What Is the Annual Compliance Calendar for Indian Exporters?
- Author:
- Manoj Sharma
- Verified by:
- Editorial team
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Short answer
The export compliance calendar for Indian exporters has monthly, quarterly, annual and per-invoice deadlines. Monthly items are GST returns and the services EDF. Annual items are the LUT, the IEC update between April and June, advance tax and the income tax return. Each export invoice must be realised within nine months under FEMA.
| Applies to | Governed by | Deadline | Penalty | Last verified |
|---|---|---|---|---|
| Indian exporters of services and goods, including freelancers, who receive payment from abroad, are registered under GST or hold an IEC | FEMA (Export and Import of Goods and Services) Regulations, 2026; CGST Act and Rules, 2017; Foreign Trade Policy 2023; Income-tax Act, 2025 (and the 1961 Act for AY 2026-27) | Rolling: monthly GST returns, EDF within 30 days of the end of the invoice month, realisation within 9 months of invoice, LUT before the first export of each financial year | FEMA penalty up to three times the sum involved; GST late fee and interest; income tax late filing fee and interest | 8 Oct 2026 |
What is an export compliance calendar for Indian exporters?
An export compliance calendar is a list of the dates by which an Indian exporter must file a form, pay a tax or complete a step with a bank or government portal. The dates come from four sources: RBI's FEMA export rules, GST law, the Foreign Trade Policy and income tax law.
- FEMA: Your AD bank tracks each export in EDPMS. Rules on declaring exports (EDF) and realising payment come from the FEMA (Export and Import of Goods and Services) Regulations, 2026, in force from 1 October 2026.
- GST: Return dates come from the CGST Rules, 2017: Rule 59 and Rule 61 for monthly or quarterly returns, Rule 80 for the annual return and Rule 96A for the yearly LUT.
- Foreign trade: An IEC holder must update or confirm IEC details online every year between April and June under Foreign Trade Policy 2023, para 2.05(d).
- Income tax: Advance tax, return filing and audit dates. The Income-tax Act, 2025 replaced the 1961 Act from 1 April 2026, but returns for AY 2026-27 still follow the old Act.
- Per invoice: Some deadlines run from each invoice date, not the calendar month, such as the nine-month realisation period and the GST payment window under an LUT.
Most exporters need two views of the calendar: a fixed list of monthly and yearly dates, and a running tracker of each unpaid invoice.
Which Indian exporters need to follow an export compliance calendar?
Every Indian exporter who receives foreign payment through a bank must meet the FEMA dates, because the rules apply to all exports of goods and services. GST dates apply only if you are registered under GST, and IEC dates apply only if you hold an IEC.
| Exporter type | FEMA dates | GST dates | IEC update | Best for |
|---|---|---|---|---|
| Freelancer exporting services, not GST-registered | Yes: EDF and realisation | No | Only if an IEC is held | Individual consultants, designers and developers below the GST threshold |
| Freelancer or agency exporting services, GST-registered | Yes | Yes: LUT, GSTR-1, GSTR-3B, GSTR-9 | Only if an IEC is held | LUT filers invoicing without IGST |
| Software exporter | Yes: EDF replaces the SOFTEX form from 1 October 2026 | Yes, if registered | Only if an IEC is held | IT and SaaS businesses that earlier filed SOFTEX |
| Goods exporter | Yes: EDF is part of the shipping bill at EDI ports | Yes, if registered | Yes: IEC is mandatory for goods unless exempted | Manufacturers, traders and e-commerce sellers |
| Company or LLP exporter | Yes | Yes | If an IEC is held | Firms with audited accounts and later income tax dates |
How do Indian exporters build an export compliance calendar for the year?
Indian exporters build the calendar by first adding fixed annual dates, then monthly return dates, then a tracker for each export invoice. The steps below follow the order in which the dates fall in a financial year that starts on 1 April.
- Before the first export of the financial year, file the LUT in Form GST RFD-11 if you export without paying IGST. The LUT is valid for the whole financial year in which it is tendered.
- Between April and June, update or confirm your IEC details on the DGFT portal, even if nothing has changed (FTP para 2.05(d)).
- Each month, file GSTR-1 by the 11th and GSTR-3B by the 20th of the next month, or follow the quarterly dates if you opted for quarterly filing.
- For every services invoice, submit the EDF to your AD bank within 30 days from the end of the invoice month (Regulation 3(2)).
- For every invoice, note the date nine months later as the realisation deadline, and ask your AD bank for an extension before it passes if payment is delayed.
- Pay advance tax by each instalment date, starting 15 June, or by 15 March if you use presumptive taxation.
- File the income tax return and, where needed, the tax audit report by the due date. For AY 2026-27, Form 67 for foreign tax credit is filed on or before the return due date.
