0 | ₹2,152 | ₹1,75,623 | 7.43% | Registered Indian businesses selling online to card-paying foreign customers |
| Stripe, $5,000 | ₹29,882 | ₹0 | ₹5,379 | ₹4,39,058 | 7.43% | Registered Indian businesses selling online to card-paying foreign customers |
| PayPal, $500 | ₹2,115 | ₹1,359 | ₹381 | ₹43,576 | 8.13% | Card and PayPal-wallet payments from overseas PayPal buyers |
| PayPal, $2,000 | ₹8,376 | ₹5,441 | ₹1,508 | ₹1,74,403 | 8.08% | Card and PayPal-wallet payments from overseas PayPal buyers |
| PayPal, $5,000 | ₹20,898 | ₹13,603 | ₹3,762 | ₹4,36,056 | 8.07% | Card and PayPal-wallet payments from overseas PayPal buyers |
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.
| Document | Who issues it | When needed | Best for |
|---|---|---|---|
| Export invoice | The startup | For every sale or billing cycle; the invoice date starts the nine-month realisation period | All startups |
| LUT (FORM GST RFD-11) | The startup files it on the GST portal | Before the first export invoice of the financial year | GST-registered startups exporting without paying IGST |
| Export Declaration Form (EDF) | The startup files it with the AD bank, or STPI or SEZ for software | Within 30 days from the end of the invoice month | Startups exporting services or software from October 01, 2026 |
| FIRA or FIRC | The AD bank or payment provider that handles the receipt | After each foreign payment is credited | Proof of foreign receipt for GST, income tax and the bank |
| e-BRC | Generated by the startup on the DGFT portal from bank remittance data | When claiming export benefits or showing realisation | Startups that need a realisation record per invoice |
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.
- 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)
- 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)
- 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)
- 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)
- 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)
- RBI, A.P. (DIR Series) Circular No. 84 dated February 29, 2012, Reporting under FETERS, Paragraph 3 (checked 6 Oct 2026)
- IGST Act, 2017, Section 2 (Definitions), Section 2(6), export of services (checked 6 Oct 2026)
- IGST Act, 2017, Section 13 (Place of supply where supplier or recipient is outside India), Section 13(2) (checked 6 Oct 2026)
- IGST Act, 2017, Section 16 (Zero rated supply), Section 16(1)(a), 16(3) and 16(4) (checked 6 Oct 2026)
- CGST Rules, 2017, Rule 96A (Export under bond or Letter of Undertaking), Rule 96A(1) and (1)(b) (checked 6 Oct 2026)
- GST Portal user manual, Filing of Letter of Undertaking (FORM GST RFD-11), Filing steps (checked 6 Oct 2026)
- DGFT, Self-Certified eBRC Generation Guidelines, Version 1.0 (10 November 2023), Rules 1, 2 and 10 (checked 6 Oct 2026)
- 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)
- RBI, Guidelines to facilitate faster cross-border inward payments (April 09, 2026), Paragraphs 3 and 4 (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)
- 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)
- 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)
- 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.