Stripe, Razorpay or a Merchant of Record: What OPGSP and GST Rules Mean for SaaS Companies Getting Paid

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.

• A merchant of record: A merchant of record sells the subscription to the end customer in its own name and then pays the SaaS company, so the SaaS company usually supplies the merchant of record rather than the end customer. Check that supply against the five conditions in IGST Act section 2(6) and confirm the GST and FEMA treatment with your adviser and AD bank. See merchant of record platforms.

Four sets of rules apply to Indian SaaS companies receiving international payments: the FEMA export regulations of 2026, RBI's Master Direction on payment aggregators, the IGST Act's export and zero-rating sections, and CGST Rule 96A on the LUT. The OPGSP circulars that many guides still quote were repealed in September 2025, except for an existing PA-CB that applied by 30 April 2024 and still awaits RBI's decision.

The purpose code for Indian SaaS companies usually comes from Group 08, Telecommunication, Computer & Information Services, of RBI's FETERS purpose code list. The right code depends on what the customer pays for, so confirm it with your AD bank. See purpose code for SaaS.

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 ₹1,87,131 and Stripe about ₹1,75,184 at today's reference rate, a difference of ₹11,948.

Each SaaS payment from abroad needs an EDF filed within the FEMA deadline, a valid LUT if you bill without IGST, a bank record of the inward remittance, and an e-BRC generated on the DGFT portal when you need proof of realisation. The payment route changes who supplies the records, but these duties stay with the SaaS company.

The main 2026 change for Indian SaaS companies is that the FEMA export regulations of 2026 came into force on 1 October 2026, and RBI Circular No. 20 superseded the earlier Master Direction and SOFTEX circulars from the same date. The realisation period was also shortened before the start date, and a new Income-tax Act applies from 1 April 2026.

• New regulations: The FEMA (Export and Import of Goods and Services) Regulations, 2026 came into force from 1 October 2026 and superseded the 2015 export regulations.
• SOFTEX replaced: A.P. (DIR Series) Circular No. 20 supersedes the Master Direction on export and the listed SOFTEX circulars, so software exports are now declared on the EDF. See SOFTEX form filing.
• Shorter period: The amendment of 22 September 2026 changed the realisation period from fifteen to nine months, and from eighteen to twelve months for rupee invoices (Regulation 5, footnotes). See export realisation period.
• OPGSP gone: The Master Direction on Payment Aggregators of 15 September 2025 repealed the OPGSP circulars, with a saving for pending PA-CB applicants. See PA-CB vs OPGSP.
• Income-tax Act: The Income-tax Act, 1961 stands repealed on 1 April 2026 and the Income Tax Act, 2025 applies from that date, while matters for tax years before 1 April 2026 are not disturbed (Income Tax Department FAQ).

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. Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026, Notification FEMA 23(R)/2026-RB, amended up to 22 September 2026, Regulations 1(2), 3(2), 4(2), 5(1)(a) and proviso with footnotes 2 to 4, 18(2) (checked 6 Oct 2026)
2. RBI A.P. (DIR Series) Circular No. 20 (RBI/2025-26/194): Export and Import of Goods and Services, 16 January 2026, Paragraph 4 and Annex (superseded Master Direction and SOFTEX circulars) (checked 6 Oct 2026)
3. RBI Master Direction on Regulation of Payment Aggregator (PA), RBI/DPSS/2025-26/141, 15 September 2025, Paragraph 4(i)(ii) Note 2; paragraphs 11(d), 11(h), 11(i); paragraph 19 (checked 6 Oct 2026)
4. IGST Act, 2017, Section 2: Definitions (CBIC tax information portal), Section 2(6), export of services (checked 6 Oct 2026)
5. IGST Act, 2017, Section 16: Zero rated supply (CBIC tax information portal), Section 16(1)(a), 16(2) and 16(3) (checked 6 Oct 2026)
6. CGST Rules, 2017, Rule 96A: Export of goods or services under bond or Letter of Undertaking (CBIC tax information portal), Rule 96A(1) and (1)(b) (checked 6 Oct 2026)
7. RBI FETERS purpose code list for receipts (Annex to A.P. (DIR Series) Circular No. 84, 29 February 2012), Receipts, Group 08 Telecommunication, Computer & Information Services: P0802, P0807 (checked 6 Oct 2026)
8. DGFT: Electronic Bank Realisation Certificate (eBRC), Self-certification of eBRC from bank IRMs; Trade Notice 33/2023-24 dated 10 November 2023 (checked 6 Oct 2026)
9. Income Tax Department e-filing portal: Objective and scope of the New Act (FAQs), FAQs 1, 2 and repeal of the 1961 Act on 01.04.2026 (checked 6 Oct 2026)
10. Skydo homepage (pricing and fee calculator), Know what you pay; calculator showing GST 18% of transaction fee (checked 6 Oct 2026)
11. 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)
12. 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)
13. 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)