- If you are required to file a GST annual return, file GSTR-9 by 31 December after the financial year ends (Rule 80(1)).
Which export compliance dates fall every month for a GST-registered exporter?
A monthly GST filer has two fixed return dates and one rolling FEMA date every month.
- GSTR-1 (outward supplies, including export invoices): 11th of the next month, per the GST portal FAQ on GSTR-1.
- GSTR-3B (summary return and tax payment): 20th of the next month under Rule 61(1)(i).
- EDF for services: within 30 days from the end of the month in which the invoice was raised, under Regulation 3(2). One EDF may cover all services exported in that month.
Which export compliance dates fall every quarter for an exporter in the QRMP scheme?
A quarterly GST filer uses different dates for the first two months and for the quarter end.
- Invoice Furnishing Facility (IFF), optional, for the first two months: from the 1st to the 13th of the next month under Rule 59(2).
- Tax for the first two months of the quarter: by the 25th of the next month in Form GST PMT-06 under Rule 61(3).
- GSTR-1 for the quarter: 13th of the month after the quarter ends (GST portal FAQ).
- GSTR-3B for the quarter: 22nd or 24th of the month after the quarter ends, depending on your State (Rule 61(1)(ii)).
- EDPMS: for invoices up to Rs 10 lakh, you may give your AD bank a quarterly declaration for bulk closure of EDPMS entries (Regulation 4(2)). No fixed date is set in the regulation, so ask your bank for its cut-off.
Which income tax dates apply to exporters in the 2026-27 transition year?
Two separate tax years run side by side in 2026-27, according to the Income Tax Department FAQ on returns.
- Income of FY 2025-26 (AY 2026-27): return filed under the Income-tax Act, 1961. The FAQ gives the due date as 31 July 2026, or 31 August for non-audit cases, and the tax audit report date as 30 September 2026 where the return is due on 31 October 2026.
- Belated return for AY 2026-27: by 31 December 2026 or before assessment is completed, whichever is earlier.
- Income of tax year 2026-27: governed by the Income-tax Act, 2025. The first advance tax instalment was due on 15 June 2026, and presumptive taxpayers pay in one instalment by 15 March under section 408(2) (Tax payments FAQ).
- Return for tax year 2026-27: filed under section 263 of the 2025 Act, and not due until July 2027 according to the FAQ.
What are the annual export compliance deadlines for FY 2026-27?
The annual export compliance deadlines for FY 2026-27 are the LUT before the first export, the IEC update by 30 June, advance tax from 15 June to 15 March, the AY 2026-27 income tax return dates and GSTR-9 by 31 December. Check each date against the linked source, since governments can extend dates by notification.
| Month | Compliance item | Rule | Best for |
|---|---|---|---|
| April (before first export) | File LUT in Form GST RFD-11 for the financial year | Rule 96A(1); Circular 8/8/2017-GST, para 2(b) | GST-registered exporters invoicing without IGST |
| April to June | Update or confirm IEC details online | FTP 2023 para 2.05(d) | Anyone holding an IEC |
| 15 June 2026 | First advance tax instalment for tax year 2026-27 | Tax payments FAQ 18 | Exporters whose tax payable is Rs 10,000 or more |
| 31 July 2026 (31 August for some non-audit cases) | Income tax return for AY 2026-27 | Income tax returns FAQ 16 | Freelancers and proprietors without a tax audit |
| 30 September 2026 | Tax audit report for AY 2026-27 where the return is due 31 October | Income tax returns FAQ 24 | Exporters whose accounts need a tax audit |
| 31 October 2026 | Income tax return for AY 2026-27 in audit cases | Income tax returns FAQ 24 | Companies and audited businesses |
| 30 November 2026 | Last date to correct GSTR-1 details for FY 2025-26, or the date you file the annual return if earlier | Section 37(3) proviso | Exporters who reported an export invoice wrongly |
| 31 December 2026 | GSTR-9 annual return for FY 2025-26; belated income tax return for AY 2026-27 | Rule 80(1); Income tax returns FAQ 7 | GST-registered exporters; anyone who missed the return date |
| 15 March 2027 | Full advance tax for presumptive taxpayers for tax year 2026-27 | Section 408(2), Tax payments FAQ 19 | Professionals using presumptive taxation |
| 31 March 2027 | LUT for FY 2026-27 expires; file a new one for FY 2027-28 | Circular 8/8/2017-GST, para 2(b) | All LUT filers |
What happens if an Indian exporter misses an export compliance deadline?
Missing an export compliance deadline leads to a penalty, a late fee or interest, depending on the law involved. FEMA delays can also restrict how you export, and GST delays can turn a zero-rated export into one on which you pay IGST.
- FEMA penalty: A contravention of FEMA rules can lead to a penalty of up to three times the sum involved, or up to Rs 2 lakh where the amount cannot be quantified, under section 13(1) of FEMA.
