How Can an Indian Exporter Track Export Compliance Deadlines?

Export compliance tracking means keeping a dated record of every export invoice and the filings and payments that depend on it. Each invoice starts its own clock under the FEMA export regulations, and GST adds its own dates. A tracker only needs to show what is due, for which invoice, and with which office.

• EDF: Services exporters file an Export Declaration Form within 30 days from the end of the month in which the invoice was raised, and one EDF can cover all of a month's exports (Regulation 3(2)). See EDF form for exports.
• Realisation: The full export value must be realised and repatriated within nine months of the invoice date for services, or twelve months if invoiced or settled in rupees (Regulation 5(1)). See export realisation period.
• EDPMS: The AD bank enters the EDF in EDPMS within five working days and marks the entry off once the export value is realised (Regulation 18(1)).
• LUT: Exporters who supply services without paying IGST do so under a bond or Letter of Undertaking, and CGST Rule 96A sets the conditions, including payment of IGST with interest if the export condition is not met (Rule 96A). See what is LUT.
• GST returns: Outward supplies, including exports, are reported in GSTR-1, and the GST Portal guide lists the due dates (GSTR-1 FAQs).

These dates are the same whichever tool holds them. A tracker is only useful if it carries the invoice date, the EDF status, the realisation due date and the LUT validity.

Any exporter with more than a few invoices a month benefits from a system, because each invoice has its own EDF and realisation dates. The regulations apply to every exporter, so the question is only how much tracking effort the volume of invoices justifies.

An exporter can set up a tracker by listing every invoice with its date, currency, amount and client, then adding computed due dates for the EDF and for realisation. The tracker is updated when the EDF is filed, when payment arrives and when the bank closes the entry.

1. List each export invoice with its number, date, currency, amount and client name.
2. Add the EDF due date: 30 days from the end of the invoice month for services (Regulation 3(2)).
3. Add the realisation due date: nine months from the invoice date, or twelve months if invoiced or settled in rupees (Regulation 5(1)).
4. Record each payment received against the invoice, with the date and the bank credit, so part payments are visible.
5. Note the date the AD bank closes or updates the EDPMS entry, and ask the bank if an entry stays open after full payment.
6. Record the LUT validity for the financial year and the GST return dates in the same calendar.
7. Review the list monthly and set a reminder well before each realisation date, so an extension request reaches the AD bank in time.

Five approaches are common: a spreadsheet, a calendar, accounting or ERP software, records from the AD bank and the GST portal, and a professional such as a chartered accountant. The right mix depends on invoice volume and on how much of the work the exporter wants to delegate.

A missed date can lead to an open EDPMS entry, restrictions on later exports, a FEMA penalty or loss of the GST export treatment. The consequence depends on which date is missed, and the AD bank can often extend the realisation period if the exporter asks with reasons.

• Extension: The AD bank may allow more time to realise export proceeds if it is satisfied with the reasons cited (Regulation 5(1), second proviso). See extension of the realisation period.
• Late EDF: The AD bank may extend the EDF submission period for services on a request that gives reasons (Regulation 3(2)(c)).
• Export limits: If 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). See export payment not received.
• GST: Under an LUT, IGST with interest becomes payable if the export condition is not met within the period in Rule 96A (Rule 96A).
• Refund: A GST refund application must be made within two years from the relevant date (section 54(1)).

Raise the issue with the AD bank before the due date and put the reasons in writing. Keep invoices, contracts and bank credit advices with the tracker, and take advice from a FEMA or GST professional for a specific case.

A tracker should show the EDF date, the EDPMS entry, the realisation date and the GST dates for each invoice. The services EDF is due within 30 days of the invoice month end, and realisation within nine months of the invoice date, or twelve if invoiced or settled in rupees.

• Old periods: Using the earlier fifteen and eighteen month realisation periods. The September 2026 amendment replaced them with nine and twelve months (Regulation 5(1), footnotes).
• Month end: Counting the EDF 30 days from the invoice date. The period runs from the end of the invoice month (Regulation 3(2)).
• Part payments: Marking an invoice as paid after a partial receipt, which leaves the balance with no due-date alert.
• Bank entry: Assuming the AD bank has closed the EDPMS entry after payment without asking for confirmation.
• LUT validity: Forgetting to file the LUT for the new financial year before the first export of that year.
• Single tool: Relying on one tool with no cross-check against the bank and the GST Portal.

Every rule, deadline and form on this page is linked to its official source, checked on the dates below.

1. 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), 3(1), 3(2), 4(2), 5(1), 5(2), 13, 18(1) (checked 9 Oct 2026)
2. CGST Rules, 2017: Rule 96A (Export under bond or Letter of Undertaking), Rule 96A(1) (checked 9 Oct 2026)
3. GST Portal FAQs: Furnishing of Letter of Undertaking for Export of Goods or Services, LUT filing (checked 9 Oct 2026)
4. GST Portal FAQs: Form GSTR-1, Due dates (checked 9 Oct 2026)
5. CGST Act, 2017: Section 54 (Refund of tax), Section 54(1) (checked 9 Oct 2026)