- Unrealised exports: If export proceeds stay unrealised for more than one year beyond the due or extended date, further exports are allowed only against full advance or an irrevocable letter of credit (Regulation 13).
- GST on exports: Under an LUT, if a services invoice is unpaid after one year, or the FEMA period with any extension if later, you must pay IGST with interest within 15 days (Rule 96A(1)(b)).
- GST late fee: A late GSTR-1 or GSTR-3B attracts a late fee of Rs 100 per day, up to Rs 5,000 (section 47(1)). Unpaid tax attracts interest of up to 18% (section 50).
- IEC: An IEC that is not updated in the April to June window is de-activated until it is updated (FTP para 2.05(e)).
- Income tax: A late return attracts a fee of Rs 1,000 if total income is up to Rs 5 lakh and Rs 5,000 otherwise. For AY 2026-27 the fee is under section 234F of the 1961 Act (FAQ 7), and later years fall under section 428 of the 2025 Act (FAQ 25).
If a FEMA date is about to pass, write to your AD bank before it does. The bank may extend the time to submit the EDF (Regulation 3(2)(c)) or to realise proceeds (Regulation 5(1)). See how to get an extension of the export realisation period.
What is the timeline for each export invoice under FEMA and GST?
Each export invoice starts its own timeline on the invoice date. The EDF is due within 30 days of the end of the invoice month, payment is due within nine months, and under an LUT the GST deadline follows one year or the FEMA period, whichever is later.
| Trigger event | Due date | Filed where | Best for |
|---|---|---|---|
| Services invoice raised | EDF within 30 days from the end of the invoice month; non-software exporters may instead submit on or before the payment date (Regulation 3(2)) | AD bank; STPI is also allowed for software; the SEZ Development Commissioner for SEZ units | All service exporters, see EDF form |
| Goods shipped | EDF at the time of export; deemed part of the shipping bill at EDI ports (Regulation 3(1)) | Customs, or SEZ Development Commissioner | Goods exporters, see shipping bill |
| EDF received by bank | Entered in EDPMS within five working days (Regulation 18(1)(b)) | Your AD bank does this | Checking that your entry appears in EDPMS |
| Invoice date (services) or shipment date (goods) | Realise full value within nine months, or twelve months if invoiced or settled in INR (Regulation 5(1)) | Payment received through your AD bank | All exporters, see export realisation period |
| Payment received for invoice up to Rs 10 lakh | Exporter declaration, per transaction or quarterly for bulk closure (Regulation 4(2)) | AD bank, closes EDPMS entry | Small-ticket freelancers, see EDPMS closure |
| Services invoice under LUT unpaid | IGST with interest within 15 days after one year or the FEMA period, whichever is later (Rule 96A(1)(b)) | GST portal | GST-registered exporters |
| Relevant date for a GST refund | Refund application within two years (section 54(1)) | GST portal | Exporters claiming refund of unused input tax credit, see GST refund on export of services |
What mistakes do Indian exporters make with an export compliance calendar?
- Old periods: Using SOFTEX forms or older rules after 1 October 2026. The 2026 Regulations apply from that date, and the realisation period is nine months after the 22 September 2026 amendment.
- Calendar months: Treating realisation as a month-end task. The nine months run from each invoice date, so every invoice has its own date.
- Late LUT: Issuing zero-rated export invoices in April before filing the new year's LUT. The LUT must be furnished prior to export.
- Ignoring IEC: Assuming an IEC needs no action once issued. It must be updated or confirmed every April to June.
- Wrong tax year: Paying 2026-27 advance tax against AY 2026-27. The tax payments FAQ says advance tax for income from April 2026 is paid against tax year 2026-27.
- Waiting on banks: Assuming the bank will request extensions on your behalf. Extensions under FEMA are given on a request from the exporter citing reasons.
How did we verify this?
Every rule, deadline and form on this page is linked to its official source, checked on the dates below.
- Foreign Exchange Management (Export and Import of Goods and Services) Regulations, 2026, Notification No. FEMA 23(R)/2026-RB (amended up to 22 September 2026), Regulations 1(2), 2(1)(f), 3(1), 3(2)(a)-(c), 4(2) provisos, 5(1), 13, 18(1)(b) (checked 8 Oct 2026)
- Foreign Exchange Management (Export and Import of Goods and Services) (Amendment) Regulations, 2026, Notification No. FEMA 23(R)/(1)/2026-RB, 22 September 2026, Regulation 5(1): fifteen months replaced by nine months; eighteen by twelve (checked 8 Oct 2026)
- RBI A.P. (DIR Series) Circular No. 20, RBI/2025-26/194, 16 January 2026, Supersession of export Master Direction and SOFTEX circulars from 1 October 2026 (checked 8 Oct 2026)
- The Foreign Exchange Management Act, 1999 (text hosted by IFSCA), Section 13(1) (checked 8 Oct 2026)
- CGST Rules, 2017: Rule 96A (Export under bond or Letter of Undertaking), Rule 96A(1)(a), (1)(b), (2) (checked 8 Oct 2026)
- CBIC Circular No. 8/8/2017-GST, 4 October 2017, Para 2(b) validity of LUT (checked 8 Oct 2026)
- GST Portal FAQs: Furnishing of Letter of Undertaking for Export of Goods or Services, FAQ 2 and 3 (checked 8 Oct 2026)
- CGST Rules, 2017: Rule 59 (Form and manner of furnishing details of outward supplies), Rule 59(2) IFF (checked 8 Oct 2026)
- CGST Rules, 2017: Rule 61 (Form and manner of furnishing of return), Rule 61(1)(i), (1)(ii) table, (3) (checked 8 Oct 2026)
- CGST Rules, 2017: Rule 80 (Annual return), Rule 80(1) (checked 8 Oct 2026)
- CGST Act, 2017: Section 37 (Furnishing details of outward supplies), Section 37(3) first proviso (checked 8 Oct 2026)
- CGST Act, 2017: Section 47 (Levy of late fee), Section 47(1) (checked 8 Oct 2026)
- CGST Act, 2017: Section 50 (Interest on delayed payment of tax), Section 50(1) (checked 8 Oct 2026)
- CGST Act, 2017: Section 54 (Refund of tax), Section 54(1) and Explanation (1) (checked 8 Oct 2026)
- GST Portal FAQs: Form GSTR-1, FAQ 10 (due dates) and FAQ 11 (checked 8 Oct 2026)
- Income Tax Department: Income Tax Act 2025 FAQs, Income Tax Returns, FAQs 1, 4, 7, 12, 16, 24 and 25 (checked 8 Oct 2026)
- Income Tax Department: Income Tax Act 2025 FAQs, Tax Payments, FAQs 14, 17, 18, 19 and 22 (checked 8 Oct 2026)
- Income Tax Department: Objective and scope of the New Act, FAQ 2 (repeal of the 1961 Act on 01.04.2026) (checked 8 Oct 2026)
- Income Tax Department: Salaried Individuals for AY 2026-27 (Return / Forms applicable), Form 67 filed on or before the due date under section 139(1) of the 1961 Act (checked 8 Oct 2026)
- DGFT, Foreign Trade Policy 2023, Chapter 2, Para 2.05(a), (d) and (e) (checked 8 Oct 2026)
Frequently asked questions
When is the EDF due for services invoiced in October 2026?
For services invoiced in October 2026, the EDF is due within 30 days from 31 October, so by 30 November 2026, under Regulation 3(2) of the 2026 FEMA export regulations. One EDF can cover all services exported that month. Exporters of services other than software may instead submit it on or before the date payment is received.
Does the nine-month export realisation period start from the invoice date or the payment due date?
For services, the nine-month export realisation period starts from the date of invoice, and for goods it starts from the date of shipment. If the export is invoiced or settled in Indian rupees, the period is twelve months. Your AD bank can extend it on request.
Do freelancers without GST registration need to file an LUT every year?
No. An LUT in Form GST RFD-11 is filed only by GST-registered persons who want to export without paying IGST. A freelancer who is not registered under GST has no LUT, GSTR-1 or GSTR-3B dates. FEMA dates such as the EDF and the nine-month realisation period still apply to every export.
What happens to an IEC that is not updated between April and June?
Under para 2.05(e) of the Foreign Trade Policy 2023, an IEC that is not updated within the April to June window is de-activated. It can be activated again once the update is completed successfully. The update is needed every year, and a holder with no changes must still confirm the details online.
Which GSTR-1 table carries goods export invoices to Customs?
Goods export invoices go in Table 6A of GSTR-1. Under Rule 96A(2) of the CGST Rules, export invoice details in GSTR-1 are sent electronically to the Customs system, and Customs confirms the export back to the GST portal. A monthly GSTR-1 filer reports them by the 11th of the following month.
Is SOFTEX still part of the export compliance calendar for software exporters?
No. From 1 October 2026, RBI's A.P. (DIR Series) Circular No. 20 superseded the SOFTEX circulars, and software exports are declared in the EDF under the 2026 FEMA regulations. The EDF is due within 30 days from the end of the invoice month and can be submitted to an AD bank, STPI or the SEZ authority.
How long can a GST refund claim for export of services wait?
Under section 54(1) of the CGST Act, a GST refund application must be filed before two years from the relevant date. For exports, this includes refunds of tax paid on zero-rated supplies and of unused input tax credit. Filing after the two-year limit means the refund claim is not allowed.